Training Session Purpose

Training Session Purpose
Goals/Objectives Learn to ‘talk-the-talk’ Learn why PSM and RMP exist Learn a bit about ammonia Learn the PSM ‘schedule’ Understand the consequences of failure to follow Learn to better understand your existing program Understand requirement changes and trends in PSM and where EPA and OSHA focus now Learn those areas that may change when your system changes

What are PSM and RMP? Process Safety Management (PSM)
Occupational Safety & Health Administration (OSHA) OSHA 29 CFR (Process Safety Management of Highly Hazardous Chemicals) “inside” the plant (loosely speaking) Risk Management Program (RMP) Environmental Protection Agency (EPA) EPA 40 CFR Part 68 (Accidental Release Prevention Requirements: Risk Management Programs Under Clean Air Act Section 112(r)(7) “outside” the plant (loosely speaking) Lingo Are PSM/RMP Interchangeable? - No! Department of Homeland Security Site security plans PLUS the General Duty Clause!!!

What is the General Duty Clause All About? - 1
General Duty Clause(s) EPA “Purpose and General Duty – “It shall be the objective of the regulations and programs authorized under this subsection to prevent the accidental release and to minimize the consequences of any such release of any substance listed pursuant to paragraph (3) or any other extremely hazardous substance. The owners and operators of stationary sources producing, processing, handling or storing such substances have a general duty, in the same manner and to the same extent as section 654, title 29 of the United States Code, to identify hazards which may result from such releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur.” (Section 112(r)(1) of the Clean Air Act) OSHA Act of 1970: “The owner shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” (29 USC 654 )

What is the General Duty Clause All About? - 2
You can be in violation if: A known hazard exists This hazard poses a threat to employees lives or personal safety If the hazard is recognized and addressed by the industry Employees are regularly exposed to that hazard Very open ended Basically, if the industry recommends it, you must do it!!!

The Unofficial Phases of PSM Implementation
Phase 1: Installation of Kryptonite! PSM Programs Initially Created in accordance with OSHA/EPA OSHA/EPA Knowledge Is Limited Phase 2 – The Era of the Kryptonite! Programs sit on the Shelf OSHA/EPA Knowledge of NH3 PSM Begins to Grow Phase 3 – Our Kryptonite Needs Fixed???!!! OSHA/EPA Personnel Have Extensive Knowledge of NH3 PSM The fines are coming!

December 2, 1984 - Bhopal, India
Why PSM and RMP? - 1 December 2, Bhopal, India 100,800 lbs of methyl isocyanate (MIC) gas released from underground storage tanks Union Carbide India Limited (UCIL) Potential employee sabotage Nocturnal temperature inversion Substandard living/housing conditions By the following morning, over 2,000 dead and 300,000 were injured by morning 1,500 people died in subsequent months Emergency services were completely overwhelmed Emergency Services/Police provided complicating instructions Residents were unaware that the simple act of covering their faces with wet cloths and lying indoors on the floor provided effective protection against the gas

Why PSM and RMP? - 2 December, 1984 – Institute, West Virginia
Union Carbide Cyanide 135 Hospitalized No temperature inversion America’s wake-up call!

Various Industry Organizations
Our Industry Various Industry Organizations International Institute of Ammonia Refrigeration (IIAR) American National Standards Institute (ANSI) American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE) American Society of Mechanical Engineers (ASME) Refrigerating Engineers and Technicians Association (RETA) Other organizations indirectly will affect as well

The “What’s” About Ammonia
Basic Facts about ammonia Ammonia is considered “highly hazardous” by OSHA Ammonia is stable and naturally occurring Ammonia is a strong alkali Lighter than air (when not saturated with water Ammonia has an “affinity” for water Human body is approximately 65% water Readily damages all body tissues Target easily accessible/exposed water sources on body (eyes, ears, mouth, etc.) Personal protective equipment (PPE) is required Incompatible with copper (and copper alloys) and galvanized steel Incompatible with certain kinds of rubber Considered Non Flammable for Shipping Upper and Lower Flammability Limits: 15-28% Concentration Auto Ignition Temperature: 1,200+ °F H 2 O N 3 H 1 3 ALK

If It Does This to a Buck…
Dollar Shrinking – It Isn’t Inflation Either If it can do this to a dollar, imagine what it will do to your unprotected eyes (which has MORE water than the bill)!!!

