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Process Safety Management & RiskManagement Planning Overview

by Lee Jarman & Tom Faherty

(The Williams Companies)

Tulsa Chapter ASSEMeeting

May 20, 2009



Objective (What is this all about?)

Provides a generalbackground to ProcessSafety Management

and Risk ManagementPlanning

Is not an in-depthdiscussion of PSM



PSM Background

PSM is a result of significant process industryincidents, for example: 1984 Bhopal, India, Chemical Release and Fatalities 1985, Institute, West Virginia chemical plant incident

(evacuations of local communities, no fatalities) 1989 Pasadena, Texas, chemical plant explosion, 23

deaths and over 100 confirmed injuries Congressional pressure, concerns over protecting the

Public and workers

OSHA PSM rules issued 1992, EPA RMP Rules issued1996



Ammonium Nitrate ExplosionOppau, Germany – Sept. 21, 1921

Photo shows crater and destruction at plant following explosion. At 7:30 a.m. onSeptember 21, 1921, two powerful explosions occurred at the BASF plant in Oppau,Germany.Hazardous material: Ammonium sulfate & ammonium nitrate (50/50)Facility type: fertilizer manufacturing

Deaths: 430-530 (differing numbers on reported fatalities)



Ammonium Nitrate Explosion Texas City, Texas – April 16, 1947

Source: Fire Prevention And Engineering Bureau Of Texas

This aerial photograph , looking south over Monsanto Chemical Co., was taken about 30minutes following the blast of the ship S. S. GRANDCAMP during loading of ammoniumnitrate. The accident damaged more than 90% of the city's buildings and killed nearly 600

people.

C &



Cyclohexane Release &ExplosionFlixborough, England – June 1, 1974

20” bypass piping fabricated on-site from shop stock. This pipe

ruptured and released

Cyclohexane which exploded.Source: UK Health and Safety Executive, Hazardous Installations Directorate

On June 1, 1974 the Nypro Co. site at Flixborough, England was severelydamaged by a large explosion. Twenty-eight workers were killed and a further 36suffered injuries. It is recognized that the number of casualties would have beenmore if the incident had occurred on a weekday, as the main office block was notoccupied. Offsite consequences resulted in fifty-three reported injuries. Property

in the surrounding area was damaged to a varying degree.



Seveso, Italy - 1976

The Seveso accident happened in 1976 at a chemical plant manufacturing pesticides and herbicides. A densevapor cloud containing tetrachlorodibenzoparadioxin (TCDD – dioxin) was released from a reactor, used for theproduction of trichlorofenol.Commonly known as dioxin, this was a poisonous and carcinogenic by-product of an uncontrolled exothermic

reaction. Although no immediate fatalities were reported, kilogram quantities of the substance lethal to maneven in microgram doses were widely dispersed which resulted in an immediate contamination of some tensquare miles of land and vegetation.More than 600 people had to be evacuated from their homes and as many as 2,000 were treated for dioxinpoisoning. This lead to the European “Seveso Directive” to try to prevent similar incidents.



Methyl Isocyanate TankRupture and ReleaseBhopal, India – Dec. 2-3, 1984

Source: United NationsEnvironment Programme

On the night of December 2-3, 1984, a sudden release of about 30 metric tons of methylisocyanate (MIC) occurred at the Union Carbide pesticide plant at Bhopal, India. The accidentwas a result of poor safety management practices, poor early warning systems, and the lackof community preparedness. The accident led to the death of over 2,800 people (other estimates put the immediate death toll as high as 8000) living in the vicinity and causedrespiratory damage and eye damage to over 20,000 others. At least 200,000 people fledBhopal during the week after the accident. Estimates of the damage vary widely between

$350 million to as high as $3 billion.

Photo Source: Indian stategovernment of Madhya Pradesh



Bhopal Aftermath

Bhopal flare tower with corroded andmissing section of pipe.

Plant enclosed by fence in foreground.

Water entered tank 610 inforeground of picture reactingwith MIC and caused anuncontrolled release of a vaporcloud.



