Presentation on theme: "Training Session Purpose"— Presentation transcript:
1 Training Session Purpose Goals/ObjectivesLearn to ‘talk-the-talk’Learn why PSM and RMP existLearn a bit about ammoniaLearn the PSM ‘schedule’Understand the consequences of failure to followLearn to better understand your existing programUnderstand requirement changes and trends in PSM and where EPA and OSHA focus nowLearn those areas that may change when your system changes
2 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)LingoAre PSM/RMP Interchangeable? - No!Department of Homeland SecuritySite security plansPLUS the General Duty Clause!!!
3 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 )
4 What is the General Duty Clause All About? - 2 You can be in violation if:A known hazard existsThis hazard poses a threat to employees lives or personal safetyIf the hazard is recognized and addressed by the industryEmployees are regularly exposed to that hazardVery open endedBasically, if the industry recommends it, you must do it!!!
5 The Unofficial Phases of PSM Implementation Phase 1: Installation of Kryptonite!PSM Programs Initially Created in accordance with OSHA/EPAOSHA/EPA Knowledge Is LimitedPhase 2 – The Era of the Kryptonite!Programs sit on the ShelfOSHA/EPA Knowledge of NH3 PSM Begins to GrowPhase 3 – Our Kryptonite Needs Fixed???!!!OSHA/EPA Personnel Have Extensive Knowledge of NH3 PSMThe fines are coming!
6 December 2, 1984 - Bhopal, India Why PSM and RMP? - 1December 2, Bhopal, India100,800 lbs of methyl isocyanate (MIC) gas released from underground storage tanksUnion Carbide India Limited (UCIL)Potential employee sabotageNocturnal temperature inversionSubstandard living/housing conditionsBy the following morning, over 2,000 dead and 300,000 were injured by morning1,500 people died in subsequent monthsEmergency services were completely overwhelmedEmergency Services/Police provided complicating instructionsResidents 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
7 Why PSM and RMP? - 2 December, 1984 – Institute, West Virginia Union CarbideCyanide135 HospitalizedNo temperature inversionAmerica’s wake-up call!
8 Various Industry Organizations Our IndustryVarious Industry OrganizationsInternational 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
9 The “What’s” About Ammonia Basic Facts about ammoniaAmmonia is considered “highly hazardous” by OSHAAmmonia is stable and naturally occurringAmmonia is a strong alkaliLighter than air (when not saturated with waterAmmonia has an “affinity” for waterHuman body is approximately 65% waterReadily damages all body tissuesTarget easily accessible/exposed water sources on body (eyes, ears, mouth, etc.)Personal protective equipment (PPE) is requiredIncompatible with copper (and copper alloys) and galvanized steelIncompatible with certain kinds of rubberConsidered Non Flammable for ShippingUpper and Lower Flammability Limits: 15-28% ConcentrationAuto Ignition Temperature: 1,200+ °FH2ON3H13ALK
10 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)!!!
11 Ammonia and How It Affects You Various Exposure Limits0-50 ppm - Detectable odorppm - Mild eye, nose, and throat irritation; may develop tolerance in 1-2 weeks with no adverse effects thereafter140 ppm - Moderate eye irritation; no long-term tissue injury in exposures of less than 2 hours300 ppm - IDLH400 ppm - Moderate throat irritation700 ppm - Immediate eye irritation/injuryppm - Directly caustic to airway, spasms of the larynx and bronchospasms, severe eye and skin injury/irritation1700 ppm – Uncontrollable spasm of the larynx2500 ppm - Fatality (after half-hour exposure)ppm – permanent destruction of lung, sinus, and throat tissues. Also significant pain5000 ppm - Rapidly fatal exposure
12 Is Ammonia All THAT Terrible? Keep Things in PerspectiveNaturally OccurringCommonly Used on FarmsLike Any ToolIf You Fail to Respect Ammonia, Ammonia Will Fail to Respect youAmmoniaAmmonia
13 Why Ammonia Then? Why not Freon Naturally occurringEnvironmentally friendlySelf alarmingInexpensiveIf You Fail to Respect Ammonia, Ammonia Will Fail to Respect youFreon and FluorocarbonsFire creates phosgene gas (mustard gas)Suffocant (heavier than air)Can’t smell itExpensive
14 Remember that these are REQUIRED by OSHA and EPA!!! Who Has a Role?EVERYONE!ManagementPSM CoordinatorOperatorsMechanicsFloor PersonnelContractors!Remember that these are REQUIRED by OSHA and EPA!!!
