t

ACKNOWLEDGEMENT

The success of the 15th Annual Meeting of the International Institute of Ammonia Refrigeration is due to the work of the authors whose technical papers appear in this book.

IIAR expresses its deepest appreciation to these authors for their contributions for the betterment of the industry.

--IIAR Board

NOTICE

The views expressed in the papers contained in this book are those of the individual authors. They do not constitute the official views of IIAR and are not endorsed by it.

1101 Connecticut Avenue, N.W. Suite #700

Washington, D. C. 20036 202/857-1100

FAX: 202/223-4579

I I I 1 I I I I I I 1 I I I I I I I I

STEPS FOR COMPLYING WITH

PROCESS SAFETY MANAGEMENT (PSM) REGULATIONS

By:

Peter R. Jordan

Neil P. Mulvey

PrimaTech Inc.

Princeton, New Jersey

Presented at:

IIAR 15th Annual Meeting

March 21-24, 1993

Vancouver, British Columbia, Canada

I I I I a I

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

a

- I. INTRODUCTION

The words Process Safety Management, or PSM, seem to be on the lips of everyone involved

with highly hazardous materials. Much of the interest has developed with the issuance of the

Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM)

regulations (29 CFR Part 1910.119) which became effective on May 26, 1992. These regulations

are designed to protect employees from the risks associated with accidental releases of highly

hazardous chemicals. Besides wondering how the PSM movement developed momentum, many

of those individuals responsible for their company's compliance with industry guidelines and state

and federal regulations are struggling with questions like, "What are we required to do?", "What

is our current status?", and "What should we do first?"

In response to these questions, this paper outlines the background and history behind the Process

Safety Management regulations, describes the requirements from the regulations, and presents

a list of steps to follow in order to comply with the regulations.

- 11. PSM BACKGROUND

Highly hazardous chemicals are attracting increasing attention i n the United States. In many

cases, this increased attention is a result of recent higlily publicized incidents involving

accidental releases of these chemicals, such as the release of methyl isocyanate gas which

Peter Jordan is the Principal Engineer and Neil Mulvey is the Vice President of Primatech, Inc.

i n Princeton, New Jersey.

occurred in Bhopal, India, in December, 1984. The accidents are not limited to the petroleum,

chemical and petrochemical industries: there have been chemical releases involving ammonia

refrigeration facilities as well (Lees, 1980 and McRae, 1987). One result is an effort by

governmental agencies to enact legislation and regulations that are designed to protect employees

and the public from the risks associated with the accidental release of highly hazardous

chemicals. The purpose of these regulations is to require facilities which handle these chemicals

to identify and be aware of their hazards, prevent or reduce the likelihood of a serious incident,

and lessen the consequences of the incident if it were to occur.

The comprehensive management programs which are designed to regulate and control the

handling of hazardous chemicals are collectively referred to as Process Safety Management

(PSM) or Process Hazards Management (PHM) programs. New Jersey was the first state to

adopt PSM regulations (State of New Jersey, 1988). Three other states, California (State of

California, 1987), Delaware (State of Delaware, 1989) and Nevada (State of Nevada, 1991),

followed. In July, 1990, OSHA proposed comprehensive regulations regarding the Process

Safety Management (PSM) of highly hazardous chemicals. These regulations were published in

the Federal Register on February 24, 1992 (OSHA, 1992); the final rule became effective on

March 26, 1992. In addition, the U.S Environmental Protection Agency (USEPA) is currently

developing process safety regulations in response to the Clean Air Act Amendments of 1990

(Dennelly, Menczel, and Simon, 1991). The USEPA is required to adopt final regulations for

Risk Management Programs (RMP) by November 1993. Others have prepared documents which

discuss, compare, and contrast the adopted regulations in detail (Hazzan and Tripoli, 1992).

8

I I I I I I I I I I I I I I i I I I 1

I 1 I I I I I I I I I 1 I I I I I I I

- 111. PSM REQUIREMENTS

Each PSM regulation targets certain lists of hazardous chemicals for inclusion and contains

threshold levels for each chemical. Anhydrous ammonia is included on these lists because of its

relatively high toxicity, its high volatility and its high production quantity. The threshold quantity

for anhydrous ammonia in the OSHA regulations is 10,000 pounds. Thus any ammonia

refrigeration system which handles 10,000 pounds or more of ammonia will have to comply with

the requirements of the OSHA regulations.

The major objective of OSHA’s PSM regulation is to establish procedures that would protect

employees by preventing or minimizing the consequences of accidents involving hazardous

materials. The regulation would accomplish this goal by requiring the development of a

comprehensive management program, one that integrates technologies, procedures and

management practices. This management program would address each of the following thirteen

elements:

employee participation plans to ensure that employers regularly consult with

employees and their representatives on the conduct and development of the

process safety management elements;

process safety information to provide a foundation for identifying and

understanding the hazards involved in the processes and to provide an accurate

body of information and data on the facility from which the other PSM elements

are supported;

9

0

0

0

process hazard analyses to identify, evaluate and control the hazards in processes

involving highly hazardous chemicals;

operating procedures to ensure that employees perform the tasks and procedures

associated with hazardous chemicals in a consistently safe manner;

training programs that will help employees understand the nature and causes of

problems arising from process operations and will increase employee awareness

with respect to the hazards particular to a process;

contractor procedures to ensure contractors performing work on, or near,

processes are aware of the potential hazards associated with their work and the

processes, are trained in the applicable site safe work practices, and are aware of

the actions to be taken during emergencies;

pre-startup safety reviews to ensure that all new or modified facilities are

constructed, installed and operated in accordance with design specifications, that

process hazard analysis recommendations have been addressed prior to startup,

and that training of operating personnel has been completed;

mechanical integrity procedures for process equipment to ensure that the

equipment is designed, installed, operated and maintained properly;

hot work permits for operations performed on, or near, processes to assure that

the employer is aware of the hot work being performed and that appropriate

safety precautions have been taken prior to beginning the work;

management of change procedures designed to address changes to process

technology, equipment and facilities to ensure the safety and health impacts of the