Ammonia and How It Affects You
Various Exposure Limits 0-50 ppm - Detectable odor ppm - Mild eye, nose, and throat irritation; may develop tolerance in 1-2 weeks with no adverse effects thereafter 140 ppm - Moderate eye irritation; no long-term tissue injury in exposures of less than 2 hours 300 ppm - IDLH 400 ppm - Moderate throat irritation 700 ppm - Immediate eye irritation/injury ppm - Directly caustic to airway, spasms of the larynx and bronchospasms, severe eye and skin injury/irritation 1700 ppm – Uncontrollable spasm of the larynx 2500 ppm - Fatality (after half-hour exposure) ppm – permanent destruction of lung, sinus, and throat tissues. Also significant pain 5000 ppm - Rapidly fatal exposure

Is Ammonia All THAT Terrible?
Keep Things in Perspective Naturally Occurring Commonly Used on Farms Like Any Tool If You Fail to Respect Ammonia, Ammonia Will Fail to Respect you Ammonia Ammonia

Why Ammonia Then? Why not Freon
Naturally occurring Environmentally friendly Self alarming Inexpensive If You Fail to Respect Ammonia, Ammonia Will Fail to Respect you Freon and Fluorocarbons Fire creates phosgene gas (mustard gas) Suffocant (heavier than air) Can’t smell it Expensive

Remember that these are REQUIRED by OSHA and EPA!!!
Who Has a Role? EVERYONE! Management PSM Coordinator Operators Mechanics Floor Personnel Contractors! Remember that these are REQUIRED by OSHA and EPA!!!

The “When’s” of PSM/RMP
Every Year Safety Inspection Forms Review Standard Operating Procedures (SOPS) and SIGN OFF Review contractors performance Every three years Compliance Audit Operator and Mechanic Refresher training Every five (5) years Submit RMP to the EPA Process Hazard Analysis (PHA) revalidation If you have electronic maintenance system (e.g., Maximo), this would be a good tool to use

Consequences – “OSHA/EPA Shock and Awe” - 1
February 12, 2004 John Morrell Company - Sioux Falls, South Dakota People living within ¾ miles told to stay in home 19,300 pound release from a 5” line 77 Injuries Full facility evacuation High pressure liquid $57,000 in fines Federal investigators said that John Morrell should have done a better job of watching out for corrosion on pipes [mechanical integrity]…

March 27, 1999 Albertsons Distribution Center – Denver, Pennsylvania NO RELEASE Potential disgruntled employee $170,000 ONLY ammonia PSM related October 10, 2010 Tanner Industries, East Providence, Rhode Island $149,080 Emergency Response Plan didn’t address releases during times when facility isn’t occupied.

January 22, 2000 Wells Dairy – LeMar, Iowa 100,000 pound release Loss of ammonia compressor room and additional areas $15,000 fine issued (originally $20,000) by Iowa’s OSHA Worst enemy (fire) may have been their best friend? As of October 2010, courts are still resolving the civil liability. Wells Dairy, the construction firm, and RVS were found to be at fault, but no financial rulings have been awarded

September, 2010 Tree Top Incorporated, Selah, Washington 1,100 pounds of ammonia released from relief valve on July 10, 2009 Facility incident occurred around 7pm am, but didn’t inform EPA until 1:30 pm on July 11, 2009 $107,000 fine Pilgrim's Pride, Russellville, Alabama Incident investigation from ammonia odors, tripping hazards, and cutting and stabbing injuries (Source: TimesDaily.com) Improper Ventilation $5,000 fine Inadequate emergency preparedness for ammonia release - $5,000 Fines were issued as a result of other OSHA issues.