15 The “When’s” of PSM/RMP Every YearSafety Inspection FormsReview Standard Operating Procedures (SOPS) and SIGN OFFReview contractors performanceEvery three yearsCompliance AuditOperator and Mechanic Refresher trainingEvery five (5) yearsSubmit RMP to the EPAProcess Hazard Analysis (PHA) revalidationIf you have electronic maintenance system (e.g., Maximo), this would be a good tool to use
16 Consequences – “OSHA/EPA Shock and Awe” - 1 February 12, 2004John Morrell Company - Sioux Falls, South DakotaPeople living within ¾ miles told to stay in home19,300 pound release from a 5” line77 InjuriesFull facility evacuationHigh pressure liquid$57,000 in finesFederal investigators said that John Morrell should have done a better job of watching out for corrosion on pipes [mechanical integrity]…
17 Consequences – “OSHA/EPA Shock and Awe” - 2 March 27, 1999Albertsons Distribution Center – Denver, PennsylvaniaNO RELEASEPotential disgruntled employee$170,000ONLY ammonia PSM relatedOctober 10, 2010Tanner Industries, East Providence, Rhode Island$149,080Emergency Response Plan didn’t addressreleases during times when facility isn’toccupied.
18 Consequences – “OSHA/EPA Shock and Awe” - 3 January 22, 2000Wells Dairy – LeMar, Iowa100,000 pound releaseLoss of ammonia compressor room and additional areas$15,000 fine issued (originally $20,000) by Iowa’s OSHAWorst 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
19 Consequences – “OSHA/EPA Shock and Awe” - 4 September, 2010Tree Top Incorporated, Selah, Washington1,100 pounds of ammonia released from relief valve on July 10, 2009Facility incident occurred around 7pm am, but didn’t inform EPA until 1:30 pm on July 11, 2009$107,000 finePilgrim's Pride, Russellville, AlabamaIncident investigation from ammonia odors, tripping hazards, and cutting and stabbing injuries (Source: TimesDaily.com)Improper Ventilation $5,000 fineInadequate emergency preparedness for ammonia release - $5,000Fines were issued as a result of other OSHA issues.
20 Consequences – “OSHA/EPA Shock and Awe” - 5 October 28, 2010American Seafoods International, LLC, New Bedford, MassachusettsNO 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 incidentDecember 1, 2004Associated 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 daysJune 18, 2010Creekstone Farms Premium Beef, Arkansas City, Kansas$130,00 fineInadequate or missing: employee participation, employee training, process hazard analysis, SOPs, emergency response program, and mechanical integrity
21 Consequences – “OSHA/EPA Shock and Awe” - 6 LAST BUT NOT LEAST!!!January 24, 2001Ammonia TheftA 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!
22 Consequences – “OSHA/EPA Shock and Awe” - 7 Are these image you want your customers to remember about you?
23 PSM (and RMP) Elements/Programs Employee ParticipationMechanical IntegrityIncident InvestigationsTrade SecretsProcess Safety Information (PSI)Process Hazard Analysis (PHA)Standard Operating Procedures (SOPS)Pre-Startup Safety ReviewManagement of ChangeContractor QualificationCompliance Audit[Operator and Mechanic] TrainingHot WorkEmergency Planning and Response
24 Employee Participation Program General Program DescriptionEnsures employees are actively involved in the creation and maintenance of the PSM Program.Basic PrincipalsTo ensure employee involvement in the PSM/RMP ProgramTo ensure employee access to information to the PSM/RMP ProgramTo ensure proper program information disseminationSpecific Areas of Interest/AttentionProcess Hazard Analysis (PHA)Standard Operating Procedures (SOPs)Consider basic ammonia awareness for all employeesDOCUMENTATION IS IMPORTANT!!!