10

I I 1 I 1 I 1 1 I I I 1 I 1 I I I I 1

I 1 I I I 1 I I I I I I I I 1 I I I I

proposed changes are analyzed and that change is documented properly;

incident investigation procedures to thoroughly investigate major, or potentially

major, incidents in order to develop and implement corrective actions to prevent

similar incidents;

emergency planning and response procedures to ensure that emergencies

involving the processing of highly hazardous chemicals are handled properly; and,

compliance audits conducted at least once every three (3) years to ensure that an

effective PSM program is in place and working.

- JY. PSM PROGRAM IMPLEMENTATION

It is estimated that over 25,000 facilities in the U.S. are potentially affected by OSHA’s new

PSM regulations. Many companies are asking questions like:

0

0

0

Is my facility covered by the new PSM regulations?

What happens if we didn’t have everything in-place by May 26, 1992?

Is OSHA going to begin inspecting facilities for PSM compliance immediately?

How aggressive will OSHA be on PSM issues?

Do some of our policies and procedures already satisfy the PSM requirements?

How do we begin developing a PSM program?

What kind of resources will be required?

Should we hold-off until we are forced to develop a plan?

Don’t let these questions and other uncertainties regarding OSHA’s implementation strategy

11

freeze you into non-action. PSM is here and it’s here to stay. OSHA will probably not be

prepared to initiate an organized inspection and compliance program until late 1992 or 1993.

They have indicated, however, that inspections will be initiated as a result of an accident or

employee complaints. OSHA may not expect to see fully implemented PSM programs, but they

will expect to see a well-defined PSM implementation plan and real progress towards developing

the necessary programs and procedures.

Rather than second guessing OSHA’s next move, we suggest that your energies would be better

spent on developing and implementing a PSM program. A four-pronged approach for PSM

compliance might be most effective. This approach includes an assessment of current PSM and

related activities already in-place and an element-by-element implementation scheme.

Specifically, the approach would include:

1. 2. Conduct a Regulatory Review 3. Conduct a PSM Audit 4.

Estimate Your On-Site Ammonia Inventory

Develop a PSM Action Plan

- V. ESTIMATE YOUR ON-SITE AMMONIA INVENTORY

The first step toward compliance with the PSM regulation should be the estimation of the on-site

ammonia inventory for your refrigeration system. Most refrigeration facilities do not have

written documentation estimating their ammonia inventory. This is a crucial piece of information

in that it dictates whether a facility is covered by the PSM regulation. Note that the threshold

quantity for anhydrous ammonia under the OSHA PSM regulation is 10,000 lbs.

12

I I I I I 1 1 I I I I I I I I I 1 I I

I I I I 1 I I I I I I I I I I I I I I

One approach used to estimate the ammonia inventory in a refrigeration system is to first

estimate the individual equipment and piping capacities. This estimation is then compared with

invoices containing the size and frequency of ammonia deliveries to the site to make a

determination of the total system inventory. The estimation of equipment and piping sizes is

commonly contained in a table containing the following information:

0

equipment location

0 design temperature and pressure

0 maximum ammonia capacity

maximum operating level

basis for inventory calculations

equipment description and identification number

Table 1 contains a component inventory list for a simplified ammonia refrigeration facility. The

maximum capacity and the maximum operating levels were calculated by multiplying the

component volume by the density of ammonia at the system temperatures/pressures. Note that

we have used the maximum operating level rather than the maximum capacity to calculate the

total ammonia inventory in the refrigeration system. This is crucial because many vessels in a

typical refrigeration facility operate at less that 50% of their maximum capacity. Once the total

ammonia inventory is calculated, it should be compared with the anhydrous ammonia regulatory

threshold (Le., 10,000 lbs. for OSHA regulations) to determine if the facility is required to

comply with the PSM regulations.

Even if your facility is under the regulatory threshold for anhydrous ammonia, we recommend

13

that you carefully review the PSM requirements. The guidelines contained in the PSM

regulations are based on general industry practice and, if reasonably implemented, can result in

a smoother running, more efficient operation. In addition, if your ammonia refrigeration facility

were to have a serious incident involving an accidental ammonia release, the facility practices

may be judged against the PSM requirements even if the ammonia inventory is below the

regulatory threshold.

14

I I I I I I I 1 I I I I I 1 I I I I I

TABLE 1

AMMONIA REFRIGERATION FACILITY

COMPONENT INVENTORY LIST

I I I I

Receiver (V- 1) Engine Room Rated for 250 20,000 lbs. NH, 10,000 lbs NH, psig, 300°F

Suction Trap (V- I Engine Room Rated for 150 10,000 lbs. NH, 2,000 lbs. NH, psig, -20 to 300°F

Air Handlers Cold Room (AH-1 to AH-10)

Rated for 250 psig, 300°F

5,000 lbs. NH, 2,500 lbs. NH,

High Pressure Liquid Header (HPLS)