Mexico City ExplosionNovember 19, 1984

1984 – Mexico City, Mexico –Explosion – 300 fatalities

(mostly offsite)

– $20M damages

HAZARD: Flammable LPG in tankHAZARD: Flammable LPG in tank



This event and the Bhopal disaster triggered the development of the PSMstandard

Phillips 66 Houston ChemicalComplex Pasadena, Texas –

Oct. 23, 1989

On October 23, 1989, at approximately 1:00 p.m., an explosion and fire ripped through the Phillips 66

Company Houston Chemical Complex in Pasadena, Texas. Twenty-three workers were killed andmore than 130 were injured. Property damage was nearly three-quarters of a billion dollars. Theaccident resulted from a release of extremely flammable process gases that occurred during regular maintenance operations on one of the plant's polyethylene reactors. The evidence showed that morethan 85,000 pounds of highly flammable gases were released through an open valve. A vapor cloudformed and traveled rapidly through the polyethylene plant. Within 90 to 120 seconds, the vapor cloudcame into contact with an ignition source and exploded with the force of 2.4 tons of TNT.



Equilon Refinery Accident

Equilon Oil Refinery –Anacortes, WA

November 25, 1998

Multiple Fatalities – 6workers killed

This was the worst worker fatality incident in the history of WashingtonState.The tragic incident illustrates the critical importance of developing andimplementing the management systems that form the core of your facilities’ process safety programs.



Ammonium Nitrate ExplosionToulouse, France – September, 21 2001

Accident occurred exactly 80 years after the Oppau, Germany disaster!

Source: United Nations Environment Programme

A huge explosion ripped through AZF (Azote de France) fertilizer factory in an industrial zone on the outskirtsof Toulouse, southwest of France, at 10:15 am, Friday September 21, 2001. Immediately after the accident, 30people were reported dead The total number of injuries was said to be 2,442. More than 350 people were in theplant at the time (266 AZF employees and 100 subcontractors).

The explosion had occurred in a warehouse in which granular ammonium nitrate was stored flat, separated bypartitions. The amount is said to be between 200 to 300 metric tons of ammonium nitrate, which is used tomake fertilizers. A spokesman for the Interior Ministry in Paris ruled out a criminal attack, saying the explosionhad been caused by an accident following an "incident in the handling of products". The exact cause remainsunknown.



Legislative, Agency Actions Clean Air Act of 1990 required OSHA and

EPA to issue regulations

OSHA Process Safety Management (PSM)regulations first published in 1990, effective1992

EPA Risk Management Program (RMP)regulations published in 1992, effective in1996.



Legislative, Agency Actions (Continued)

Clean Air Act of 1990 authorized an independent investigationagency

U.S. Chemical Safety and Hazard Investigation Board (CSB)established in 1998

The CSB Mission: – “The CSB conducts root cause investigations of chemical

accidents at fixed industrial facilities… The agency does not issuefines or citations, but does make recommendations to plants,regulatory agencies such as the Occupational Safety and HealthAdministration (OSHA) and the Environmental Protection Agency(EPA), industry organizations, and labor groups. Congressdesigned the CSB to be non-regulatory and independent of other agencies so that its investigations might, where appropriate,

review the effectiveness of regulations and regulatoryenforcement.” (CSB website, www.csb.gov)



Since 1992 PSM Program Implementation

Incidents resulting in various levels of investigation from Federalagencies, such as:

Repeated incidents at site of 1989 explosion in Pasadena,Texas

Refinery and Chemical Plant incidents in Los Angeles and SanFrancisco Bay Area of California in 1996, 1998

Creation of the Chemical Safety Board (CSB)

BP Amoco Texas City Incidents 2004, 2005, 2007, 2008

BP Refinery Incidents in Illinois, New Jersey

Valero Refinery Incidents, 2006, 2007

Total Fina Refinery Explosion, Borger/Amarillo, Texas, 2008

Etc.



