RMP Changes Affecting Refineries & Petrochemical Plantscontent. Petrochemical Plants RMP Changes...

Click here to load reader

download RMP Changes Affecting Refineries & Petrochemical Plantscontent. Petrochemical Plants RMP Changes Affecting

of 24

  • date post

    19-Apr-2020
  • Category

    Documents

  • view

    2
  • download

    0

Embed Size (px)

Transcript of RMP Changes Affecting Refineries & Petrochemical Plantscontent. Petrochemical Plants RMP Changes...

  • February 2016 Page 1RMP Changes Affective Refineries and Petrochemical Plants

    RMP Changes Affecting Refineries & Petrochemical Plants

    Sue Sung, Ph.D., P.E. Director – EHS Global Services Trinity Consultants, Inc. Dallas, Texas

  • February 2016 Page 2RMP Changes Affective Refineries and Petrochemical Plants

    RMP/PSM Changes on the Horizon! 08/01/2013 Executive Order 13650

    • Directed federal agencies to: • Improve operational coordination with, and support to, State and local

    partners • Enhance Federal agency coordination and information sharing • Modernize policies, regulations, and • Work with stakeholders to identify best practices standards

    12/09/2013 OSHA • Issued a Request for Information on the Process Safety Management (PSM)

    Standard

    07/31/2014 EPA • Issued a RFI on the Risk Management Program (RMP) Rule

  • February 2016 Page 3RMP Changes Affective Refineries and Petrochemical Plants

    Overview of RFI on RMP Rule

    Update the list of regulated substances to harmonize the coverage with the OSHA PSM Standard

    Add new requirements to the RMP Prevention Program to be consistent with changes addressed in the OSHA PSM RFI

    Add to or modify the RMP Rule in 12 additional subjects

    EPA requested information in support of the agency’s rule-making to:

  • February 2016 Page 4RMP Changes Affective Refineries and Petrochemical Plants

    OSHA PSM RFI in EPA RFI • Update the list of regulated substances • Additional risk management system elements • Define and require evaluation of updates to applicable Recognized

    and Generally Accepted Good Engineering Practices (RAGAGEP) • Extend mechanical integrity (MI) requirements to cover any safety-

    critical equipment • Require owners and operators to manage organizational changes

    under Management of Change (MOC) • Require third-party compliance audits • Effects of OSHA PSM coverage on RMP applicability

  • February 2016 Page 5RMP Changes Affective Refineries and Petrochemical Plants

    Additional Items in EPA RFI • Safer Technology and Alternatives Analysis • Emergency Drills To Test a Source’s Emergency Response Program

    or Plan • Automated Detection and Monitoring for Releases of Regulated

    Substances • Additional Stationary Source Location Requirements • Compliance With Emergency Response Program Requirements in

    Coordination With Local Responders • Incident Investigation and Accident History Requirements

  • February 2016 Page 6RMP Changes Affective Refineries and Petrochemical Plants

    Additional Items in EPA RFI • Worst case release scenario quantity requirements for processes

    involving numerous small vessels stored together • Public disclosure of information to promote regulatory compliance

    and improve community understanding of chemical risks • Threshold quantities and off-site consequence analysis endpoints for

    regulated substances based on acute exposure guideline level toxicity values

    • Program 3 NAICS codes based on RMP accident history • The ‘‘Safety Case’’ regulatory model • Streamlining RMP requirements

  • February 2016 Page 7RMP Changes Affective Refineries and Petrochemical Plants

    OSHA PSM NEP Enforcement • Top cited PSM elements in OSHA Refinery National Emphasis

    Programs (NEP):

    Including RAGAGEP

    Source: Chemical Safety Board: http://www.csb.gov/UserFiles/file/Barab%20(OSHA)%20PowerPoint.pdf

  • February 2016 Page 8RMP Changes Affective Refineries and Petrochemical Plants

    EPA RMP Enforcement • Prevention Program (i.e., OSHA PSM)

    • Obsolete equipment or design • Failure to review new industry standards

    (RAGAGEP) • PHA findings not resolved, documented,

    or tracked • “Near miss” accidents not investigated • Relying solely on already developed

    industry or manufacturers’ operating procedures

    • Failure to certify operating procedures annually

    • MOC procedures not being followed • Contractor safety performance and

    programs not evaluated

    • RMP Specific • Wrong program level determination • Failure to document RMP management

    system • Failure to maintain documentation for

    worst-case release scenarios • Failure to document maximum inventory,

    upper and lower limits • Wrong chemical chosen for worst case

    scenario modeling in RMP • Failure to report accidents with amounts

    below the CERCLA/EPCRA Reportable Quantities

    • Facilities with few employees claim to have an ERP, indicating they would act as a responding facility