Low Pressure Liquid Header ( L P W

Primarily in Engine Room

Primarily in Engine Room and on Roof

ASME Code for 1200 lbs. NH, 1,200 lbs. NH, Pressure Piping, B31.5

ASME Code for Pressure Piping, B31.5

500 lbs NH, ~~

500 lbs NH,

I I

TOTAL INVENTORY: 16,200 lbs NH,

Operated < 50 % Full, Density = 37.7 lb/ft3

Operated < 20 % Full, Density = 40.0 lb/ft3

Coils <50% Full, Density = 40 lb/ft3

100 ft. of 4" dia. 450 ft. of 3" dia. Density = 37.7 lb/ft3

300 ft. of 2" dia. 1000 ft. of 1" dia. Density = 40.0 lb/ft3

15

VI. CONDUCT A REGULATORY REVIEW

Once a facility has determined whether they must comply with the PSM regulation, the next step

is to gain a working knowledge of the regulation. We recommend that you obtain a copy of the

regulation published in the Federal Register (OSHA, 1992). The regulation not only lists the

specific PSM requirements but also provides background and supplemental information. Copies

of the OSHA regulation are available through the regional OSHA agencies. Additionally, the

following OSHA documents will provide helpful insight into developing and implementing a

PSM program:

0

0

0

0

0

#3132 Process Safety Management (1992)

#3084 Chemical Hazard Communication (1992 Revised)

#3088 How to Prepare for Workplace Emergencies (1991 Revised)

#2098 OSHA Inspections (1992 Revised)

#3021 OSHA: Employee Workplace Rights (1991 Revised)

#3077 Personal Protective Equipment (1992 Revised)

#3133 Process Safety Management Guidelines for Compliance (1992)

If you would like additional information on the regulation, the IIAR sponsors seminars designed

to review the impact of the regulation on the ammonia refrigeration industry.

Once you have developed a working knowledge of the PSM regulation, we recommend that you

contact the appropriate regulatory agency to discuss PSM compliance issues, especially if you

are constructing a new ammonia refrigeration facility. The best method to conduct the

discussions is face-to-face. The first benefit in these discussions is that you can begin to develop

16

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

I I 1 I 1 I I I I I I I I I 1 I I 1 I

a working relationship with the regulator(s). We have seen several instances where the actions

of regulators demonstrated that they did not understand the ammonia refrigeration industry, and

these discussions have helped "educate" them. In addition, the regulators typically have a wealth

of knowledge which they are usually willing to share, especially about the specific procedures

that the agency will follow in implementing the regulation. Bear in mind that there is a lot of

interpretation associated with the regulation and, in many cases, the best way to determine how

the regulation is being interpreted is to talk directly to the regulators.

yII. CONDUCT A PSM AUDIT

Once you have developed a working knowledge of the PSM regulation, it is crucial to develop

a strategy for PSM compliance. The first step in developing this strategy is to conduct a

thorough audit of the policies, practices, and procedures at your facility vis-a-vis the new PSM

requirements. This assessment would result in the identification of specific recommendations to

address program deficiencies. The basic premise with this approach is that most facilities have

existing programs and procedures addressing many of the PSM requirements. For example, most

facilities have existing operating procedures, training programs, maintenance procedures and

emergency response plans. While some improvements may be necessary, the existing procedures

should serve as the basis for compliance.

The PSM audit is conducted by posing a series of questions based on elements contained in the

OSHA regulation. These questions are designed to ensure that all thirteen elements are being

planned, scheduled, updated and executed in compliance with the regulation. They should be

17

drafted prior to any on-site review. A complete audit addressing each of the thirteen OSHA PSM

elements will include approximately 300 questions. The same checklist of questions should be

used for each audit if more than one refrigeration system exists at a facility or within the

company. This will help to ensure thoroughness, efficiency, and consistency.

The on-site review should be performed by a team of individuals with expertise in facility and

the PSM regulation. Only a minority of the members of the audit team should be involved in the

day-to-day operation or management of the facility being audited (State of New Jersey, 1988).

The audit questions and answers, remarks and comments, and recommendations for improvement

can be documented on an audit "worksheet": Figure 1 provides an example of a typical audit

worksheet. The deficiencies identified during the course of the audit will be addressed by

implementing an Action Plan.

18

1 I I I I I 1 1 I 1 I I I I I I I 1 I

FIGURE 1

EXAMPLE OF A TYPICAL AUDIT WORKSHEET

AUDIT-PC 1.51

Company: Smith’s I c e Cream Company F a c i l i t y : Armnonia Refr igerat ion F a c i l i t y

Worksheet

System: 1 Page: 1

1. Has the employer developed and implemented w r i t t e n operating procedures that provide c lear i ns t ruc t i ons f o r sa fe l y conducting a c t i v i t i e s involved i n each covered process consistent w i th the process safety information?

I I

12. Do the operating procedures laddress steps f o r each loperating phase:

12.i. I n i t i a l Startup? I

I I

I

I

I I

12.i i . Normal operations?

;Some w r i t t e n loperating procedures ;ex i s t but they ;consist mainly o f ;manufacturer’s ; gener i c recomnended ;pract ices and lprocedures contained 1 i n the equipment 1 manua 1

I

‘;Equipment operating lprocedures address ; i n i t i a l start-up, ;normal operation and !normal shut-down i

,I

I I

d e n t i f y s i t e lPRJlAlthoush no w r i t t e n kpecif ic operations [ ind equipment f o r rhich SOPS should be; feve 1 oped I !

i

:SOPS ex i s t , system ;operators are wel l ;experienced and ; f a m i l i a r wi th a l l ;aspects o f equipment loperation I

19

VIII. DEVELOP PSM ACTION PLAN

The Action Plan should address the specific approaches for developing and implementing the

requirements of the PSM element. It should include a schedule for development and

implementation of the PSM program. In developing the schedule several factors should be

considered, including:

0

0

mandatory dates as specified in the regulation

where appropriate, combining the implementation of one element with another;

for example, combining the development of certain process safety information

with the schedule for completing process hazard analyses

0 an assessment of those items that may be viewed by OSHA as a high priority and,

0 consideration for the time and available resources to implement a

recommendation.