October 28, 2010 American Seafoods International, LLC, New Bedford, Massachusetts NO INJURIES $195,000 fine for inadequate PSM program including inadequate SOPs and lack of inspections (Mechanical Integrity Program) Additional $84,000 fine for failure to update Process Safety Information and failure to investigate a 2001 incident December 1, 2004 Associated Milk Producers – New Ulm, Illinois $88,400 fine “…for failure to immediately notify the NRC of a 3,873-pound anhydrous ammonia release during a fire at the facility…” (approximately a 5 hour delay) and follow up wasn’t reported for 80 days June 18, 2010 Creekstone Farms Premium Beef, Arkansas City, Kansas $130,00 fine Inadequate or missing: employee participation, employee training, process hazard analysis, SOPs, emergency response program, and mechanical integrity

LAST BUT NOT LEAST!!! January 24, 2001 Ammonia Theft A couple of young thieves trying to steal the anhydrous ammonia from a nursing tank in a cotton field in Mississippi had an accident and the pressurized gas escaped, burning them and about 25 to 30 acres of the field. "They were extracting it from the tank, and because it was pressurized, they either couldn't cap it back off or couldn't contain it in their tank," an officer said. "The chemical began to release and got on their clothes and burned them. "They stripped off their clothes and ran to a creek where the sheriff found them buck naked and arrested them," he said. Ammonia theft is a huge industry issue!

Are these image you want your customers to remember about you?

PSM (and RMP) Elements/Programs
Employee Participation Mechanical Integrity Incident Investigations Trade Secrets Process Safety Information (PSI) Process Hazard Analysis (PHA) Standard Operating Procedures (SOPS) Pre-Startup Safety Review Management of Change Contractor Qualification Compliance Audit [Operator and Mechanic] Training Hot Work Emergency Planning and Response

Employee Participation Program
General Program Description Ensures employees are actively involved in the creation and maintenance of the PSM Program. Basic Principals To ensure employee involvement in the PSM/RMP Program To ensure employee access to information to the PSM/RMP Program To ensure proper program information dissemination Specific Areas of Interest/Attention Process Hazard Analysis (PHA) Standard Operating Procedures (SOPs) Consider basic ammonia awareness for all employees DOCUMENTATION IS IMPORTANT!!!

Mechanical Integrity Program - 1
General Program Description Creates a structure of procedures and schedules to ensure safe operation of ammonia refrigeration equipment, piping, and systems. Basic Principals To properly identify all equipment in the ammonia refrigeration system To ensure accurate operating and maintenance procedures have been created To ensure adequate operator and mechanic training has been established To ensure all necessary testing, inspection, and preventative maintenance is scheduled To identify all equipment deficiencies and to take corrective actions to address those deficiencies

Mechanical Integrity Program - 2
Specific Areas of Interest Standard Operating Procedures Operator Training Maintenance Procedures Computerized Databases (e.g., Maximo or other maintenance planning programs) This is a MAJOR thrust of recent OSHA inspections Do you have a Mechanical Integrity or “break it/fix it” program Documentation, documentation, and more documentation

Incident Investigation Program
General Program Purpose Implements procedures for investigating serious incidents and near‑misses and to prevent any recurrence of similar incidents. Basic Principals Define what constitutes an incident and a ‘near-miss’ Create a structure for performing incident (and ‘near-miss’) investigations Identify methods for addressing recommendations as the result of near incidents (and ‘near-misses’) Establishing methods of communicating the status of the investigation team 100 Pounds in 24 hours constitutes an ‘incident’ Other Notes Incident Investigations must be kept for five (5) years

Process Safety Information - 1
General Program Purpose To identify the hazards posed by anhydrous ammonia and the process (the refrigeration system) in which it is used including: The specific [chemical] hazards of anhydrous ammonia The technology used in the ammonia refrigeration system, and The equipment used in the ammonia refrigeration system. Basic Principals Hazards of anhydrous ammonia including discussions of: Toxicity information for anhydrous ammonia Physical data of anhydrous ammonia Reactivity of anhydrous ammonia Corrosivity of anhydrous ammonia Thermal and chemical mixing of anhydrous ammonia Historical reactions to anhydrous ammonia exposure

Basic Principals (Continued) Discussion of technology associated with the anhydrous ammonia refrigeration system simplified process or block flow diagram process chemistry maximum intended inventory safe lower and upper operating limits consequences of deviation from normal operating limits Lost or missing information/data EVAPORATORATIVE CONDENSER LIQUID RECEIVER SUCTION ACCUMULATOR MOTOR COMPRESSOR EVAPORATOR COIL

Basic Principals (Continued) Discussion of equipment associated with and used in the ammonia refrigeration system materials of construction piping and instrumentation diagrams (P&IDs) electrical classification relief system design and design basis ventilation system design and design basis design codes and standards employed material and energy balance (system load estimate) safety systems