25 Mechanical Integrity Program - 1 General Program DescriptionCreates a structure of procedures and schedules to ensure safe operation of ammonia refrigeration equipment, piping, and systems.Basic PrincipalsTo properly identify all equipment in the ammonia refrigeration systemTo ensure accurate operating and maintenance procedures have been createdTo ensure adequate operator and mechanic training has been establishedTo ensure all necessary testing, inspection, and preventative maintenance is scheduledTo identify all equipment deficiencies and to take corrective actions to address those deficiencies
26 Mechanical Integrity Program - 2 Specific Areas of InterestStandard Operating ProceduresOperator TrainingMaintenance ProceduresComputerized Databases (e.g., Maximo or other maintenance planning programs)This is a MAJOR thrust of recent OSHA inspectionsDo you have a Mechanical Integrity or “break it/fix it” programDocumentation, documentation, and more documentation
27 Incident Investigation Program General Program PurposeImplements procedures for investigating serious incidents and near‑misses and to prevent any recurrence of similar incidents.Basic PrincipalsDefine what constitutes an incident and a ‘near-miss’Create a structure for performing incident (and ‘near-miss’) investigationsIdentify methods for addressing recommendations as the result of near incidents (and ‘near-misses’)Establishing methods of communicating the status of the investigation team100 Pounds in 24 hours constitutes an ‘incident’Other NotesIncident Investigations must be kept for five (5) years
28 Process Safety Information - 1 General Program PurposeTo 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 ammoniaThe technology used in the ammonia refrigeration system, andThe equipment used in the ammonia refrigeration system.Basic PrincipalsHazards of anhydrous ammonia including discussions of:Toxicity information for anhydrous ammoniaPhysical data of anhydrous ammoniaReactivity of anhydrous ammoniaCorrosivity of anhydrous ammoniaThermal and chemical mixing of anhydrous ammoniaHistorical reactions to anhydrous ammonia exposure
29 Process Safety Information - 2 Basic Principals (Continued)Discussion of technology associated with the anhydrous ammonia refrigeration systemsimplified process or block flow diagramprocess chemistrymaximum intended inventorysafe lower and upper operating limitsconsequences of deviation from normal operating limitsLost or missing information/dataEVAPORATORATIVECONDENSERLIQUIDRECEIVERSUCTIONACCUMULATORMOTORCOMPRESSOREVAPORATOR COIL
30 Process Safety Information - 3 Basic Principals (Continued)Discussion of equipment associated with and used in the ammonia refrigeration systemmaterials of constructionpiping and instrumentation diagrams (P&IDs)electrical classificationrelief system design and design basisventilation system design and design basisdesign codes and standards employedmaterial and energy balance (system load estimate)safety systems
31 Process Safety Information - 4 Piping and Instrumentation Diagrams (P&IDs) and Block/Process Flow Diagrams – The Difference Between…
32 Process Safety Information - 5 Special ConsiderationsRelief Valve CalculationsModifications to ANSI/ASHRAE 15More strict requirements for maximum distance from valve to header (or direct atmospheric discharge, when applicable)Header diameter requirements can be affectedThese lines are grandfathered if there is no modification to that runThis is a general duty clause issue and a code/ordinance compliance issue
