2Resume - ComPSM ComPSM Max Aerospace/Mechanical/Nuclear Engineers PE License40 years combined NH3 PSM experience among 3 primesAudit consulting experience with customers in many regions with both EPA and OSHAMember of RETA, IARW, IIARMaxWorked in PSM/RMP since January 200010 Years in Secondary Nuclear Plant Piping/Valve SystemsStarted ComPSM with Tom Henry in 2003Developed two complete PSM ProgramsAudit consulting experience mitigating/eliminating penalties for customersPerformed Dozens of Audits across countryPerformed Dozens of PHAs across country
3What 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)PLUS the General Duty Clause!!!
8“Why did my company get chosen???” Why Me???“Why did my company get chosen???”“Name out of a hat”Injury/IllnessAmmonia releaseWhistleblower (OSHA/EPA are often skeptical of these)National Emphasis Program (NEP)OSHA ProgramFocuses on ‘problematic companies’Multi-day grilling
9What’s the Difference Between EPA/OSHA Audits? - 1 EPA (UNDER NORMAL AUDIT CONDITIONS!!!)EPA less intrusiveEPA audits are shorterEPA audits last a half day to a dayEPA seems to be more forgiving than OSHA for plants with less problemsNot super knowledgeable of NH3 refrigeration, but getting trainingEPA Audits add environmental issuesOn average, EPA fines appear to be less, but when they fine… they fine BIG!!!EPA and expedited settlementsStarted in January 2004Only minor, easily correctable violations.Not if violations pose an imminent/substantial endangerment to human health or the environmentTitle V sources are not eligible for an ESAFines less than $7,500
10What’s the Difference Between EPA/OSHA Audits? - 2 OSHA walks in door – SURPRISE!!!Currently focusing on ‘repeat offenders’ (NEP)Metastasizing through a companyCommunicate within your company!!!Will focus EXCEPTIONALLY heavy on mechanical integrityThe secret checklist!OSHA auditors are likely to show up for several ‘sessions’ 3-4 visits totaling 20+ hoursAt times appear to be digging aimlessly (actually may be?)OSHA auditors tend to take info back for advice from more knowledgeable people and the COME backNot super knowledgeable of NH3 refrigerationHave heard of two auditors who were actually verbally aggressiveHave often overstepped/overstated requirements!
11Current Key Areas of Review General Overview of PSM Mechanical Integrity!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! Speed of resolution of recommendations (PHA/Audits) Timing of PHAs/Audits/Inspections/SOP reviews Process Hazard Analysis (PHA) Standard Operating Procedures Training Documentation of Releases (EPA) Audits Contractor Qualifications
12Mechanical Integrity Targets Mechanical Integrity Review PointsRecords on relief valve replacementCalibration/Testing of ammonia sensorsTesting of Safety SetpointsCompressor cutoutsCompressor alarmsHigh level cutouts on vesselsLow level cutouts on vessels“B109” Form completion5 Year Major Mechanical NDTIs visual enough?
13Recommendation Implementation PHA Recommendations Audit Recommendations Focus on how fast resolved Priority order Signed off When can we toss old recommendations?
14Process Hazard Analysis Quick Overview Looking for depth of questions Who performed it? Operators involved? Did you look at the facility? Let me see those recommendations! Did you just sit in a room or did you walk the plant?
15Timeliness of Planned Items Process Hazard Analysis (PHA) – 5 years Risk Management Plan (RMPlan) resubmittal – 5 years Compliance Audits – 3 years Equipment [B109] Reviews – Annually Sign off on Standard Operating Procedures – Annually Maintenance schedules for equipment Annual reviews of NH3 sensors
16Standard Operating Procedures Are all processes coveredEach piece versus each common typeRecertified AnnuallyCustomer hit for missing 4 years priorWritten signatures (not just printed)DatedReviewed all at once or grouped is okayMake sure it includes information on NH3All modes of operation addressed?Operating limits/Deviations/Corrections
17Operators/Mechanics Training Up and coming area of reviewDifficult to reviewEPA generally scans information/OSHA more focusedWhat do you need to have?RETA or class certification papersTraining formsTechnically speaking, something that shows training or implies training on all equipmentIf class taken, keep a copy of a detailed syllabus or the class book for company proof of areas coveredOn site training???... MaybeMay interview employees about their training
18For whom should you have paperwork ContractorsFor whom should you have paperworkRefrigeration – SureElectricians in compressor room – SureEVERY contractor that works on or around the systemBe creative in figuring this out (insulation, ammonia detection, water treatment…)Are you required to have every contracted every year?...Only if they have been within a year and also if you prior to anyone starting if outside of a yearWhy not get all the ‘usual suspects’ annually at a certain date?Contractors should just send, but…
19Management of Change Program Want to see completed formsMake sure they are fully signed off (real signatures)Make sure they aren’t being done retroactivelyReplacement in kind need to be included, but…It doesn’t hurt to do themDon’t be surprised if they ask stillMay ask to show changes during a walk throughIf you have an MoC, they can ask about contractor data!If you have an MoC, they’ll ask about PSSRs
20Pre-Startup Safety Review Program They should/will ask for completed formsHeard them ask about training prior to startup and wanting to see training recordsMake sure they are fully signed off (real signatures)Materials of construction – Piping certifications
21Compliance Audit Program Most recent two internal compliance auditsThe will check for 3 year timingRecent audit wanted a 3rd???They WILL ask to see recommendations listingThey WILL check to see if they are resolved (quickly)Any auditor worth their weight will scanWho did them and are they qualified?Internal auditing is risky unless the person doesn’t have tunnel vision to your company’s policiesIf you have a reputable consultant who makes recommendations…pay attention to the recommendations
22Risk Management Program and Plan Risk Management Program (RMP) vs Risk Management Plan (RMPlan)?Only EPA ReviewsRisk Management ProgramFlow chart that shows PSM in company structureManagement System (who does what)Risk Management Plan (Submittal)May/will ask questions about Offsite Consequence Analysis (OCA)Most up to date census data used? New census will change new OCAsResubmitted every 5?Emergency point of contact changed? Releases
23Did you say something, Hank? Hot Work ProgramLikely to ask for completed forms Who signs off and are they appropriate How long are they kept Visiting site (inspection) prior to starting OSHA will look at much more heavilyDid you say something, Hank?
