CalARP/RMP/PSM Five-Year Update (Critical Elements, Focusing, Timing)

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1 Risk Manaement Professionals 2009 Central Valley Chemical Safety Day CalARP/RMP/PSM Five-Year Update (Critical Elements, Focusin, Timin) Steven T. Maher, PE CSP Risk Manaement Professionals 949/ RMP Risk Manaement Professionals

2 Risk Manaement Professionals Aenda Reulatory Process Safety Prorams that Require 5-Year Updates Key Elements of US EPA RMP & CalARP Prevention Proram Comparison CalARP/RMP/PSM Key Periodic Requirements Pacin Yourself for the 5-Year Updates What To Do If Startin Late Key Requirements of CalARP, PSM, & RMP Reulatory Challenes Common Deficiencies Miscellaneous Oversihts & Challenes Select Citation Summary RMP Risk Manaement Professionals

3 Risk Manaement Professionals Reulatory Process Safety Prorams that Require 5-Year Updates California Accidental Release Prevention (CalARP) Proram Ammonia Threshold = 500# EPA Risk Manaement Proram (RMP) Ammonia Threshold = 10,000# Cal/OSHA Process Safety Manaement (PSM) Proram Ammonia Threshold = 10,000# RMP Risk Manaement Professionals

4 Risk Manaement Professionals Key Elements of US EPA RMP & CalARP Hazard Assessment (potential hazards to the community) Estimate Potential Release Quantities Determine Downwind Effects Evaluate Scenarios Ranin from Probable/Low-Impact to Improbable/Worst-Case Potential Exposure to Affected Populations Under Worst-Case Conditions Accident History for Previous Five Years Prevention Proram (Prevention Proram 3 primarily encompasses PSM elements; however, the differences in the lists of reulated substances and the threshold quantities result in additional facilities covered by the RMP Rule) RMP Risk Manaement Professionals

5 Risk Manaement Professionals Key Elements of US EPA RMP & CalARP Emerency Response Proram Considers Manitude of Potential Release and Possible Community Impacts Protective Actions to Protect Humans, Health, and the Environment > On-site mitiation > Off-site emerency response > Community alert & response Coordination with Local Emerency Plannin Committee Employee Trainin RMP Risk Manaement Professionals

6 Risk Manaement Professionals Elements of PSM (California) EP PSI PHA IIPP OP EPR PP TRN II CON MOC HWP MI PSSR RMP Risk Manaement Professionals

7 Risk Manaement Professionals CalARP/RMP Proram 2 Prevention Proram Other Elements CA II SI PP2 HR OP Hazard Assessment Seismic Safety Assessment / Walkdown Submittal Formulation Maint. TRN RMP Risk Manaement Professionals

8 Risk Manaement Professionals CalARP/RMP Proram 3 Prevention Proram Other Elements HWP EP CON PSI PP3 PHA OP TRN Hazard Assessment Seismic Safety Assessment / Walkdown Submittal Formulation II MI CA PSSR MOC RMP Risk Manaement Professionals

9 Risk Manaement Professionals Prevention Proram Comparison Section EPA (40 CFR) (P3) OSHA (29 CFR) Cal/OSHA ( 8 CCR) CalARP (19 CCR) (P3) Trade Secrets (p) Process Safety Information (d) 5189 (d) Process Hazard Analysis (e) 5189 (e) Operatin Procedures (f) 5189 (f) Trainin () 5189 () Mechanical Interity (j) 5189 (j) Manaement of Chane (l) 5189 (l) Pre-Startup Safety Review (i) 5189 (i) Compliance Audits (o) [IIPP] Incident Investiation (m) 5189 (m) Employee Participation (c) 5189 (p) Hot Work Permit (k) 5189 (k) Contractors (h) 5189 (h) Emerency Response Proram (n) 5189 (n) Article 7 RMP Risk Manaement Professionals

10 Risk Manaement Professionals CalARP/PSM/RMP Key Periodic Requirements Five-Year SI (2) / PSI (3) HR (2) / PHA (3) RMP Submittal Hazard Assessment External Events Review (CalARP-Only) Triennial Trainin Compliance Audit Hazardous Materials Business Plan RMP Risk Manaement Professionals

11 Risk Manaement Professionals CalARP/PSM/RMP Key Periodic Requirements Annual Operatin Procedures Emerency Plannin & Response IIPP Non-Specific Maintenance (2) / Mechanical Interity (3) Incident Investiation MOC (PSM & Proram 3 Only) PSSR (PSM & Proram 3 Only) Hot Work Permit (PSM & Proram 3 Only) Contractor Safety & Qualification (PSM & Proram 3 Only) Chanes in Desin or Operation!! RMP Risk Manaement Professionals

12 Risk Manaement Professionals Pacin Yourself for the 5-Year Updates T 2 Months T 1 Month Arrane for Any Needed CalARP/RMP/PSM Contractor Support Project Start and Initial Information Gatherin Arrane for CUPA Support Project Kickoff Meetin & Information Gatherin PSI/SI Creation / Update Misc. Prev. Pro. 2 Elements: OP, TRN, Maint., CA, II Misc. Prev. Pro. 3 Elements: OP, TRN, MI, MOC, PSSR, CA, II, EP, HWP, CON Prevention Proram Element Review & Summary for RMP Submittal HA & Draft for Review RMP Risk Manaement Professionals