33 Process Hazard Analysis - 1 General Program Purposeto analyze potential hazards associated with the anhydrous ammonia refrigeration systemBasic PrincipalsEstablish an acceptable methodologyDetermine appropriate potential hazards to addressDevelop an appropriate PHA TeamIdentify recommendations to improve the safety of the anhydrous ammonia refrigeration systemCreate a structure to track recommendations and ensure their resolutions
34 Process Hazard Analysis - 2 Acceptable MethodologiesWhat ifChecklistWhat if/checklistHazard and Operability Study (HAZOP)Failure and Mode and Effects Analysis (FMEA)Fault Tree Analysis“Or other equivalent method”Generally What If/Checklists are performed
35 Process Hazard Analysis - 3 What should be addressed?Known hazardsPrevious incidentsEngineering and administrative controlsConsequences of control failuresFacility site issuesHuman FactorsA facility walk through and inspection should be performed by the Team!Who does it?Someone knowledgeable in the analysis method usedSomeone knowledgeable in refrigeration plant designSomeone knowledgeable in refrigeration plant operations
36 Process Hazard Analysis - 4 Additional NotesA listing of recommendations must be madeRecommendations must be reviewed in a ‘timely’ mannerThe EPA and OSHA both review for completeness during auditsThe PHA should be an open dialog of potential hazards seen by the each member of the team based on their own experiencesThe team should NOT be exclusively from the facilityOnly each unique type of equipment needs to be reviewed and not each individual piece of equipmentSince 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
37 Standard Operating Procedures - 1 General Program PurposeTo provide clear instructions for anhydrous ammonia refrigeration system operationBasic PrincipalsIdentify safety and health information regarding anhydrous ammoniaIdentify the required operating phasesIdentification of safety features associated with each type of ammonia refrigeration equipmentIdentify the operating limits of each type of ammonia refrigeration equipment
38 Standard Operating Procedures - 2 Operating PhasesInitial StartupNormal OperationsTemporary OperationsEmergency ShutdownEmergency OperationsNormal ShutdownStartup Following a Turnaround or after an Emergency ShutdownApplicabilityNot All Are Applicable to Ammonia RefrigerationSome Are Combined (Emergency Shutdown and Emergency Operations)
39 Standard Operating Procedures - 3 Safe Work PracticesHot WorkConfined Space EntryLockout/Tagout (LOTO)Line Opening ProcedureOther notesWhen the system changes, the SOPs may as wellThese must be annually reviewedThe 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
40 Operator and Mechanic Training Program - 1 General Program Purposeprovides on and off the job training for mechanic/operators to enable them to safely operate the ammonia refrigeration systemBasic PrincipalsDefine qualificationIdentify employees requiring trainingIf someone is touching the system, they better have records showing they are qualified to do what they are doing.System wide training versus task trainingIdentify acceptable training typesIdentify documentation to be completedDefine general requirementsIdentify terms of refresher trainingIdentify appropriate ‘grandfathering’
41 Operator and Mechanic Training Program - 2 Important NotesWhat is QualificationTask related trainingSystem related trainingRefresher TrainingEvery three (3) years (required)Can be open ended and subjectiveInternal and externalAnnual review of training is recommended (this eliminates the confusion of the three year timing)May be required if new equipment is addedGrandfatheringIf you’ve been running the system since before May 26, 1992Documentation is the difference!!!