The following sections provide approaches for the development of five high priority PSM

elements :

Process Safety Information

Process Hazard Analysis

0 Operating Procedures

0 Contractors Procedures

Management of Change Procedures

Ix. PROCESS SAFETY INFORMATION

Process safety information is considered the foundation of the other PSM elements. It enables

20

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

those involved in the process to identify and understand the potential hazards associated with the

ammonia refrigeration system. The compiled information is a necessary resource to a variety

of users: operators, contractors, trainers and emergency responders.

An ammonia refrigeration facility is required to compile written information pertaining to the

hazards associated with the ammonia, the technology of the system, and the ammonia

refrigeration equipment.

The information pertaining to the hazards associated with ammonia includes the following items:

0 toxicity information

permissible exposure limits

physical data

reactivity data

0 corrosivity data

0 hazardous effects of inadvertent mixing of ammonia with different

thermal and chemical stability data

materials

Information pertaining to the hazards of ammonia is readily available in a variety of sources:

Material Safety Data Sheets, suppliers’ literature, and IIAR publications. Thus, very little effort

will be required to document this information in a facility’s central filing system, and to make

this information readily accessible to facility employees.

21

Information pertaining to the technology of the ammonia refrigeration system includes the

following items:

maximum intended inventory

block flow or simplified process flow diagram

safe upper and lower limits for operating parameters

an evaluation of the consequences associated with deviations from operating

parameters.

Appendix A describes the items typically found on block flow and simplified process flow

diagrams. For most ammonia refrigeration systems, block flow diagrams which depict the items

in the ammonia refrigeration system and the material flow from item to item are preferred over

process flow diagrams due to the relative simplicity of most ammonia refrigeration systems.

These block flow diagrams can be used by new system operators or by non-site personnel to gain

a quick understanding of the refrigeration system. Block flow diagrams are relatively easy to

prepare; one can typically be produced in four to eight man-hours.

The safe upper and lower limits for operating parameters are usually derived from the

engineering design of the plant, vendor supplied data, or the equipment operating procedures.

The evaluation of the consequences associated with deviations from operating parameters can

best be obtained by conducting a process hazards analysis of the entire ammonia refrigeration

system. By definition, a process hazards analysis identifies the normal operating ranges for the

process parameters and identifies consequences associated with a deviation from these

parameters. Thus, the consequences can typically be obtained directly from the process hazards

I I I I I I I I I I 1 i I 1 I I I 1 I

22

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

analysis worksheets with minimal additional effort.

Information pertaining to the ammonia refrigeration equipment includes the following items:

materials of construction

piping and instrument diagrams (P&IDs)

electrical classification

relief system design and design basis

ventilation system design

design codes and standards

material and energy balances for processes built after May 26, 1992

safety systems (interlocks, detection or suppression systems)

In addition, a facility must document that the equipment complies with recognized and generally

accepted good engineering practices. When existing equipment was built to codes no longer in

use, the facility must document that the equipment is designed, maintained, inspected, tested,

and operated in a safe manner.

The first step that is typically taken to document the ammonia refrigeration equipment is to

prepare accurate and complete P&IDs. Appendix A describes the items found on P&IDs. This

task has typically proven to be very time consuming for many ammonia refrigeration systems

since the P&IDs for many facilities are incomplete or non-existent. Ensuring that complete and

accurate P&IDs for even a relatively small ammonia refrigeration facility can take two to three

man-weeks.

23

Preparation of ammonia refrigeration P&IDs first involves a review of the existing facility

drawingshketches. After this review, conduct a detailed examination of the system to compare

the drawingshketches with the as-built equipment. After the first examination, the sketches are

submitted to a draftsman or CAD operator so that the initial set of drawings can be prepared.

The initial set of drawings are then field verified before final drawings are prepared.

Once P&IDs are available, document the codes and standards that were used to design the

ammonia refrigeration equipment using a table such as the one shown in Table 2. The first step

to prepare this table is to divide up the facility into subsystems such as compressors, condensers,

high pressure vessels , and low pressure vessels. For each subsystem, document the engineering

codes and standards which apply to that subsystem and the practices that were actually used to

construct the facility. Any instances where the facility does not meet existing codes and

standards are documented and then corrected.

24

I I I I I I I I I I 1 I I I I I I 1 1

TABLE 2

AMMONIA REFRIGERATION FACILITY

DESIGN CODES AND STANDARDS

Compressors Each compressor should have suction stop valve(s), discharge stop valve(s), and a discharge check valve. (IIAR Bulletin No. 109)

Oil separators should be located on the compressor discharge lines. (Manufacturer’ s recommendation)

Each compressor has a suction stop valve and a discharge stop valve.

Compressors are not equipped with oil separators.

Ensure each compressor is equipped with a discharge check valve.

Install oil separators in the compressor discharge lines.

25

- X. PROCESS HAZARD ANALYSIS

A facility is required to perform initial process hazard analyses on the ammonia refrigeration

system to identify, evaluate, and control the hazards involved in the process. For most facilities,

this analysis must be completed by May 26, 1994. Additional time may be used if the facility

contains more than one ammonia refrigeration system or if the facility contains other compounds

covered by the regulation. Further, the analyses must be updated and revalidated at least every

five years and all associated documentation must be retained for the life of the process.