OSHA Response

Current emphasis program to inspectchemical facilities for PSM compliance

Refinery emphasis inspection program

underway Chemical processing facilities are next in cue

Other petroleum processing facilities to be

inspected under the program Congress considering additional mandates



OSHA PSM Program Goals

Targets protecting workers, on-site personnel

OSHA list of Highly Hazardous Chemicals focusedon immediate, on-site hazards

Seeks implementation across chemical processingindustry of key findings from incident investigations

Requires maintaining documents and records aslong as the life of the process

Is a “performance-based” standard, identifiesminimum program expectations



EPA RMP Program Goals

Primarily concerned with preventing off-siteconsequences, short- and long-term

Separate list of chemicals of concern(primarily airborne materials)

Adopted or referenced OSHA PSM as basisof program

Requires submitting various documents,plans and updates to the agency



U. S. Chemical Safety and Hazard

Investigation Board Established to investigate chemical incidents, independent of OSHA

and EPA investigations

CSB selects which chemical or process incident to investigate based onpublic, worker impacts

CSB does not have authority to fine or issue citations CSB investigations do not have maximum lengths, and can take as

long as the Board thinks appropriate to conduct an investigation

CSB is required to hold public hearings on progress of investigation andpossible findings

CSB is required to publish final reports identifying root causes, industry

and agency gaps, maintain these in forums such as the CSB website,and to present these to Congress

PSM, RMP documents and programs are a primary basis for investigations at chemical and oil & gas facilities.

Office in Washington D.C, opening a second in Denver, CO in 2008/9

U S Chemical Safety and



U. S. Chemical Safety andHazard Investigation Board

http://www.chemsafety.gov/index.cfm



Agency Investigation Triggers

CSB can select which incidents to investigate, EPA and OSHAhave specific regulatory requirements for conducting incidentinvestigations

OSHA: Deaths, multiple hospitalizations, significant facilityevacuations, significant fires and explosions, worker complaints

EPA/State Environmental Authority: Release of regulatedsubstances above specified levels, impacts to water resources,land impacts, third party evacuations, public complaints

CSB: Can investigate any fixed facility incident with public or worker impact, including those investigated by EPA, OSHA,

DOT, plus those with other significant public attention



Note regarding process to develop

regulations Usually developed as result of incident investigation,

Congressional order, court order, public pressure

Usually are based on an existing industry standard(API, ANSI, ASTME, or consensus boards)

Are modified after public review and comment(activist groups, court actions, union and industry

groups, legislatures, etc.)

Are not easily changed once in place



14 Key Elements of PSM

Employee Participation Plan

Process safety Information (Documentationof the process)

Process Hazard Analysis

Operating procedures

Operator Training Contractor Evaluation and Selection

Pre-Start-Up Safety Reviews



14 Key Elements of PSM (continued)

Mechanical Integrity Program

Hot Work Permitting Process

Management of Change

Incident Investigation

Emergency Planning and Response

PSM Compliance Audits

Control of Trade Secrets



Employee Participation

Employee involvement in hazard review

Employee participation in incidentinvestigations

Communications of findings from hazardreviews, incident investigations, audits,change processes (MOC), to affected

workers



Process Safety Information

List of specific documents, records to bemaintained

Must be available for hazard reviews,

investigations, training, etc.

Must be updated when impacted by MOC,other modifications



Process Safety Information Information pertaining to the hazards of the highly

hazardous chemicals in the process. This informationshall consist of at least the following: – 1910.119(d)(1)(i) Toxicity information;

–

1910.119(d)(1)(ii) Permissible exposure limits; – 1910.119(d)(1)(iii) Physical data;

– 1910.119(d)(1)(iv) Reactivity data:

– 1910.119(d)(1)(v) Corrosivity data;

– 1910.119(d)(1)(vi) Thermal and chemical stability data; and

– 1910.119(d)(1)(vii) Hazardous effects of inadvertent mixingof different materials that could likely occur.



PSI regarding the process technology

Information concerning the technology of the process shallinclude at least the following

– 1910.119(d)(2)(i)(A) A block flow diagram or simplified processflow diagram (see Appendix B to this section);

– 1910.119(d)(2)(i)(B) Process chemistry;

– 1910.119(d)(2)(i)(C) Maximum intended inventory;

– 1910.119(d)(2)(i)(D) Safe upper and lower limits for such items astemperatures, pressures, flows or compositions; and,

– 1910.119(d)(2)(i)(E) An evaluation of the consequences of deviations, including those affecting the safety and health of

employees. 1910.119(d)(2)(ii) Where the original technical information no

longer exists, such information may be developed inconjunction with the process hazard analysis in sufficient detail to support the analysis.



