Psm vpppa reg v

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Process Safety Management John Newquist Draft 5 29 2012

Transcript of Psm vpppa reg v

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Process Safety Management

John Newquist

Draft 5 29 2012

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Overview

TrendsTop PSM Cited Issues

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Outline of Standard

• Application• Employee

Participation• Process Safety

Information • Process Hazard

Analysis • Operating Procedures • Employee Training • Contractors

• Pre-Start up Safety Review

• Mechanical Integrity • Hot Work (Non-routine

Work Authorizations) • Management of

Change • Incident Investigation • Emergency Planning

and Response • Compliance Audits

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Trends• CHEM NEP• Ammonia• Sigcases• Repeat

Violations

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P&IDs

• 119(d)(3)(i)(B)• Relief Valves not in P&ID• P&ID indicated flame arrestors that did not

exist. • P&ID did not indicate correct piping

connections to vessels. Incorrect diameters of piping.

• P&ID did not show LEL detectors and interlocks.

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P&IDs

• 119(d)(3)(i)(B)• No design basis for relief valves on reactor• Valve tags were reversed, mislabeled• HF vent line was not marked• HF dump tank was not identified. • Three way valves were not identified• Equipment were transposed on the

diagrams

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Process Safety Information

• 119(d)(3)(i)(H)PSI did not list: • Cutout devices and Interlocks• High and low level sensors• Ammonia detectors• High and low pressure devices• Emergency Stop Buttons• Electrical Classification of Equipment

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RAGAGEP• 119(d)(3)(ii)• U-1 Form missing for pressure vessel• Mechanical room for ammonia had no emergency ventilation• Electrical Classification of equipment missing• Venting Flanges not meet ANSI/ASME 31.3• No documentation that piping fit for service per API 570• Manual block valves were located down stream of automatic dump

valves (Hydrogen Fluoride Industry Practice Institute or HFIPI)• HF tanks not sized 1.5x for anticipated deliveries. HFIPI • HF dump tank did not have capacity of largest HF tank. HFIPI• HF liquid flow velocity exceeded 5.9 feet/second• Eye wash and shower were not configured to sound in the control

room. HFIPI• No valve capping kit for HF rail car unloading• High pressure vent lines were not labeled. • Relief valve discharge 3.5` above platform vs. 15 feet. (IIAR 2-2008)

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PHA

• 119(e)(1)• No PHA on the Hydrogen Storage tank• PHA missing several elements• PHA did not address failure of ventilation• PHA did not address previous fires. • PHA did not previous piping failures. • PHA did not address previous failures of

cooling systems

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PHA

• 119(e)(3)(i) The hazards of the process;• The hazard of power failure was not discussed in the

PHA.• The Hazard of natural gas draining to the surge drum too

long.• The hazard of releasing material in the neutralization pits• The hazard of weight of hoses on pipe nipples was not

addressed• The Hazards of venting flanges was not addressed in the

PHA.• The hazard of forklift traffic was not addressed.

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PHA

• 119(e)(3)(v)• No analysis of facility siting issues related

to formaldehyde dispersion • Building siting and how affected by the

ammonia process• Ammonia system including piping,

recirculator, chiller, receiver, and condensors were located to the roadway and subject to vehicle impact.

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PHA

• 119(e)(3)(vi)• Human factor• Fatigue• No consider of opening block valves

downstream of remote operated dump valve• Second and third shift training• People on vacation leave• Operational overload during emergencies• Operation interactions

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PHA

• 119(e)(5)• PHA items not resolved for years• PHA did not address team finding and

recommendations such as • Installing back flow prevention when adding

flammable liquids in a tank• Automatic Pressure controls for Nitrogen• Adding relief valves• Facility siting for control rooms• Reconfigurations of valves issue on PHA was

not resolved.

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Operating Procedures

• 119(f)(1)• No written procedures for maintaining the ammonia

systems• No procedures for communicating issues during shift

changes• No procedures for upset condition or avoiding deviations

beyond operating limits. • Transferring chemicals from pit to pit• Neutralization of chemicals

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Operating Procedures

• 119(f)(1)(i)(E)• No procedures for when discharge pressure, suction

pressure, discharge temperature, lubrication oil pressure, and lubrication oil temperature exceed normal operating range

• No Specific steps to stop an emergency• No identification of emergency upset conditions and

procedures to take to resolve it. • No procedure for emergency operations for transfer of

chemicals out a Surge tank• No clear procedures for emptying HF tanks with isolating

nitrogen systems

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Operating Procedures

• 119(f)(3)

• No certification of operating procedures annually.