OSHA offers a choice of methodologies to use for the analysis and specifies that the employer

use one or more that are appropriate for the process being considered. The rule requires that

the analysis address not only the hazards of the process but the identification of previous

incidents, controls applicable to the hazards, consequences of control failure, facility site, and

human factors as well. A qualitative evaluation of the range of possible safety and health effects

on employees caused by the failure of controls must also be addressed by the analysis.

The regulations specify that a team approach must be used in performing the process hazard

analysis and for updating and revalidating the analysis. At least one team member must possess

knowledge and experience specific to the process being considered and at least one team member

must be knowledgeable in the specific process hazard analysis methodology being used.

To follow up the analysis, the employer must establish a system to promptly address the results

and assure the recommendations are resolved and the resolutions documented. Actions to

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I I I I I I I I I I 1 I I I 0 I i I I

resolve the recommendations must be documented, performed as soon as possible, and

communicated to those employees who work with the process or may be affected by the actions.

We prefer using the What-IfKhecklist method for conducting process hazard analyses on

ammonia refrigeration systems. This method is a flexible and thorough technique which enables

a knowledgeable team to analyze hazardous scenarios in an effective and efficient manner. For

most ammonia refrigeration systems, the on-site analysis can be conducted in less than one week

using the What-IfKhecklist method.

A What-IfKhecklist analysis is conducted by posing a series of " What-If" questions, each

representing a potential deviation from process design, maintenance, inspection or operating

practices. For each " What-If" question, the potential hazards associated with the potential

deviation are identified. The consequences of each scenario are subjectively evaluated to

determine whether the deviation could lead to a serious injury or a catastrophic event. Existing

safeguards, mitigating features or operating procedures which can reduce the likelihood or

consequences of the event are identified. Where appropriate, recommendations for improvement

are offered for consideration.

The preparation for the process hazards analysis involves touring the site, discussing the design

and operation of the equipment with facility personnel, and gathering relevant drawings and data.

Information used to conduct process hazard analyses includes plot plans and P&IDs. The team

leader usually develops the "What-If" questions based on this initial review of the facility. The

27

"What-If" analysis worksheets are then completed by the entire team.

A What-If/Checklist analysis is normally performed by completing a worksheet for each system

(see Figure 2). There is specialized computer software available which uses electronic

worksheets for guiding, documenting and reporting on What-IfKhecklist studies. With the use

of this software and with the aid of a data projection pad and an overhead projector, the "What-

If" worksheets can be displayed onto a wall screen for all team participants to see during the

study. Use of the computer software along with the data projection pad greatly enhances the

effectiveness and efficiency of a What-IfKhecklist study.

28

I I I I I I II I I 1 I I 1 1 1 I I 1 I

UHAT I F - P C 3.02 Uorksheet

Company: Smith's I c e Cream F a c i l i t y F a c i l i t y : A m n i a Refr igerat ion F a c i l i t y Page: 1

11. Valve closed i n !Low suction pressure :No safety o r ;compressor suct ion l i n e ;could develop on

!compressor i consequences i envi ronment a 1

; (operabi 1 i t y issue) I

I I

12. Stra iner in suct ion ;See question #I f o r I 1 l i n e plugged I hazards, consequences 1 I I and safeguards !

I

i i I 13. Valve closed i n !compressor discharge !could develop on I compressor and/or

:High discharge pressurelPotentia1 l y damage

I

1

!compressor !release a m n i a due to ; ;high discharge I I

I

I

I

I

I I I +- -

Compressors equipped wi th low suction pressure cut outs

F a c i l i t y inspects & t es ts safety cutouts annually

Compressors equipped wi th high discharge pressure cutouts

F a c i l i t y inspects & t es ts safety cutouts annually

Compressor equipped wi th dual r e l i e f valves

System parameters w i l l be logged by operators once a s h i f t

Ven t i l a t i on fans are automatical ly s ta r ted i f the amnonia monitor i n the engine room alarms - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ +- - -+ - - - - - - - - - - - - - - - - -

FIGURE 2

TYPICAL WHAT-IF WORKSHEET

29

XI. OPERATING PROCEDURES

The regulations requires development and implementation of written operating procedures that

provide clear instructions for safe operation of the process and are consistent with the process

safety information. The written operating procedures must address steps for each operating

phase, operating limits, safety and health considerations, and safety systems and their functions.

The written operating procedures must be reviewed as often as necessary to assure that they

remain accurate, current, and complete considering any changes to the process, and annually

certified by the employer that they are accurate and current. Besides procedures for operation

of the process, the employer must also develop and implement safe work practices to control

hazards during lockout or tagout, confined space entry, opening process equipment or piping,

and control over entrance to the facility by support personnel.

We use the following four step process to prepare written standard operating procedures (SOPs)

for ammonia refrigeration facilities:

Step 1.

Step 2. Prepare example SOPs

Step 3.

Step 4. Prepare remaining SOPs

Develop the SOP format

Review the example SOPs with facility personnel

A. Step 1 - Develop the SOP Format

An SOP format should be designed to present the necessary information to meet the

requirements of the OSHA PSM regulation as well as present the information in a clear,

30

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I I I I I I I I I 1 I i 1 I i 1 I I I

concise way which is readily understandable to the operating personnel. Since the SOPs

comprise the company’s policy with respect to what is to be accomplished, and how it

is to be accomplished safely, it is important that they are specific to the system of

interest, clear, and consistent.

We usually write SOPs in a modular format. Several of the key modules contained in the

SOPs are discussed briefly below.

1. Process Description

This section briefly describes the ammonia refrigeration system. It contains an

overview of the equipment and the operating limits, and highlights any special or

unique operating and safety considerations.

2. Description of Equipment and Safety Systems

This section lists the equipment and safety systems which are included within the

ammonia refrigeration system. Typically, it will include a description of the

equipment, its designation, design specifications, and a description of its service.

