acknowledgementweb.iiar.org/membersonly/pdf/tc/t284.pdf · acknowledgement the success of the 21’...

ACKNOWLEDGEMENT

The success of the 21’ A n n d Meeting of the International Institute of Ammonia Refiigeration is due to the quality of the technical papers in this volume and the labor of their authors. IIAR expresses its deep appreciation to the authors, reviewers, and editors for their contributions to the ammonia refiigeration industry.

Board of Directors, International Institute of Ammonia Refigeration

ABOUT THIS VOLUME

IIAR Technical Papers are subjected to rigorous technical peer review.

The views expressed in the papers in this volume are those of the authors, not the International Institute of Ammonia Refiigeration. They are not official positions of the Institute and are not officially endorsed.

EDITORS Christopher P. Combs, Project Coordinator

M. Kent Anderson, President

International Institute of Ammonia Refigeration 1200 Nineteenth St., N W

Suite 300 Washington, DC 20036-2422

+1-202-857-1110 (voice)

www.iiar.org +1-202-223-4579 (fax)

http://www.iiar.org

I I I I I I I I I I I I I I I I I I I

Technical Paper #9

Integration of PSM/RMP Into a Typical Business

Don Jeter, P. E. & Ed Eliason Eagle Engineering & Testing Services

Bellingham, WA

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Background

The Clean Air Act Reauthorization created a new environment for industry. In addition to consideration of the day to day releases of hazardous materials, it also mandated a focus on catastrophic releases, in particular, their prevention and mitigation. The mandates of the Clean Air Act Reauthorization are addressed by the OSHA’s Process Safety Management Program (PSM), and the EPA’s Risk Management Program (RMP). The PSM program focuses on the safety of the workers at an industrial site, while the RMP focuses on the offsite safety issues.

Both of these programs (PSM & RMP) require industry to take a proactive approach to the prevention and mitigation of catastrophic releases. In particular, the PSM program and RMP-prevention program involve fourteen elements. These elements are more effect-oriented than prescriptive, leaving the details for implementation and integration up to the ownedmanager of the facility. Some of the elements require the facility owner to timely address recommendations for changes, while others require planning and training for adverse situations. This paper looks at the integration of these elements with respect to a typical business.

To be involved with these regulations, the process must use a highly hazardous chemical in a quantity greater than the threshold quantity specified in the regulations. For anhydrous ammonia, the threshold is 10,000 pounds for both the PSM and RMP regulations. Therefore, refrigeration plants with 10,000 pounds or more of ammonia will be involved with both OSHA- PSM, and EPA-RMP (Level 3).

The Business Model

For these considerations, the business is assumed to involve a continuous 24-hour-per- day operation with periodic shut downs for maintenance and construction. The business is assumed to involve an operations department with “hourly workers” who are supervised by an operations supervisor. This supervisor receives schedules and targets from the facility managemenuowner. Construction projects and major maintenance are scheduled and coordinated with the periodic shutdowns, while day-to-day maintenance is performed with the facility in operation, although some parts of the facility may be shut down. Management’s functions are to allocate resources and provide directions based on the information and feedback received from operations and clients. Figure 1 shows this Typical Business Structure Model.

Prior to PSM & RMP, operational feedbacks were not standardized and some industries did not have periodic safety reviews. The PSM & RMP regulations now require an owner/manager to periodically review their process and operating procedures, and then address and resolve the resulting recommendations. The regulations specify the types of reviews, but do not prescribe methods for addressing and resolving recommendations. One of the keys is to integrate the reviews and the resulting recommendations into the business planning and budgeting cycles of the business.

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Process Safety Management Functions

Implementation of OSHA-PSM and EPA-Rh4P prevention programs involves fourteen elements; six can be classified as long term, while seven are more associated with day-to-day operations. One element, Employee Participation, is required to be a part of all the other elements. The short-term elements are: Training, Contractors, Hot Work Permits, Mechanical Integrity, Incidenmear-Miss Reporting, Management of Change, and Pre-Startup Safety Review. The long-term elements are: Audits, Emergency Planning, Operating Procedures, Process Safety Information, Process Hazards Analysis, and Trade Secrets. The detailed requirements for these elements is beyond the scope of this paper and has been covered by References 1,2,3,4 and 5.