Piping and Instrumentation Diagrams (P&IDs) and Block/Process Flow Diagrams – The Difference Between…

Special Considerations Relief Valve Calculations Modifications to ANSI/ASHRAE 15 More strict requirements for maximum distance from valve to header (or direct atmospheric discharge, when applicable) Header diameter requirements can be affected These lines are grandfathered if there is no modification to that run This is a general duty clause issue and a code/ordinance compliance issue

Process Hazard Analysis - 1
General Program Purpose to analyze potential hazards associated with the anhydrous ammonia refrigeration system Basic Principals Establish an acceptable methodology Determine appropriate potential hazards to address Develop an appropriate PHA Team Identify recommendations to improve the safety of the anhydrous ammonia refrigeration system Create a structure to track recommendations and ensure their resolutions

Acceptable Methodologies What if Checklist What if/checklist Hazard and Operability Study (HAZOP) Failure and Mode and Effects Analysis (FMEA) Fault Tree Analysis “Or other equivalent method” Generally What If/Checklists are performed

What should be addressed? Known hazards Previous incidents Engineering and administrative controls Consequences of control failures Facility site issues Human Factors A facility walk through and inspection should be performed by the Team! Who does it? Someone knowledgeable in the analysis method used Someone knowledgeable in refrigeration plant design Someone knowledgeable in refrigeration plant operations

Additional Notes A listing of recommendations must be made Recommendations must be reviewed in a ‘timely’ manner The EPA and OSHA both review for completeness during audits The PHA should be an open dialog of potential hazards seen by the each member of the team based on their own experiences The team should NOT be exclusively from the facility Only each unique type of equipment needs to be reviewed and not each individual piece of equipment Since over 5 years, perspectives, experience, personnel, and the methods of performing PHAs changes, it is recommended to ‘start over” and not just review the previous PHA. Unofficial term/concept – equipment classification

Standard Operating Procedures - 1
General Program Purpose To provide clear instructions for anhydrous ammonia refrigeration system operation Basic Principals Identify safety and health information regarding anhydrous ammonia Identify the required operating phases Identification of safety features associated with each type of ammonia refrigeration equipment Identify the operating limits of each type of ammonia refrigeration equipment

Operating Phases Initial Startup Normal Operations Temporary Operations Emergency Shutdown Emergency Operations Normal Shutdown Startup Following a Turnaround or after an Emergency Shutdown Applicability Not All Are Applicable to Ammonia Refrigeration Some Are Combined (Emergency Shutdown and Emergency Operations)

Safe Work Practices Hot Work Confined Space Entry Lockout/Tagout (LOTO) Line Opening Procedure Other notes When the system changes, the SOPs may as well These must be annually reviewed The annual review MUST be documented. The EPA and OSHA will fine you during an audit if you do not show record of SOP annual review! These should be in easy access to operators/mechanics

Operator and Mechanic Training Program - 1
General Program Purpose provides on and off the job training for mechanic/operators to enable them to safely operate the ammonia refrigeration system Basic Principals Define qualification Identify employees requiring training If someone is touching the system, they better have records showing they are qualified to do what they are doing. System wide training versus task training Identify acceptable training types Identify documentation to be completed Define general requirements Identify terms of refresher training Identify appropriate ‘grandfathering’

Operator and Mechanic Training Program - 2
Important Notes What is Qualification Task related training System related training Refresher Training Every three (3) years (required) Can be open ended and subjective Internal and external Annual review of training is recommended (this eliminates the confusion of the three year timing) May be required if new equipment is added Grandfathering If you’ve been running the system since before May 26, 1992 Documentation is the difference!!!