3. Ammonia Chemical Properties and Hazards

This section describes the properties and hazards associated with ammonia. It

contains the precautions necessary to prevent exposure to ammonia, including

administrative controls, engineering controls, and personnel protective equipment.

It also describes the measures to be taken if physical contact or exposure occurs.

4. System Operating Limits

This section describes the system operating limits, their relation to system

31

performance, and the consequences associated with deviations from the operating

limits, including those affecting the safety and health of the employees. It also

describes the steps required to correct and/or avoid deviations.

5 . Stepwise Procedures

This section contains the procedures necessary to operate the system. It should

cover all phases of the system operation, including initial startup, normal

operation, temporary operations, normal shutdown, and shutdown following a

turnaround or an emergency shutdown. It also contains safe work practices for

the control of hazards during operations, such as lockout/tagout, confined space

entry, opening process equipment or piping, and control over entrance into the

facility.

6. Emergency Procedures

This section contains the emergency procedures for the system including the

conditions under which emergency shutdown is required, and the assignment of

qualified operators to ensure that the emergency shutdown is executed in a safe

and timely manner. It typically references additional information contained in the

emergency response manual@).

B. Step 2 - Prepare Example SOPS

Based on the finalized list of procedures to be developed and the prioritized schedule for

development, one or a few procedures will be selected as examples. These example

procedures are developed and reviewed with the facility personnel before proceeding with

32

I 1 1 I I I 1 I € f I I € € I € I I I

I I € I € I 1 I 1 1 I I 1 I 1 I I I I

the development of the remaining procedures. This phased development allows a final

review of the proposed format applied to actual procedures. The phased development

will also help in identifying any gaps in the needed information and provide an

opportunity to provide such information.

The written SOPs must reflect actual operating conditions in the ammonia refrigeration

system. The best way to fulfil this requirement is to regularly consult the system

operators and engineers during SOP development. The persons responsible for

developing the SOP must work closely with the system operators and engineers,

especially during the early development stages , to determine the specific procedures

necessary to perform the tasks and procedures assigned to them in a consistently safe

manner. Once these procedures have been determined, they can be formalized and

established in writing according to the previously establish SOP format.

Simplified process sketches will often enhance the operator’s understanding of the

procedure or a step in the procedure. Areas where such sketches may be valuable should

be identified and included in the SOPs.

C. Step 3 - Review Example SOPs with Facility Personnel

SOP development should be an iterative process: after the SOPs are written, they should

be reviewed by appropriate facility personnel to ensure accuracy. Any deviations

between the written SOPs and the actual operations should be revised as necessary.

33

In some cases, the SOP review may best be accomplished by gathering a team of

individuals with expertise in different areas such as engineering, operations, maintenance,

and safety. We use a computer data projection device during the SOP review to

maximize interaction by the team. With the use of an overhead projector, the data

projection pad displays the image from a computer screen onto a wall screen for all to

see. Thus, the projection device allows the entire team to view the SOP during the

review session. This approach has been found to maximize team interaction as well as

to minimize the need for further review and editing of the SOPs.

D. Step 4 - Development of Remaining SOPs

As indicated previously, one or several example SOPs will be developed initially. These

examples will be reviewed with the facility personnel prior to development of the

remaining SOPs. After the example SOPs are reviewed, and any corrections regarding

the format or approach are resolved, proceed with developing the remaining SOPs. As

developed, the SOPs will be submitted as draft documents to the entire team for review.

XII. CONTRACTOR PROCEDURES

The requirements for contractor safety are intended to ensure that the actions of contractors’

employees do not lead to catastrophic releases, fires or explosions. This is accomplished by

assuring that contractors’ employees are aware of the hazards associated with the work, safe

work procedures to carry out their work, and actions to be taken in case of an emergency. It

also requires that contractors assure that their employees follow safe work practice requirements.

34

a The contractor requirements apply to contractors performing maintenance or repair, turnaround,

major renovation, or specialty work on or adjacent to a covered process. It does not apply to

contractors providing incidental services such as janitorial work or delivery services. I

The regulation specifies requirements for the employer (Le., facility) and for the contractor

employer. Table 3 provides an excellent summary of the requirements and responsibilities of

these two groups (Thompson Publishing, 1992).

I I

E 1 1 I

35

TABLE 3. PSM CONTRACTOR REQUIREMENTS

Responsibilities

(1 Review contractor safety record

Provide information on hazards:

To contractor

To contract employees

Explain emergency action plan:

To contractor

To contract employees

Safe work practices:

Implement

Assure adherence

Control entrance, presence, exit of contractors, contract

employees

11 Evaluate contractor performance

11 Maintain contract employee injury, illness log

Assure, document contract employee training

Advise facility of unique hazards

Facility

X

X

X

X

X

X

X

Contractor

X

X

X

X

I 1 1

36

Key steps to developing and implementing a contractor safety program include:

1. Audit existing contractor procedures.

2. Establish a screening procedure to evaluate contract employer’s safety

performance.

Establish and implement an orientation program for contract employees who will

perform work on or adjacent to a covered process.

Establish a requirement that contract employer’s adhere to safe work practices.

Establish a procedure to evaluate contract employer’s performance in fulfilling

PSM obligations.

3.

4.

5 .

The contractor requirements should be reviewed with key facility personnel, including:

0 facility management

0 purchasing staff

0 operating personnel

0 maintenance personnel

Due to documented accidents where a major contributing cause

contractor safety procedures, it is expected that these requirements

for OSHA review (OSHA, 1992).

was the lack of adequate

will receive a high priority

XIII. MANAGEMENT OF CHANGE PROCEDURES

Any facility or process is continually undergoing change. Changes may be implemented to

improve the efficiency of the operation, improve operability, improve safety or to replace

mechanical equipment. Any change, regardless of how small or insignificant it may seem, has

37

the potential to compromise existing safeguards and have potentially catastrophic results.