24Confined Space Entry Program Make sure you have a program of some sortFacilities will often say they don’t enter confined spacesWill review programGenerally not as much of an issue with cold storage (non processing) facilitiesMay want to see locations identified as confined spaces
25Lockout Tagout Program Some have required you have a written program! May inspect lock boxes During walk-throughs, may look for lock outs Generally ask questions to maintenance about implementation
26Psychology of an Auditor Auditors are people too… In a natural way (don’t force it), find common interests (works for OSHA due to repeat visits)Likely to be inexperienced in understanding of NH3 Refrigeration, but training has been comingThey may try to hold you to practices in the petro-chem industry which are not done in NH3 refrigerationTend to go down channels they understand, but may not be what you would expectSome can be confrontational and some even rude (usually only with radically non-compliant plants)Some want to show you they are smarter than you OR YOUR consultant
27Before the Day of the Audit To “Do’s” - 1Before the Day of the AuditIf you have a PSM consultant experienced in audit assistance, make sure they are there. If you don’t, FIND ONE! Mitigate Negotiate MitigateIf you have a corporate person with experience, make sure they are there!If another facility in your company has been hit, GET THEM INVOLVED!If possible, preparation should be done days in advanceWho says whatHave ALL documents in room where audit will take place – no searching!!!Organize on a table so it’s ready for reviewTabbed for easy accessUse the IARW as a resource for audits!Before the audit, ask the auditor if they have a checklist you could use to help organize (generally will only work with EPA)Do a walk-through of the whole facility (including roof) for housekeepingFor goodness sake, CLEAN that engine room (dirt/dust free, if possible)!!!Make sure to adjust shifts to get the best (and most well spoken) operator working on the day of the audit
28To “Do’s” - 2 The Day of the Audit Audits are like interviews – tone/opinion set in first couple minutesPrep the room (have drinks or donuts)Determine room seating arrangement in advanceKeep a positive attitude that says, “we are always trying to improve”Tell the auditor you welcome their expertise and adviceBe polite… even if things get testy.Some aware that some auditors can be testy, confrontational, and rude! Not normal, but it happensTake notes about EVERYTHINGTry to make a personal connection and get to know them.If you disagree and you feel justified, ask for a clarification and insert what you believe to be correct, but KNOW YOUR STUFF!If you get frustrated with the inspector, excuse yourself for some reason, get it together, and go back in.
29The “Don’ts” If possible, no contractors on site If possible, no hot work!!!You should know your program as well as possible for the audit, do NOT let your consultant do all the talking!Avoid giving electronic files… they may want them ALLIf you have a fully electronic program AND it allows, print a copy of the program and organize appropriatelyNEVER be confrontationalKeep out the operator who wants to tell stories about the plantDon’t offer anything more than drinks and donutsIf possible, never make them sit and wait while you search for information (as noted previously, have everything available in the room)
30Non NegotiablesThere are certain fines you just can’t mitigate/negotiate (the ‘non negotiables’)Fail to notify of incident to NRC IMMEDIATELY – EXPENSIVEFail to initiate investigation teamFail to change emergency contact in RMPlanFail to review (or late) annual review of SOPsFail to revalidate (or late) the PHA - every 5 yearsFail to audit internally (or late) - every 3Have NOTHING
31IARW resource/database for audits! Make sure to use it. ClosingIARW resource/database for audits! Make sure to use it.Find out if another IARW member has had this auditor and call them!!!What did they ask about?Were there any area they went overboard on?What were they like personally? ANYTHING.Likewise, contribute BACK after the auditDialog of the members in the meetingWho has been audited here?What have you seen?General Question and Answer Session