Contractor Qualification Program - 1
General Program Purpose evaluates contractors’ safety performance while ensuring contractors understand known hazards and can work safely Basic Principals Define means used to select contractors Define the steps necessary to qualify a contactor Identify the facility’s requirements and responsibilities to contractors working at the facility Identify the contractors requirements and responsibilities

Facility’s Responsibilities the Contractor evaluating the contractor’s qualifications to perform the work projected informing the contractor of known fire, explosion, and toxic release hazards (especially for non ammonia contractors) explaining applicable OSHA regulations and how they affect the project implementing and employing safe work practices contractor entry and exit periodic contractor evaluation providing facility safe work practices and emergency response plan reviewing and evaluating the contractor’s safe work practices and training and ensuring that each contract employee has been informed and trained and understood the training reviewing the design, engineering, and P & IDs for the project with the contractor performing site walk through noting the hazards associated with ammonia system maintaining a separate contractor employee injury and illness log related to the contractor’s work on the project

Contractor’s Responsibilities to Their Employees ensuring contractor employees are trained in the work practices (especially safe work practices) instructing employees of known potential fire, explosion or toxic release hazards and the applicable provisions of emergency response plan documenting that each employee has received and understood the instructions and training ensuring that employees follows safety rules. advising your company of any unique hazards presented by the contractor’s work or of any hazards found by the contractor’s work. Additional Notes Contractor information must be updated annually Documentation is a MUST! OSHA and the EPA will fine you if you do not have documentation for your contractors during audits

Management of Change Program
General Program Purpose establishes and implements written procedures for managing changes to the technology, equipment, and procedures for the anhydrous ammonia refrigeration system. Basic Principals ensure all appropriate anticipated reviews are considered prior to commencing a refrigeration plant modification Identify potential documentation changes required as the result of proposed changes Ensure appropriate document updating is completed Ensure design reviews are completed Ensure safety and health considerations are addressed as the result of changes Does NOT apply to “Replacement in Kind”… but…

Pre-Startup Safety Review Program
General Program Purpose ensures all PSM and RMP Program related areas have been addressed prior to introducing ammonia to the refrigeration system. Basic Principals Ensure all PSM documentation has been modified to suit the modified facility prior to introducing ammonia into the new system/component Ensure all necessary training has been performed regarding new equipment/processes prior to introducing ammonia into the new system/component

Compliance Audit Program
General Program Purpose To verify that the PSM and RMP programs meets federal requirements and are implemented Basic Principals Establish audit frequency and timing Define the requirements of the auditor and/or team Identify the scope of the audit Define requirements for addressing and tracking audit recommendations Additional Notes The “team” You can have a team; however, having an individual with experience auditing programs is a must! Don’t audit yourself! Two most recent audits must be maintained

General Program Purpose
Trade Secret Program General Program Purpose Defines the rights of employees regarding access to PSM and the effects of trade secrets Basic Principals Regardless of potential industry secrets, the employer must inform employees working with the process about the process Not applicable to ammonia refrigeration system except in rare circumstances

Risk Management Program - 1
General Program Purpose To summarize, document and communicate the elements of the Risk Management Program (RMP) to the Environmental Protection Agency (EPA) and other state and federal agencies and responders Basic Principals Identify the covered process Describe the anhydrous ammonia refrigeration system in general as it relates to the facility and local community (executive summary) Describe the Prevention Program 3 information

Basic Principals (Continued) Management System A listing of how the PSM/RMP will be administered, but more importantly, by whom Risk Management PLAN vs. Risk Management PROGRAM Risk Management PLAN is a document that is [re]submitted to the EPA at least every five (5) years or sooner if facility modifications require resubmittal The Risk Management PROGRAM discusses how the PSM Program and Emergency programs are administered and provides details about the covered “process” BOTH are required – Many facilities do not have a “Program”

Basic Principals (Continued) Provide an Off-Site Consequence Analysis (OCA) Worst Case Alternative Release Identify and describe any accidents occurring in the past five (5) years Describe the Emergency Planning and Response Program

Did you say something, Hank?
Hot Work Program General Program Purpose Provide rules for performing any open flame or open arc work at the facility Basic Principals OSHA 29 CFR (a) If you don’t have one, make sure your contractors program is sufficient – They could destroy your facility! Did you say something, Hank?

Confined Space Entry Program
General Program Purpose Provides rules/restrictions for entering confined spaces at the facility Basic Principals OSHA 29 CFR Is large enough and so configured that an employee can bodily enter and perform assigned work; and Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and Is not designed for continuous employee occupancy. Most ammonia system do not have confined spaces… BUT Condensers Penthouse air units Confined space or PERMIT REQUIRED confined space

Lockout Tagout Program
General Program Purpose Provide rules for working with and controlling stored energy systems (electrical, mechanical, and electro-mechanical) Basic Principals OSHA 29 CFR (The control of hazardous energy (lockout/tagout) “Suicide Prevention Program!”