  • February 2016 Page 9RMP Changes Affective Refineries and Petrochemical Plants

    Potential RMP/PSM Changes with Significant Impacts

    Addition of New Risk Management System

    Elements RAGAGEP

    Safer Technology and Alternative

    Analysis

    Mechanical Integrity Incident Investigation Stationary Source Siting

  • February 2016 Page 10RMP Changes Affective Refineries and Petrochemical Plants

    Potential New Risk Management System Elements (1 of 2)• Center for Chemical Process Safety (CCPS) Risk Based Process

    Safety (RBPS) program • Measurements and Metrics – To establish performance and efficiency

    indicators to track the effectiveness of the risk management system, and to identify opportunities for improvement of its elements and work activities.

    • Management Review and Continuous Improvement – To evaluate “regularly” the management systems in place, as opposed to waiting for an incident investigation or scheduled audits to identify deficiencies

    • Process Safety Competency – To focus on organizational learning so that process knowledge can be applied effectively to managing risks

  • February 2016 Page 11RMP Changes Affective Refineries and Petrochemical Plants

    Potential New Risk Management System Elements (2 of 2)

    • Bureau of Safety and Environmental Enforcement (BSEE) Revisions to Safety and Environmental Management Systems (SEMS II):

    • Stop work authority for imminent risk / dangerous activity • Ultimate work authority for operational safety and decision making • Employee participation plan to promote employee as well as management

    participation in hazard mitigation/elimination

    • Additional accident prevention elements considered in the RFI: • Conduct of Operations by Department of Energy (DOE) • Process Safety Culture by CCPS • Job Safety Analysis by CCPS

  • February 2016 Page 12RMP Changes Affective Refineries and Petrochemical Plants

    RAGAGEP in PSM and RMP OSHA PSM 1910.119

    EPA RMP 40 CFR 68 General Requirement Related to RAGAGEP

    (d)(3)(ii) 68.65(d)(2) Process Safety Information: Document that all equipment in PSM-

    covered processes complies with RAGAGEP

    (d)(3)(iii)

    68.65(d)(3) Process Safety Information: Document that equipment is designed and constructed in a safe manner where the design codes, standards, or practices used for existing equipment are no longer in general use or not available when the equipment was designed and constructed

    (j)(4)(ii) 68.73(d)(2) Mechanical Integrity: Inspections and tests are performed on

    process equipment subject to the standard’s MI requirements in accordance with RAGAGEP

    (j)(4)(iii) 68.73(d)(3) Mechanical Integrity: Inspections and test frequency follows

    manufacturer ’s recommendations and good engineering practice, and more frequently if indicated by operating experience

  • February 2016 Page 13RMP Changes Affective Refineries and Petrochemical Plants

    RAGAGEP – New OSHA Policy June 5, 2015 OSHA Guidance Memo • Established primary and secondary sources of RAGAGEP

    • Published codes, consensus documents, and non-consensus documents are primary • Appropriate internal standards are secondary as long as they are as stringent as applicable

    RAGAGEP • Clarifies OSHA enforcement for RAGAGEP requirements

    • “Shall”, “must”, “shall not”, and “should not” are mandatory minimum requirements and failure to follow is presumed to be a violation

    • Compliance with “should” will be presumed to be acceptable • Establishes two categories of RAGAGEP Appendices and Annexes

    • Normative sections explain how to comply with the standard, and their language is treated the same as the standard body

    • Informative sections provide background or reference information but may provide information on hazard identification and abatement

  • February 2016 Page 14RMP Changes Affective Refineries and Petrochemical Plants

    RAGAGEP – Changes in RMP • Required to document applicable RAGAGEP as part of PSI and MI

    with the recently defined OSHA RAGAGEP • Potentially adding RAGAGEP under the following section to require

    facilities to review current RAGAGEP and update existing equipment to meet newer or updated RAGAGEP standards:

    • 40 CFR 68.67(f) PHA • 40 CFR 68.75 MOC

  • February 2016 Page 15RMP Changes Affective Refineries and Petrochemical Plants

    Safer Technology & Alternative Analysis • EPA’s existing guidance on the ‘‘general duty clause’’ in CAA section

    112(r)(1