The short-term elements focus on the operation and construction parts of the business. Figure 2 shows these short-term elements superimposed on the operations and construction block diagram. Four of the short-term elements (Management of Change, Pre-Startup Safety Reviews, Mechanical Integrity, and Incident Reporting) provide feedback to management. For the most part, these feedbacks are not on a planned basis and require management to address the recommendations outside of the “normal” planning and budgeting schedule.

The long-term items are more focused toward management and can be scheduled activities. Two of these elements (Audits, and Process Hazards Analysis) also provide feedback to management. Figure 3 shows these elements superimposed on the management business functions. Per the regulations, these feedbacks must also be addressed in a timely manner, but the regulations do not provide for a mechanism; that is left up to the managemendowner.

Figure 4 shows the collection of both the short- and long-term P S W elements.

Anatomy of a Catastrophic Incident

Typically, a process operates in its “normal” mode of operation, but can be disrupted and deviate into a “first level of upset.” The operator is notified of this deviation by alarms or other observations and takes corrective action to resolve the situation. If these corrections are not in time, or don’t resolve the problem, it can escalate and develop into a significant problem and require a “second level response.” This second level response typically involves a process shutdown and bringing in additional personnel. If the problem can not be managed with these measures, it may then grow into a catastrophic release.

Of course, some catastrophic releases are caused by a single failure with out going through the first and second levels of response. These usually involve a breach of the containment of the system, i.e. breaking of piping or equipment.

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Feedbacks to Management

Most businesses operate on an annual or fiscal year basis with appropriate budgets and scheduling functions. Additions of the PSM and RMP feedbacks into this annual cycle add to the complexity of the management functions. The timing of these new feedbacks within this business cycle can either complement the process or be a disruption.

The short-term feedbacks (typically to fix an immediate problem) are usually unanticipated, and therefore become “brush fires.” Being unanticipated, they must be handled on an expedited basis with reserve budgets and schedule disruptions. Incidenwear-Miss Reporting can cause significant disruptions because they are the most unanticipated of the four short-term feedbacks. They typically are associated with a process interruption, and possibly injuries or fatalities. The only optimization for this feedback element is to avoid the situations that require this analysis.

The Management of Change (MOC) and Pre-Startup Safety Review (PSSR) are related to construction and maintenance projects. The MOC is a review of the planned work. Its purpose is to update Process Safety Information and inform operators of the design before it is built. If a problem is uncovered at this stage, it can be redesigned before construction is started. The PSSR is a verification that the construction is properly completed, and that the operating procedures and training are adequate and completed. For planned construction projects, the MOC and PSSR should be part of the scheduled design and construction efforts. In situations where several plant modifications are being considered and pursued at the same time, communication of one project’s MOC information to other can significantly reduce unanticipated surprises. The communication and coordination will be discussed in more detail later.

For unanticipated maintenance, the MOC and PSSR may utilize a simplified format, but must cover the essential parts of these items. In some cases, these unanticipated maintenance items require a two-phase resolution. The first phase might involve a change in operating procedures, with a longer-term equipment modification to follow. Both of these phases need to go through the MOC & PSSR process, along with an updating of the Process Safety Information package.

The final short-term feedback is Mechanical Integrity, which involves the proactive testing, and identification and documentation of equipment problems to improve reliability. This should be an “early warning” system. Ideally, it should provide adequate time to schedule repairs during the normal maintenance cycles. It is important that mechanical integrity information be communicated with other maintenance and modification projects, so that these project designers have correct information about the equipment with which they will be interfacing. In some cases, modification projects can also resolve the problems identified by the mechanical integrity element. Finding these opportunities can reduce the expense and shutdown time required to perform the same work as two separate projects.

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Audits and Process Hazards Analysis (PHA) re-validations are the long-term feedbacks to management. The audits are required every three years, while the PHA re-validations are required every five years. The purpose of the audits is to look at the whole PSM and RMP - prevention program so as to verify the structures to meet the regulatory requirements as well as their actual implementation. The PHA is a detailed technical evaluation of the chemical processes including facilities locations, human factors, and overall siting issues.

These long-term feedbacks provide recommendations directly to management. Typically, some of these recommendations are more long-term and need significant engineering analysis before management can address the concerns. Because the Audit and PHA re- validations cover broad spectrums, there may be a significant number of generated recommendations. This quantity and complexity of recommendations can create an “overload” for management to address in a timely manner.