What Has Changed Recently and OSHA/EPA Trends - 1
ANSI/ASHRAE Methods for determining relief valve discharge pipe size Reduces allowable lengths from valve to header Changes discharge calculations for valves discharging vapor back into system via a relief valve Fire Control Boxes IIAR and RETA with assistance from International Codes Consultants (ICC) have been successful in convincing many localities that fire control boxes (“dump boxes”) should not be required Many responders don’t understand what they are for and how to operate them OSHA has changed target from Petro/Chemical industry to ammonia

What Has Changed Recently and OSHA/EPA Trends - 2
Audit Focus Major aim has been Mechanical Integrity Documentation! Paper versus electronic - REAL Signatures Training – review of training documentation Safe Work Practices Ammonia detection systems calibrated and documented “Non Negotiables” SOPs annually signed off PHA performed at five (5) years All contractors have documentation Audits performed every three years promptly Recommendations from audits and PHAs are addressed RMP resubmittal on-time

What Changes if the System Changes… - 1
Employee Participation ONLY completion of employee Participation Forms Process Safety Information Information Relevant to the Technology of the System Block/Process Flow Diagram Process Chemistry (ONLY if a new classification of equipment is added) Inventory Analysis Safe Lower and Upper Operating Limits (ONLY if a new classification of equipment is added) Consequences of Deviation (ONLY if a new classification of equipment is added)

Process Safety Information (Continued) Information Relevant to the Equipment in the Process Piping and Instrumentation Diagram (P&ID) Relief System and Design Basis Material and Energy Balance Safety Systems Standard Operating Procedures (SOPs) If a new classification of equipment is installed, there may be an additional chapter needed Most changes would be clerical in nature (to include new equipment numbers) if no new classification of equipment is added Operator/Mechanic Training Only new training performed and forms completed

Contractor Qualification Program The program won’t change, but you may need to qualify new contractors and obtain their documentation Management of Change (MOC) An MOC form will be required Pre-Startup Safety Review (PSSR) A PSSR form may be required (if not a replacement in kind) Safe Work Programs The program won’t change, but forms may require completion

Risk Management Program (RMP) If a new classification of equipment is added and/or the expansion of the facilities ammonia inventory is sufficiently increased Emergency Planning and Response Program If a facility expansion is required, this is likely

What Likely Won’t Change…
Parts of the Process Safety Information (PSI) Information pertaining to the hazards of ammonia It is unlikely that this section would change as the result of facility modifications Information Relevant to the Equipment in the Process Materials of Construction Electrical Classification Design Codes and Standards Employed Incident Investigation Program HOPEFULLY a form doesn’t require completion! Compliance Audit Program

Valve failure requires replacement
Examples - 1 Valve failure requires replacement Replacement in kind!!! No MOC Needed HOWEVER Hot Work Permits Lock Out/Tag Out Line Opening Procedure

Examples - 2 Replacement of an air unit with another BUT
Replacement in kind BUT Manufacturer Names Model Numbers Serial Numbers Mechanical Integrity Equipment Lists Maintenance Listings PSI If unit changed, may change capacity or inventory Management of Change Form Hot Work Permit Lock Out/Tag Out Line Opening Procedure

Examples - 3 Add an air unit Mechanical Integrity PSI SOP
DEFINITELY!!! Mechanical Integrity Equipment Lists Maintenance Listings PSI Inventory Estimate Load Analysis P&IDs Block Flow Diagram (possibly) SOP Most likely clerical type issues (assuming a similar type of air unit currently exists Hot Work Permit Lock Out/Tag Out Line Opening Procedure

Examples - 4 Major Renovation Mechanical Integrity PSI SOP
ABSOLUTELY!!! Mechanical Integrity Equipment Lists Maintenance Listings PSI Inventory Estimate Load Analysis P&IDs Safe Upper and Lower Operating Limits (possible) Block Flow Diagram (likely) SOP Most likely clerical type issues (assuming a similar type of air unit currently exists

Examples – 4 (Continued)
Process Hazard Analysis (PHA) If a new process is added If there is a significant increase in ammonia inventory Risk Management Program (RMP) If a PHA has to be performed Hot Work Permit Lock Out/Tag Out Line Opening Procedure

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