42 Contractor Qualification Program - 1 General Program Purposeevaluates contractors’ safety performance while ensuring contractors understand known hazards and can work safelyBasic PrincipalsDefine means used to select contractorsDefine the steps necessary to qualify a contactorIdentify the facility’s requirements and responsibilities to contractors working at the facilityIdentify the contractors requirements and responsibilities
43 Contractor Qualification Program - 2 Facility’s Responsibilities the Contractorevaluating the contractor’s qualifications to perform the work projectedinforming the contractor of known fire, explosion, and toxic release hazards (especially for non ammonia contractors)explaining applicable OSHA regulations and how they affect the projectimplementing and employing safe work practices contractor entry and exitperiodic contractor evaluationproviding facility safe work practices and emergency response planreviewing and evaluating the contractor’s safe work practices and training and ensuring that each contract employee has been informed and trained and understood the trainingreviewing the design, engineering, and P & IDs for the project with the contractorperforming site walk through noting the hazards associated with ammonia systemmaintaining a separate contractor employee injury and illness log related to the contractor’s work on the project
44 Contractor Qualification Program - 3 Contractor’s Responsibilities to Their Employeesensuring 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 plandocumenting that each employee has received and understood the instructions and trainingensuring 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 NotesContractor information must be updated annuallyDocumentation is a MUST!OSHA and the EPA will fine you if you do not have documentation for your contractors during audits
45 Management of Change Program General Program Purposeestablishes and implements written procedures for managing changes to the technology, equipment, and procedures for the anhydrous ammonia refrigeration system.Basic Principalsensure all appropriate anticipated reviews are considered prior to commencing a refrigeration plant modificationIdentify potential documentation changes required as the result of proposed changesEnsure appropriate document updating is completedEnsure design reviews are completedEnsure safety and health considerations are addressed as the result of changesDoes NOT apply to “Replacement in Kind”… but…
46 Pre-Startup Safety Review Program General Program Purposeensures all PSM and RMP Program related areas have been addressed prior to introducing ammonia to the refrigeration system.Basic PrincipalsEnsure all PSM documentation has been modified to suit the modified facility prior to introducing ammonia into the new system/componentEnsure all necessary training has been performed regarding new equipment/processes prior to introducing ammonia into the new system/component
47 Compliance Audit Program General Program PurposeTo verify that the PSM and RMP programs meets federal requirements and are implementedBasic PrincipalsEstablish audit frequency and timingDefine the requirements of the auditor and/or teamIdentify the scope of the auditDefine requirements for addressing and tracking audit recommendationsAdditional NotesThe “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
48 General Program Purpose Trade Secret ProgramGeneral Program PurposeDefines the rights of employees regarding access to PSM and the effects of trade secretsBasic PrincipalsRegardless of potential industry secrets, the employer must inform employees working with the process about the processNot applicable to ammonia refrigeration system except in rare circumstances
49 Risk Management Program - 1 General Program PurposeTo 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 respondersBasic PrincipalsIdentify the covered processDescribe the anhydrous ammonia refrigeration system in general as it relates to the facility and local community (executive summary)Describe the Prevention Program 3 information
50 Risk Management Program - 2 Basic Principals (Continued)Management SystemA listing of how the PSM/RMP will be administered, but more importantly, by whomRisk Management PLAN vs. Risk Management PROGRAMRisk Management PLAN is a document that is [re]submitted to the EPA at least every five (5) years or sooner if facility modifications require resubmittalThe 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”
51 Risk Management Program - 3 Basic Principals (Continued)Provide an Off-Site Consequence Analysis (OCA)Worst CaseAlternative ReleaseIdentify and describe any accidents occurring in the past five (5) yearsDescribe the Emergency Planning and Response Program
52 Did you say something, Hank? Hot Work ProgramGeneral Program PurposeProvide rules for performing any open flame or open arc work at the facilityBasic PrincipalsOSHA 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?
53 Confined Space Entry Program General Program PurposeProvides rules/restrictions for entering confined spaces at the facilityBasic PrincipalsOSHA 29 CFRIs large enough and so configured that an employee can bodily enter and perform assigned work; andHas 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.); andIs not designed for continuous employee occupancy.Most ammonia system do not have confined spaces… BUTCondensersPenthouse air unitsConfined space or PERMIT REQUIRED confined space
54 Lockout Tagout Program General Program PurposeProvide rules for working with and controlling stored energy systems (electrical, mechanical, and electro-mechanical)Basic PrincipalsOSHA 29 CFR (The control of hazardous energy (lockout/tagout)“Suicide Prevention Program!”