However, modifications which involve a "replacement in kind" do not constitute a change in

accordance with the PSM regulation.

OSHA's PSM regulation requires facilities to establish and implement written procedures to

manage changes to process chemicals, technology, equipment, and procedures. These

procedures must also apply to changes to related facilities that affect a covered process, such as

utility systems and emergency response programs.

The management of change (MOC) procedure must ensure that the following items are addressed

before any change is made:

0

0

0

the technical basis for the proposed change is reviewed;

the impact of the change on safety and health is considered;

modifications to operating procedures are identified and implemented;

necessary time period for the change is established; and,

authorization requirements for the proposed change are established and followed.

Employees involved in the process, along with maintenance and contract employees, whose job

tasks will be affected by the change, must be notified and trained in the proposed change prior

to start-up. The process safety information and written operating procedures must be updated

where necessary.

It is recognized that change is essential during the life cycle of a facility or process. To allow

38

for such changes, but to ensure that unrecognized and/or unacceptable hazards are not

introduced, the MOC procedure must be developed and implemented to help manage the

necessary changes. The objective of this procedure is to ensure that all changes are properly

reviewed and that any hazards introduced by the implementation of the change are identified and

controlled prior to placing the change in operation.

In establishing a MOC procedure, the following key items should be addressed:

1. Establish the purpose, scope and objective of the MOC procedure. For example,

a typical "scope" may be written as follows:

This management of change procedure is intended to apply to all equipment and procedures involving the ammonia refrigeration system. This procedure applies to any change in procedures regardless of whether the change is considered major or minor, or is of a temporary or permanent nature. All changes, whether considered temporary or permanent, shall be subject to review in accordance with this procedure. Adequate safeguards, either procedural or hardware, shall be provided to safely operate a temporary change. Since it is likely that more emphasis will be provided on procedural safeguards for temporary changes, closer scrutiny may be warranted for temporary changes to ensure the modification does not represent an unacceptable risk.

2. Determine the type of process modifications that constitute a change and will be

covered by the MOC procedure. For example, changes to equipment might

include :

0 substitution of a material of construction with a different material. For

example, a process vessel and/or section of piping is designed with killed

carbon steel. Replacement of a section of the equipment with ordinary

39

carbon steel would constitute a change

replacement of a vessel with one of a different pressure rating;

piping changes as described above for vessels

replacing an existing field mounted, local pump control panel with a

programmable logic controller

changing the elevation of a vessel nozzle or the discharge location of a

vessel outlet. For example, changing the location of a tank overflow from

a location near the top of the tank to discharge at an elevation close to the

ground

installation of a bypass around a section of equipment

replacing a control valve with one of a different size and,

replacing a gasket with one of a different material.

0

0

A change in facilities occurs whenever a modification is made to plant services

or utilities which would not necessarily appear on a process and instrument

diagram. Facility type changes might include changes to:

emergency back-up systems

power supply system

plant security

0 adjacent processes/equipment

A change in procedures might include a temporary or permanent modification of

fire detection and prevention system

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i I 1 I I 1 I 1 I I I I I 1 1 I i I 1

written procedures, including:

0 standard operating procedures

0 preventive maintenance procedures

0 inspection and testing procedures

emergency operating procedures

training procedures and requirements

A change in process technology arises whenever the process or mechanical design

is altered. A change in process technology may occur as a result of changes in

the operating parameters (e.g., pressure, temperature), design inventories,

instrumentation and control systems or materials of construction. Examples of

process technology type changes might include:

0 an increase in ammonia inventory;

equipment unavailability;

installation of new equipment, such as the installation of a new

compressor; and,

a change in operating pressure (or temperature, or flow rate, etc.) outside

of established operating limits. For example, the established operating

limits for a specific piece of equipment are 0-25 psig. It is desired to

operate the equipment at 50 psig to obtain higher temperatures in the

refrigeration system. Since the desired operating pressure (50 psig) is

outside the established limits, this would constitute a change.

41

3. Establish a MOC form which will be used as the primary control document. The

MOC form should include the following provisions:

tracking number

authorizatiodsign-off sheet

priority classification

justification or reason for change

description of change

classification of change (i.e., minor or major)

documentation of technical review

identification of recommendations

identification of follow-up action plan

4. The MOC procedure should clearly identify the roles and responsibilities of

facility personnel in the implementation of the procedure.

Figure 3 includes a diagram of how a MOC procedure is expected to work.

The MOC procedure should be one of the first PSM elements developed since it will help to

control and manage all changes to the PSM program.

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I I I I I I I I I

Y E S

I I I I

COMPLETE SAFETY REVIEW C H E C K L I S T

FIGURE 3 MANAGEMENT OF CHANGE PROCEDURE

CONDUCT W H A T - I F OR HAZOP STUDY

I MANAGEMENT O F CHANGE FORM S U B M I T T E D I

M INOR CHANGE 4 1 I PREL I M I NARY ENG I NEER I NG 1

MAJOR CHANGE 1 I PREL I M I NARY ENG I NEER I NG I

I t I I JI I

I

ADDRESS RECOMMENDATIONS i 6

G INFORM AND T R A I N NECESSARY PERSONNEL

I

I

COMPLETE A U T H O R I Z A T I O N

1 UPDATE RMP F I L E

43

XIV. CONCLUSIONS

Process Safety Management is quickly becoming a major requirement for U. S . companies. The

finalization of OSHA’s PSM regulation and the yet to be proposed USEPA process safety

regulations have placed PSM as one of the highest safety/environmental initiatives in the U.S.

today. This presently applies to refrigeration facilities handling 10,000 lbs. or more of

ammonia.