Optimization Opportunities

The PSM and RMP regulations leave the details of addressing and resolving the proposed recommendations up to the owner/management. Many management structures involve departments, or individual managers who are responsible for various parts of the business. Figure 5 shows the management functions divided into five areas: 1) Operations, 2) Process / Engineering, 3) Maintenance, 4) Environment Health and Safety (EH&S), and 5) Scheduling and Coordination. In this figure, the feedbacks are shown going to the appropriate management functions.

As discussed above, some of the recommendation feedbacks are from short-term elements, which must be handled on an expedited basis. Others can be scheduled so as to improve their integration with the business structure. Four optimization activities have been seen to help the addressing and resolution of recommendations. The first is the sorting and consolidation of the recommendations. The second is the timing of the recommendation feedback to management. The third is prioritization of the concerns and associated recommendations. The fourth is the coordination of the selected recommendations and resolutions with the company’s business plan.

The first, Sorting and Consolidation, primarily involves PHA recommendations. During the course of a PHA, the same safety concern may be the basis for several recommendations. Without adequate sorting and consolidation, management is required to review the merits of each recommendation, without knowledge of the other possible solutions. On the other hand, if all of the recommendations associated with one concern are collected and reviewed by a working group, the product will be much easier for management to work. They can see the problem or concern basis, along with the whole range of recommended solutions. If necessary, management has the information to select a temporary corrective action, as well as initiate the financial planning to design and implement a permanent resolution. The working group that handles this effort needs to be representative of the original PHA or Audit team that created the recommendations. Figure 6 shows this collection and review function added into the recommendation feedback loop.

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From the timing point of view, if significant recommendations are not in sequence with the budgeting and maintenance shutdown schedules, they may go unresolved, not due to management lack of attention, but because the time to design and procure the parts is unavailable. For serious problems this can require an unscheduled shutdown to make the needed changes, or leave known problems unresolved until the next maintenance opportunity.

For PHA’s a lead time of 12 months prior to a maintenance turnaround is reasonable for submitting a set of sorted and consolidated recommendations to management. With an annual budgeting cycle, this will allow the selected recommendation resolutions to be included with the other work items in the shutdown budget. As a general rule, this will provide time for design and purchase of the required equipment. In addition, the recommended work items can be coordinated with the other work during the shutdown.

Audits are mainly concerned with proceduies, and therefore, rarely affect the maintenance timing. The audit process is disruptive by its nature. People working on the various elements of PSM and FWP must take time out for interviews and to provide required documentation. From a scheduling point of view, it is important to recognize these time requirements and the delays they can cause. If possible, the audit should be scheduled so that it does not coincide with other heavy workloads (i.e. peak seasonal productions or maintenance efforts). The schedules of the other elements need to have adequate slack to accommodate the audit. Because the PHA’s involve teams of people, these audit disruptions can reduce the progress of the whole team. To reduce this impact, additional key people (Le., PHA facilitators) should be available to fill ‘in when the audit is in progress, or the PHA should be suspended during this time so that the remainder of the team is not unproductive.

The third item, Prioritization, involves ranking the risks of the concerns behind the recommendations. Risk is made up of two components: 1) the probability of the concern’s occurring, and 2) the consequence of the concern. The risk is then the product of these two elements:

Risk = Probability X Consequence

One way to present risk estimates is to use a risk matrix with four levels of probability on the vertical axis, and four levels of consequence along the horizontal axis. High-risk items will stand out toward the upper right of the matrix, while low-risk concerns will be toward the lower left. Figure 7 is an example of a Risk Matrix. Reference 6 discusses prioritization of maintenance based on risk.

It is important to recognize that management must address all of the concerns and their associated recommendations. The prioritization matrix is intended to help management focus more resources on the highest risk concerns while keeping the lower risk concerns in perspective.

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The final item, Coordination with the Business Planning, involves proactive long range planning. The business plan needs to include appropriate forecasts for the long-term PSM/RMP elements. Also, the long range facility upgrades and modifications should be factored into the PHA re-validations so as to avoid recommendations that would create conflicts with the planned work. In some cases, the PHA re-validation will identify additional justifications for the proposed work. It also possible that the proposed work scope can be adjusted so as to resolve concerns identified by the PHA and avoid redo and retrofit projects. Figure 8 shows this integration.