PSI regarding the process equipment

1910.119(d)(3) Information pertaining to the equipment in the process.

– 1910.119(d)(3)(i) Information pertaining to the equipment in the processshall include:

– 1910.119(d)(3)(i)(A) Materials of construction;

–

1910.119(d)(3)(i)(B) Piping and instrument diagrams (P&ID's); – 1910.119(d)(3)(i)(C) Electrical classification;

– 1910.119(d)(3)(i)(D) Relief system design and design basis;

– 1910.119(d)(3)(i)(E) Ventilation system design;

– 1910.119(d)(3)(i)(F) Design codes and standards employed;

– 1910.119(d)(3)(i)(G) Material and energy balances for processes built after May 26, 1992; and,

– 1910.119(d)(3)(i)(H) Safety systems (e.g. interlocks, detection or suppression systems).

http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_0119&src_anchor_name=1910.119(d)(3)

http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_0119&src_anchor_name=1910.119(d)(3)(i)

http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_0119&src_anchor_name=1910.119(d)(3)(i)

http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_0119&src_anchor_name=1910.119(d)(3)



OSHA PHA Requirements The process hazard analysis shall address:

– 1910.119(e)(3)(i) The hazards of the process;

– 1910.119(e)(3)(ii) The identification of any previous incident

which had a likely potential for catastrophic consequences

in the workplace;

– 1910.119(e)(3)(iii) Engineering and administrative controls

applicable to the hazards and their interrelationships such

as appropriate application of detection methodologies to

provide early warning of releases. (Acceptable detection

methods might include process monitoring and control instrumentation with alarms, and detection hardware such

as hydrocarbon sensors.);



PHA Requirements (Continued)

The process hazard analysis shall address: – 1910.119(e)(3)(iv) Consequences of failure of engineering

and administrative controls;

– 1910.119(e)(3)(v) Facility siting;

– 1910.119(e)(3)(vi) Human factors; and – 1910.119(e)(3)(vii) A qualitative evaluation of a range of the

possible safety and health effects of failure of controls on

employees in the workplace.



PHA Process Goals

Systematic Reviews of new, existing andmodified processes Requires participation by persons operating,

maintaining process (“intimate knowledge”)

Requires participation by a technical expert Includes an evaluation of health and safety

impacts Facilitated by person trained in method used



PHA Methods Acceptable to OSHA

What-If;

Checklist;

What-If/Checklist;

Hazard and Operability Study (HAZOP);

Failure Mode and Effects Analysis (FMEA);

Fault Tree Analysis; or

An appropriate equivalent methodology.



Example of PSM Elements that can be

impacted by a PHA Process Safety Information (Documentation of the

process) Operating procedures Operator Training Pre-Start-Up Safety Reviews Mechanical Integrity Program

Emergency Planning and Response PSM Compliance Audits



PHA Methods typically used in Williams

Midstream and E&P HAZOP: Hazard and Operability Study

What if / Checklist?

Facility Siting Checklist

Human Factors Checklist

Hazard Screening Review Checklist: Applies to

minor changes conducted under MOC



Training

Initial operations training 3-year recertification for operators Task or function specific training for persons

performing mechanical integrity functions. Document that training has been conducted Management Of Change requires training

prior to a person operating a modified

process initially



Contractors

Contractor selection process

Contractor review process

Contractor employee training on hazards of

process Company (Williams) and contractor (contract firm)

duties and responsibilities

Contract operator/maintenance training



Pre-start-up Safety ReviewsRequirement for new and modified processes and equipment.

1910.119(i)(1) The employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification issignificant enough to require a change in the process safety information.

1910.119(i)(2) The pre-startup safety review shall confirm that prior to theintroduction of highly hazardous chemicals to a process:

– 1910.119(i)(2)(i) Construction and equipment is in accordance withdesign specifications;

– 1910.119(i)(2)(ii) Safety, operating, maintenance, and emergencyprocedures are in place and are adequate;

– 1910.119(i)(2)(iii) For new facilities, a process hazard analysis hasbeen performed and recommendations have been resolved or

implemented before startup; and modified facilities meet the

requirements contained in management of change, paragraph (l).