55 What Has Changed Recently and OSHA/EPA Trends - 1 ANSI/ASHRAEMethods for determining relief valve discharge pipe sizeReduces allowable lengths from valve to headerChanges discharge calculations for valves discharging vapor back into system via a relief valveFire Control BoxesIIAR 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 requiredMany responders don’t understand what they are for and how to operate themOSHA has changed target from Petro/Chemical industry to ammonia
56 What Has Changed Recently and OSHA/EPA Trends - 2 Audit FocusMajor aim has been Mechanical IntegrityDocumentation!Paper versus electronic - REAL SignaturesTraining – review of training documentationSafe Work PracticesAmmonia detection systems calibrated and documented“Non Negotiables”SOPs annually signed offPHA performed at five (5) yearsAll contractors have documentationAudits performed every three years promptlyRecommendations from audits and PHAs are addressedRMP resubmittal on-time
57 What Changes if the System Changes… - 1 Employee ParticipationONLY completion of employee Participation FormsProcess Safety InformationInformation Relevant to the Technology of the SystemBlock/Process Flow DiagramProcess Chemistry (ONLY if a new classification of equipment is added)Inventory AnalysisSafe 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)
58 What Changes if the System Changes… - 2 Process Safety Information (Continued)Information Relevant to the Equipment in the ProcessPiping and Instrumentation Diagram (P&ID)Relief System and Design BasisMaterial and Energy BalanceSafety SystemsStandard Operating Procedures (SOPs)If a new classification of equipment is installed, there may be an additional chapter neededMost changes would be clerical in nature (to include new equipment numbers) if no new classification of equipment is addedOperator/Mechanic TrainingOnly new training performed and forms completed
59 What Changes if the System Changes… - 3 Contractor Qualification ProgramThe program won’t change, but you may need to qualify new contractors and obtain their documentationManagement of Change (MOC)An MOC form will be requiredPre-Startup Safety Review (PSSR)A PSSR form may be required (if not a replacement in kind)Safe Work ProgramsThe program won’t change, but forms may require completion
60 What Changes if the System Changes… - 4 Risk Management Program (RMP)If a new classification of equipment is added and/or the expansion of the facilities ammonia inventory is sufficiently increasedEmergency Planning and Response ProgramIf a facility expansion is required, this is likely
61 What Likely Won’t Change… Parts of the Process Safety Information (PSI)Information pertaining to the hazards of ammoniaIt is unlikely that this section would change as the result of facility modificationsInformation Relevant to the Equipment in the ProcessMaterials of ConstructionElectrical ClassificationDesign Codes and Standards EmployedIncident Investigation ProgramHOPEFULLY a form doesn’t require completion!Compliance Audit Program
62 Valve failure requires replacement Examples - 1Valve failure requires replacementReplacement in kind!!!No MOC NeededHOWEVERHot Work PermitsLock Out/Tag OutLine Opening Procedure
63 Examples - 2 Replacement of an air unit with another BUT Replacement in kindBUTManufacturer NamesModel NumbersSerial NumbersMechanical IntegrityEquipment ListsMaintenance ListingsPSIIf unit changed, may change capacity or inventoryManagement of Change FormHot Work PermitLock Out/Tag OutLine Opening Procedure
64 Examples - 3 Add an air unit Mechanical Integrity PSI SOP DEFINITELY!!!Mechanical IntegrityEquipment ListsMaintenance ListingsPSIInventory EstimateLoad AnalysisP&IDsBlock Flow Diagram (possibly)SOPMost likely clerical type issues (assuming a similar type of air unit currently existsHot Work PermitLock Out/Tag OutLine Opening Procedure
65 Examples - 4 Major Renovation Mechanical Integrity PSI SOP ABSOLUTELY!!!Mechanical IntegrityEquipment ListsMaintenance ListingsPSIInventory EstimateLoad AnalysisP&IDsSafe Upper and Lower Operating Limits (possible)Block Flow Diagram (likely)SOPMost likely clerical type issues (assuming a similar type of air unit currently exists
66 Examples – 4 (Continued) Process Hazard Analysis (PHA)If a new process is addedIf there is a significant increase in ammonia inventoryRisk Management Program (RMP)If a PHA has to be performedHot Work PermitLock Out/Tag OutLine Opening Procedure