PSM, as defined by OSHA, is a comprehensive management program consisting of 13 distinct

elements including technological, procedural and managerial practices. Many facilities already

have programs and practices in place that meet some of these requirements. A PSM audit of

existing programs and procedures allows a facility to take advantage of its existing practices and

develop a site specific Action Plan for the development and implementation of a comprehensive

PSM program.

Although in order to achieve full compliance, all of the 13 elements must be in place, we

suggest that five of the highest priorities should be process safety information, process hazard

analysis, operating procedures, contractor procedures and management of change procedures.

This paper reviews the requirements and presents specific compliance strategies for these

elements. OSHA’s PSM regulation is admittedly a comprehensive set of requirements, but with

proper planning, a sound approach and a commitment of some basic resources, compliance can

be achieved.

44

a a I a I a I I I I 1 I I I I i a I I

I I i I I I I I I I I 1 I I I I I I I

REFERENCES

Dennelly , R., Menczel, J., and Simon, C. W., "Accidental Release Prevention Provisions Under the Clean Air Amendments of 1990: Content and Direction," For Presentation at the 84th Annual Air and Hazardous Waste Association Conference, Vancouver, Canada, 1991.

Hazzan, M. J. and C. F. Tripoli, "Process Safety/Risk Management Programs: Compliance with State and Federal Regulations", Primatech, Inc., presented at the AIChE PSM Conference, Houston, TX, February, 1992.

Lees, F. P., Loss Prevention in the Process Industries, Vol. 2, First Edition, Butterworth & Co (Publishers) Ltd, London, England, 1980.

McRae, M. H., "Anhydrous Ammonia Explosion in an Ice Cream Plant, Progress, Vol. 6, No. 1, January, 1987, pp. 17-19.

Plant/Operations

Occupational Safety and Health Administration (OSHA), "Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents; Final Rule, 'I 29 CFR Part 1910, Washington, DC: OSHA, February, 1992.

State of California, "Hazardous Materials Management Act, California Health and Safetv Code, Article 2, Chapter 6.95, California, January, 1987.

State of Delaware, "Extremely Hazardous Substances Risk Management Act, Chapter 77 of Title 7, Delaware Code, Delaware, September, 1989.

State of Nevada, "An Act Relating to Hazardous Substances.. . ' I , Senate Bill No. 641, Nevada, 1991.

State of New Jersey, "Toxic Catastrophe Prevention Act," N.J.A.C. 7:31 et. seq., New Jersey, June, 1988 and August, 1988.

Thompson Publishing Group, "Chemical Process Safety Report", 1992

45

APPENDIX A

AMMONIA REFRIGERATION SYSTEM DRAWINGS

BLOCK FLOW DIAGRAM

A block flow diagram is a simplified diagram including a legend of an ammonia refrigeration facility which depicts the items in the ammonia refrigeration system and the material flow from item to item.

PROCESS FLOW DIAGRAM (PFD)

A Process Flow Diagram is a diagram including a legend of an ammonia refrigeration facility which depicts the use, generation, storage or handling of ammonia. It typically includes the following items:

A. Items of equipment B. Material flow from item to item C. Simplified basic control loops or major control schemes D. Points of discharge to the environment E. Showing or cross-referencing documents which give details of the following:

1. material balance 2. flows 3. raw materials 4. products 5. intermediates 6 . treatment chemicals 7. operating conditions

a. temperature b. pressure c. stream characteristics

8. operating cycles 9. batch sizes 10. legend

PIPING AND INSTRUMENT DIAGRAM (P&ID)

The piping and instrument diagram is a detailed design drawing showing all of the ammonia refrigeration equipment in an "as-built" condition. It typically contains the following items:

A. Every item of ammonia refrigeration equipment and its identification number (including installed spare equipment)

46

I I I I I I I I I I I I I I I 1 I 1 I

B. Every pipe including: 1. size 2. flow direction 3. identification number 4. indication of ANSI piping specification and break between piping specification

C. Symbols and identification of every instrument including: 1. instrument function - to show trips and interlocks following either ISA

standards or an appropriate standard which could be used for the purpose of a hazard analysis or safety review

2. an appropriate symbol legend for instrumentation

D. Every valve

E. Fail-safe position of control valves or non-hand operated valves in the case of instrument air or power failure

F. Steam traps

G . Representation of insulation or heat tracing for: 1. piping 2. ammonia refrigeration equipment 3. instruments

H. Sizes of all important equipment nozzles with location shown schematically to reflect function and elevation, including:

1. drains 2. vents 3. flushing connections 4. steam connections

I. References to inter-facing with other diagrams describing: 1. process 2. service 3. treatment 4. disposal 5 . utility systems

J. Every relief valve and relieving device 1. type 2. size 3. set pressures

K. Instruments to monitor early detection of abnormal conditions or an ammonia release

47

L. Where critical, the relative elevations between equipment and of key piping

M. Notes or symbols on such items as: 1. slope of critical piping to avoid pockets 2. critical symmetrical piping

N. Notes on each item of equipment, such as: 1. material of construction 2. design temperature 3, design pressure 4. design thermal duty of heat exchangers 5 . design capacity 6. dynamic head of rotating equipment, etc.

m: This information can be shown on a separate table appropriately cross- referenced on the P&ID

0. Citations of referenced documents

P. Legends

- Note: May be one or more detailed diagrams, appropriately cross-referenced

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