– 1910.119(i)(2)(iv) Training of each employee involved in operating a

process has been completed.



Mechanical Integrity Program

Applies to a list of specific types of componentslisted in regulations (basically, any piece of processequipment)

Written procedures, including testing schedule

Training programs Inspection and testing records (date, item,

inspector, what found, what corrected) kept for lifeof process or equipment



Hot Work Permit

Specifically identified in PSM rule 1910.119(k)(1) The employer shall issue a hot work permit for

hot work operations conducted on or near a covered process.

1910.119(k)(2) The permit shall document that the fireprevention and protection requirements in 29 CFR 1910.252(a)have been implemented prior to beginning the hot workoperations; it shall indicate the date(s) authorized for hot work;and identify the object on which hot work is to be performed.The permit shall be kept on file until completion of the hot workoperations.

http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_0119&src_anchor_name=1910.119(k)(2)

http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_0119&src_anchor_name=1910.119(k)(2)



Management of Change

1910.119(l)(1) The employer shall establishand implement written procedures to managechanges (except for "replacements in kind")to process chemicals, technology,equipment, and procedures; and, changes tofacilities that affect a covered process.



Incident Investigation

Requires that all incidents resulting in or which couldhave resulted in a release of a PSM material beinvestigated promptly, with the investigationbeginning not later than 48 hours after the incident.

The team must include at least one personknowledgeable in the process (usually an operator or maintenance person), a contractor employee is acontract firm was involved, and other experts as

appropriate.



Emergency Planning and Response

Requires a facility to develop and maintain anemergency response plan for major events and for handling small or minor events.

References other emergency response planregulations and training requirements

A PHA recommendation can affect this plan byidentifying a potential incident scenario



Compliance Audits

Certification that an audit has beenconducted is required at least every 3 years

Audit meant to verify that all PSM elementsare in place and are up to date

At least 2 audits must be available



Trade Secrets

Employers may identify and maintain trade secrets. However: 1910.119(p)(1) Employers shall make all information necessary to comply with

the section available to those persons responsible for compiling the processsafety information (required by paragraph (d) of this section), those assisting inthe development of the process hazard analysis (required by paragraph (e) of this section), those responsible for developing the operating procedures(required by paragraph (f) of this section), and those involved in incidentinvestigations (required by paragraph (m) of this section), emergency planning

and response (paragraph (n) of this section) and compliance audits (paragraph(o) of this section) without regard to possible trade secret status of suchinformation.

Employers may require and enforce non-disclosure requirements on companyand contract personnel who have access to or using information designated astrade secrets.



Example of “Disposable” PSM

Records (OSHA) Incident Investigation Reports (minimum of 5

years) PSM Audit Reports (minimum of last 2) Hot Work Permits

Always check Williams policies before disposing of anyrecords



Example of “Evergreen” Records

Documentation that is to be kept current andupdated Process Safety Information Files

Process Technology Files Procedures

Training files

Contractor Evaluation and Selection Files



Example of “Permanent” PSM Records

(OSHA)Kept for the life of the process or equipment

All equipment inspection records

All PHA Reports All Equipment Files (until equipment is disposed

of permanently)

MOC-related files (become part of permanent

equipment/process record of changes or modifications)

PSM vs. EPA Risk



PSM vs. EPA RiskManagement Plans(RMP)

The principal areas in which the requirementsof the EPA differ from the OSHA Rule are:

Different chemical list and Threshold Quantities (TQ) for some chemicals. e.g., Chlorine 1500 lbs. (PSM) v. 2500 lbs.(RMP)

EPA requires hazard assessments that include analyses of the “worst case” accident consequences.

EPA requires preparation of written risk management plansto document the risk management program. The plans mustbe submitted to designated agencies and will be available to

the public.

Risk Management Plans must be registered with the EPA.

PSM Summary



PSM Summary

Facilities with a process using a highly hazardous chemical in anamount exceeding the TQ must develop, document andimplement:

– Written hazard information, process analysis, operatingprocedures, emergency procedures and employee/contractor training.

– Maintenance procedures, inspections, incident evaluations.

– Re-evaluation of PSM information, procedures, complianceaudits of processes and related equipment, and refresher training every three years.

– PHA must be updated & revalidated every 5 years.



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