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 ServicesTrinity 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
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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
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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):
IncludingRAGAGEP
Source: Chemical Safety Board: http://www.csb.gov/UserFiles/file/Barab%20(OSHA)%20PowerPoint.pdf
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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
ElementsRAGAGEP
Safer Technology and Alternative
Analysis
Mechanical Integrity Incident Investigation Stationary Source Siting
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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
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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 RMPOSHA PSM1910.119
EPA RMP40 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
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RAGAGEP – New OSHA PolicyJune 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
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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
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Safer Technology & Alternative Analysis• EPA’s existing guidance on the ‘‘general duty clause’’ in CAA section
112(r)(1) states that “The owners and operators should try to substitute less hazardous substances for extremely hazardous substances or minimize inventories when possible. This is usually the most effective way to prevent accidents and should be the priority of a prevention program.”
• June 9, 2015 EPA and OSHA joint Chemical Safety Alert urging facilities to:• Identify process hazards systematically in PHA review• Develop strategies to identify and apply inherently safe technologies and
inherently safe design to reduce risks to workers, communities, and environment• EPA may amend the RMP rule to require facilities to analyze, document, and
implement safer technologies and alternatives
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Strategies for Safer Technology & Alternative Analysis
Inherent
Passive & Active
Procedural
Source: NIOSH website: http://www.cdc.gov/niosh/topics/hierarchy/
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Mechanical IntegritySAY WHAT YOU DO• Establish inspection and preventative
maintenance program - from initial installation throughout life of facility
• Replace “breakdown” philosophy with on-going equipment integrity philosophy
• Ensure equipment is suitable for process application in which it will be used
• Establish ongoing reliability engineering analysis for critical equipment
• Establish predictive/preventative maintenance program
• Develop written MI procedures to ensure tests, inspections, and preventative maintenance conducted properly and consistently
DO WHAT YOU SAY• Perform periodic inspections and
tests & correct equipment deficiencies promptly.
• Establish procedures to promptly correct deficiencies in equipment outside acceptable limits.
• Establish QA/QC programs
. . . AND DOCUMENT EACH INSPECTION & TESTING
February 2016 Page 18RMP Changes Affective Refineries and Petrochemical Plants
MI for Safety-Critical Equipment (SCE)
• OSHA PSM 1910.119(j) applies to• pressure vessels and storage tanks • piping systems (including
components such as valves) • relief and vent systems and devices • emergency shutdown systems • controls (including monitoring
devices and sensors, alarms, and interlocks)
• pumps
• EPA may expand SCE to equipment such as:• Computer software systems
interacting with process components
• Electrical power systems• Utility systems interacting with
listed SCE• Instruments used as indicators for
SCE• Would substantially increase the
list of SCE and associated maintenance and inspection tasks
February 2016 Page 19RMP Changes Affective Refineries and Petrochemical Plants
Incident Investigation• RMP requires facilities to investigate each significant incident that resulted
in, or could reasonably have resulted in (i.e., near-miss), a catastrophic release. However, the accident history requirement does not include near-miss accidents or accidents with only the potential for off-site consequences.
• EPA may broaden incident investigation and accident history to include:• clear requirements to investigate near misses and determine root causes of
accidents, near misses, and process upsets • establishing specific time frames for incident investigations to be completed
February 2016 Page 20RMP Changes Affective Refineries and Petrochemical Plants
How To Identify Near-Miss Incidents• API RP 754, Process Safety Performance Indicators• CCPS Process Safety Leading and Lagging Metrics
February 2016 Page 21RMP Changes Affective Refineries and Petrochemical Plants
Stationary Source Siting• Facility siting is explicitly required under the PHA element:
• 29 CFR 1910.119(e)(3)(v)• 40 CFR 68.67(c)(5) (Program Level 3 only)
• EPA considers adding more specific requirements to address stationary source siting, such as establishing buffer/setback zone requirements for new covered stationary sources or establishing safety criteria for siting of occupancies within a facility
• Status of siting technique:• No clear guidance on how to adequately address stationary source siting in the
PHA• Facility can refer to industry guidance on siting considerations and most
companies have applied a simple checklist• Some companies have been conducting technical analysis for explosion impacts
or toxic exposure levels
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West Fertilizer Company Before and After April 2013
Example Facility Siting Analysis(software simulation video)
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Conclusion• Significant efforts have been made by companies’ safety groups for
elements covered under the PSM Standard
• In addition to the overlapping issues, environmental staff needs to address issues unique to the RMP rule:• Emergency response planning• Accidental release history• Off-site consequence analysis• Facility siting for new sources• RMP management system documentation• RMPlan submittal with potential new requirements
February 2016 Page 24RMP Changes Affective Refineries and Petrochemical Plants
Dr. Sue [email protected]