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Safe Work Practices

• 119(f)(4)

• No safe work procedures developed for contractors or maintenance employees working on PSM covered processes for

• Lockout

• Confined space

• Hot works

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Mechanical Integrity

• 119(j)(2) No inspection procedures• Pressure Vessels• Piping, components, Hose adapters• Pump • Venting Flanges• Compressors and cutout switches• Relief Systems and change out schedule• Emergency Shutdown Systems• Valves requiring Carseals• No Procedures for torquing bolts

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Mechanical Integrity

• 119(j)(4)(i) No inspection of • Relief valves• Pressure vessels (Oil pot, Accumulator, Receiver,

and Transfer Drum)• Ammonia Feed Pumps • Venting flanges• Pipe Nipples, Deadlegs, Inspection ports, hose

adapters• High Level alarms and emergency shutdown

systems.

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Mechanical Integrity

• 119(j)(4)(ii)• No authorized API 570/574 piping inspector or piping

inspections• No API 510 pressure vessel inspector• No corrosion rates established for pressure vessels• Pump not maintained and lubricated per manufacturer’s

recommendations• Rupture Disk was not replaced per manufacturer’s

recommendations• No 100% Radiography or Ultrasonic testing on process

pipe weld repair per ANSI B31.1• No fitness for service for repairs per API 579 for tanks

undergoing repair at head nozzles

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Mechanical Integrity

• 119(j)(4)(iii)• No annual piping inspection• No API internal pressure vessel inspection• No inspection testing of the condensate vapor

system for buildup that might clog the system. • No hydrostatic testing of HF tanks• No testing or exercising of HF vent valves/dump

valves• Not testing compressor cutout switches• Blast Evaporators, heat exchangers not inspected

• No pump inspections

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Management of Change

• 119(L)(1)• No implementation of procedures after• Replacing manual valves with pneumatic actuated

valves. • Installing a LEL detector• Disconnection of the Cooling water System• Installing an alarm on the quench system• Expanding Toulene tank system• Leak at Relief Header Rupture disk • Bolt torquing procedure change• After making changes in the Ammonia system• No MOC for condenser removed from process

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Incident Investigation

• 119(m)(1)

• No incident investigation for

• Ice buildup and cracks in evaporator coils

• Prior incident of adding high temperature product to flammables

• Prior ammonia release.

• Prior corrosion in pipes

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Compliance Audits

• 119(o)(1)

• No PSM evaluation audits were conducted

• No audits of Mechanical integrity, Management of Change, PHA, and Emergency Response.

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Other Issues

• Lockout

• Emergency Response

• Confined Space Rescue

• Electrical Classification

• Hot Works

• Boiler Safety

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Two Investigators

• In most of the cases that we investigate, we have found that most firms completely ignore the 1910.119(j)(5) requirement, and don’t even consider doing an MOC for a temporary change that meets the requirements of 1910.119(l).

• We have two or three cases in our backlog of open cases that deal exactly with these issues. Guess the refinery NEP is having some impact.

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More Comments • I fully agree on the MOC’s; they are called by the workers “Matter of

Convenience” because they believe they are used to justify exceptions and deviations.

• I would add a couple to your list; PSSR (Pre Start-up Safety Review) and organizational issues.

• I just reviewed a couple of investigations where there was an unexpected shutdown on a portion of the unit and in a rush to get the unit back up (they did not fully understand why it had shutdown) and they ended up in a more serious situation.

• Most companies only apply the PSSR part of the PSM standard to a cold start, and even the procedures are written for a cold start and do not work for hot restarts.

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Summary

• Identify the top risks in the facility • Look at corrosion monitoring on pipes and vessels, • Pump vibration leads to failures and fires. • Procedures related to boiler startup, hot works,• Evaluate hydrogen sulfide monitoring, hydrofluoric acid, • Address fatigue and control panel alarms during start ups, • Management of change is slipping.• Gasket torquing procedures should be reviewed as well

as gasket compatibility for service, • Relief valve inspection and testing is a must.• Facility siting is ever present

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[email protected]

Facebook….john newquist312-353-5977

LinkedIn is john newquist

[email protected] Twitter is johnanewquist

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Further This was prepared as a collaborative effort several

friends as a preliminary aid for anyone in the safety and health field.

These are just some the issues. A comprehensive job hazard analysis should be conducted for any task where someone can get hurt.

This is not an official OSHA publication. Those will be on the OSHA.gov website.

If you see any errors my email is [email protected] 312-353-5977 I want to thank Bryan H. Art D. Jim L. Clyde T. Mark K.

and Janet S. for all their assistance in answering questions and providing insight to the many hazards in this sector.