EPA-RMP Considerations

The EPA-RMP requires additional documentation for: (1) hazard assessment, (2) prevention program, (3) emergency-response plan, (4) overall management system, and ( 5 ) submission of risk management plan document. For ammonia, the prevention program is essentially identical to the OSHA-PSM program. Reference 7 is a summary of the EPA-RMP requirements.

The hazards assessment is an evaluation of worst case(s) and alternative release cases scenarios. The intention is to delineate the off-site consequences of a release of hazardous material. The worst-case scenarios are essentially defined by the regulations, while the alternate release scenarios are to be specific to the facility’s operation. The determination of alternate release scenarios should be an extension of the Process Hazards Analysis. References 1 and 4 provide specific guidance for Ammonia Refrigeration operations and Reference 8 provides a general review of the consequence modeling requirements.

The emergency response plan again should be an extension of the OSHA-PSM emergency response plan. Specifically, this plan must be coordinated with the local fire department and Local Emergency Response Planning Committee (LERPC) so that the community’s response to a significant release can be coordinated with the facility’s efforts.

The overall management system is a documentation of the facility management structure, with respect to the implementation of these regulations. At the same time, the Risk Management Plan document is a computerized submittal of information associated with the regulations. The submittal of these plans and the associated public response will be a significant part of the EPA- RMP program. References 9,10, and 1 1 discuss communication with the local community.

Summary

The OSHA-PSM and EPA-RMP regulations require facilities handling highly hazardous chemicals to set up proactive programs. These regulations introduce new information feedbacks to management which require their attention. The fourteen elements required by PSM and RMP- prevention program can be divided into short- and long-term categories. The short-term elements are mostly associated with the operational day-to-day activities, while the long-term


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elements are more involved with the management functions of the business. Feedbacks from the operational short-term elements are typically unplanned and must be addressed on an expedited basis. However, the long-term elements can be planned and coordinated with the business planning and budgeting cycle. It has been observed that proper timing of these long-term feedbacks can significantly improve management’s ability to address and resolve them. Coordination, prioritization and integration with the business long-range planning functions can also contribute to the optimum implementation of these regulations.

Finally, the upcoming PSM plan submittal date (June 1999) may add to the feedback to management. It is important to have a solid internal program in place from which to build an RMP submittal. It is much better to work with PSM/RMP as part of an established procedure, rather than to regard it as a monotonous exercise.

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References

1. Risk Management Program Guidance for Ammonia Refrigeration (40 CFR Part SO), EPA 550-B-98-014 Office of Solid Waste and Emergency Response (5104) [on web site www.epa. g;ov/cep~o].

2. Center for Chemical Process Safety, “Guidelines for Hazard Evaluation Procedures,” 2nd ed. CCPS, AIChE, New York, 1992.

3. Center for Chemical Process Safety, “Plant Guidelines for Technical Management of Chemical Process Safety” revised edition, CCPS, AIChE, New York, 1995.

4. IIAR Risk Management Guidelines, 1998.

5. IIAR Process Safety Management Guidelines, 1998.

6. Harnly John A. “Risk Based Prioritization of Maintenance Repair Work,” Process Safety Progress Vol. 17, No. 1, Spring 1998,32-38.

7. Russell, P.E., David L. “Getting a Handle On Risk Management,” Chemical Engineering Vol. 105, No. 13, December 1998,114-120.

8. Crowl, Daniel A. “Consequence Modeling for the EPA Risk Management Plan (RMP),” Process Safety Progress Vol. 16, No. 1, Spring 1997, 1-5.

9. Davis, Bruce C., Garrett, JoAnn “Communicate Better With Your Neighbors,” Chemical Engineering Progress, March 1998,6 1-65.

10. McCready, David, “Development and Communication of Worst-case Scenarios for the EPA Risk Management Program,” Process Safety Progress Vol. 15, No. 2, Summer 1996, 95-100.

1 1. Auger, John E. “EPA’s Risk Management Regulation: Communicating Worst-case Scenarios,” Process Safety Progress Vol. 1 5, No. 2, Summer 1996, 10 1-1 03.

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