13 Risk Manaement Professionals Pacin Yourself for the 5-Year Updates T 1 Month T Work with CUPA to Determine Need for Seismic Safety Assessment/Walkdown Site Visits for PHA/HR PHA/HR Report & Draft for Review Site Visits for Seismic Safety Assessment/Walkdown Seismic Report & Draft for Review On-Site CalARP / RMP / PSM Trainin RMP Submittal Draft for Review Finalization of All Work Products & Submittal RMP Risk Manaement Professionals

14 Risk Manaement Professionals What To Do If Startin Late Combinin Consultant Site Activities Runnin Tasks In Parallel Communicatin with the CUPA RMP Risk Manaement Professionals

15 Risk Manaement Professionals Key Requirements of CalARP, PSM, & RMP See Ref. 2 & 5 for Additional Information RMP Risk Manaement Professionals

16 Risk Manaement Professionals Common Deficiencies (from RMP observations and Ref. 3) Operatin Procedures (OP) Written procedures not synchronized with Operator actions Each phase of operation not listed Emerency shutdown procedure job assinments not clear Temporary operations not included Process Safety Information (PSI) Pipin & Instrumentation Diarams (P&IDs) missin or not current PSI not properly filed, manaed, or available Relief system desin or desin basis not documented Compliance with reconized and enerally-accepted ood enineerin practices not documented Electrical area classifications not documented Chemical reactivity hazard evaluations not documented RMP Risk Manaement Professionals

17 Risk Manaement Professionals Common Deficiencies Process Hazard Analysis (PHA) Five-year updates not done on-time Recommendations not closed or closure not documented Human factors or facility sitin not addressed in report Facility sitin not based on current desin codes & standards Mechanical Interity (MI) Written procedures related to the onoin interity of the process not available Inspections are not occurrin or inspection frequency is not consistent with industry standards Equipment deficiencies not corrected in a safe or timely manner Facility relies on a Contractor and does not have a written preventive maintenance schedule that it is committed to RMP Risk Manaement Professionals

18 Risk Manaement Professionals Common Deficiencies Incident Investiation (II) Incident investiations not done correctly Lack of follow-throuh on recommendations Findins not shared with affected employees Employee Participation (EP) Written plan not shared with employees Employees involved in the covered process do not know where PSM/RMP documentation is located Compliance Audits (CA) Lack of follow-throuh on recommendations Inspection of electrical equipment in hazardous areas not conducted to verify compliance with RMP Risk Manaement Professionals

19 Risk Manaement Professionals Common Deficiencies Trainin (TRN) Documentation that demonstrates that trainin has been performed not available Personal protective equipment (PPE) procedures and trainin documentation not available or procedures not followed Hot Work Permit (HWP) Employees not trained or knowledeable in the procedures Safe work practices (e.., LO/TO, HWP, Confined-Space Entry, Line Breakin) not followed (employees or contractors) Manaement of Chane (MOC) MOC Procedure not current or used Prevention Proram documentation not updated to reflect a chane in the system RMP Risk Manaement Professionals

20 Risk Manaement Professionals Common Deficiencies Pre-Startup Safety Review (PSSR) Written procedures do not exist Contractors (CON) Lack of documentation on contractors that the facility is known to frequently use for handlin maintenance or construction Most common proram-wide deficiency: ADDRESSING RECOMMENDATIONS RMP Risk Manaement Professionals

21 Risk Manaement Professionals Process Hazard Analysis Recommendations Federal OSHA has the followin uidance for Process Hazard Analysis findins: An employer can justifiably decline to adopt a recommendation where the employer, can document, in writin and based upon adequate evidence, that one or more of the followin conditions is true: 1. The analysis upon which the recommendation is based contains factual errors. 2. The recommendation is not necessary to protect the health and safety of employees and contractors. 3. An alternative measure would provide a sufficient level of protection. 4. The recommendation is infeasible. RMP Risk Manaement Professionals

22 Risk Manaement Professionals Recommendation Follow-up Basics Assin an individual responsible for followin up on the recommendation. Assin a taret date of completion to each and every recommendation. Document the actions taken for addressin the recommendation, label it as CLOSED, and document the date of completion. RMP Risk Manaement Professionals

23 Risk Manaement Professionals Miscellaneous Oversihts & Challenes Installation & Maintenance Contractors Not Communicatin the Reulatory Impact of Ammonia Inventories to Owners Early Communication with Reulators Obtainin Desin & Project Files from Contractors IIAR and Other Industry Requirements Citable by Reulators RMP Risk Manaement Professionals

24 Risk Manaement Professionals Select Citation Summary (Ref. 3) Total Number of Citations Issued to Refinery Employers 361 Total PSM Citations 9 Sinificant Enforcement Cases 8 Willful Violations 459 Serious Violations 8 Repeat Violations 14 Unclassified Violations 15 Other Violations $2,709, Total Penalties Assessed RMP Risk Manaement Professionals

25 Risk Manaement Professionals Select Citation Summary (Ref. 3) MOC MI - Oper. OP Recom. MI - Insp. & Test PSI OP PSI PHA MI - Insp. & Test Recom. MI - Oper. MOC PHA RMP Risk Manaement Professionals

26 Risk Manaement Professionals References Ammonia Refrieration System Emerency Action Plans vs. Emerency Response Plans, presented at the 2006 RETA Annual Meetin MPAndBestPractices.pdf - Process Safety Reulations and Prevention Proram Overview. 3. Steinway, Seitz, Perry, and Sieel, Before OSHA Comes Knockin, Chemical Enineerin Proress, March Maher, Mone, Hall, Adams - Ammonia Refrieration System Emerency Action Plans vs. Emerency Response Plans (Requirements and Ramifications) asy.pdf - Compliance Audits Made Easy. RMP Risk Manaement Professionals

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