Newea 2014 - Strengthening Treatment Facility Chemical Process Safety
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Newea 2014 - Strengthening Treatment Facility Chemical Process Safety
- 1. New England Water Environment Association’s Annual Conference Strengthening Treatment Facility Chemical Process Safety David P. Horowitz, P.E., CSP Tighe & Bond 53 Southampton Road Westfield, MA 01085 dphorowitz@tighebond.com
- 2. New England Water Environment Association’s Annual Conference Strengthening Treatment Facility Chemical Process Safety AKNOWLEDGEMENTS: Adam Lomartire – Global Petroleum Andrew Klein – Tighe & Bond
- 3. Takeaways ■ Significant safety concerns – West, TX ■ Significant environmental concerns – Charleston, WV ■ Regulatory requirement – 29 CFR 1910.119 – 40 CFR 68
- 4. Agenda ■ Regulatory requirements ■ Program elements ■ EPA inspections ■ Areas of focus
- 5. Regulatory Requirements ■ OSHA – Process Safety Management (PSM) – 29 CFR 1910.119 – Promulgated 1992 ■ EPA – Chemical Accident Prevention (CAP) – – – – AKA The “risk management plan” or “RMP” rule 40 CFR 68 Promulgated in 1998 Revisions in 2000 and 2004
- 6. What is “Process Safety Management”? ■ Management system ■ Ties elements together – Engineering – Operations – Maintenance ■ Data driven – Prove assumptions – Documented backup ■ Feedback loop ■ Ongoing requirements
- 7. Applicability Thresholds *: applicable only if pressurized for distribution in the facility
- 8. What About the Rest of Us?
- 9. General Duty Clause The owners and operators of stationary sources producing, processing, handling or storing such substances have a general duty, in the same manner and to the same extent as section 654, title 29 of the United States Code, to identify hazards which may result from such releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur. -- Section 112(r)(1) of the Clean Air Act
- 10. GDC Requirements ■ ■ ■ ■ ■ ■ Hazard identification Design safety Operational safety Consequence evaluation Consequence minimization Communication
- 11. EPA CAP Program Levels ■ Three program levels ■ Increasing requirements for each ■ Program 3 = OSHA PSM plus – Registration – Off-site consequence analysis
- 12. Consequence Evaluation ■ Effects of release ■ Simple modeling ■ Impacts to the community ■ Emergency planning Communicate consequences to Communicate consequences to local Fire Department and/or local Fire Department and/or Emergency Planning Commission Emergency Planning Commission
- 13. EPA CAP Program Levels ■ Level 1 – No off site impact – No prior incidents – Not subject to OSHA PSM 1
- 14. EPA CAP Program Levels ■ Level 2 – Potential off site impacts – Not subject to OSHA PSM ■ Level 1 – No off site impact – No prior incidents – Not subject to OSHA PSM 2 1
- 15. EPA CAP Program Levels ■ Level 3 off site impacts – Potential off site impacts – Subject to OSHA PSM; or – One of 10 designed industries by NAICS code ■ Level 2 – Potential off site impacts – Not subject to OSHA PSM ■ Level 1 – No off site impact – No prior incidents – Not subject to OSHA PSM 3 2 1
- 16. RMP Elements ■ ■ ■ ■ ■ ■ ■ ■ Management system Hazard assessment Process safety information Process hazard analysis Operating procedures Training Mechanical integrity Management of change ■ ■ ■ ■ ■ ■ ■ ■ Startup review Compliance audits Incident investigation Employee participation Hot work permits Contractor safety Emergency preparedness Trade secrets
- 17. EPA Focus ■ Chemical safety incorporated into almost every field audit ■ Enhanced training for field personnel 2011 ■ More rigorous inspections
- 18. Inspection Experience ■ “General Duty” is a broad concept ■ Gives inspectors a wide range of latitude ■ Prior inspections were less detailed ■ Staffing
- 19. EPA “Hot Buttons” ■ ■ ■ ■ ■ ■ ■ ■ Management system Hazard assessment Process safety information Process hazard analysis Operating procedures Training Mechanical integrity Management of change ■ ■ ■ ■ ■ ■ ■ ■ Startup review Compliance audits Incident investigation Employee participation Hot work permits Contractor safety Emergency preparedness Trade secrets
- 20. Process Safety Information ■ Operating limits ■ Ventilation design – TR-16, MA PWS guidelines ■ Design standards ■ Material and energy balance ■ Piping and instrumentation diagrams – Up to date
- 21. Process Hazard Analysis ■ Correct methodology ■ Process safety information available – Document what was available to the team ■ Sign-in for the team members ■ Documented recommendations
- 22. Process Hazard Analysis ■ Corrective action plan – Complete within one year ■ Proof of corrective action ■ Review during compliance audit (3-year) ■ Maintain for the life of the process
- 25. What might Change? ■ Process chemistry ■ Mechanical integrity ■ Procedures ■ System drawings ■ Safety and alarm systems ■ Emergency preparedness
- 27. Windsocks
- 29. Emergency Preparedness ■ ■ ■ ■ Relate to off-site consequence Plan for a worst-case event Endorsement Contractor involvement
- 30. ER Training Records ■ Sign-in ■ What was provided ■ Assessment ■ Qualifications
- 32. EPA Audit Tips ■ Take great notes ■ Cooperate ■ Action plan ■ Verification ■ Good faith
- 33. Conclusions ■ Significant safety concerns ■ Significant environmental concerns ■ Regulatory requirement – Compliance not easy
- 34. Questions David P. Horowitz, P.E., CSP 413.572.3211 dphorowitz@tighebond.com LinkedIn: www.linkedin.com/in/dphorowitz Twitter: @dphorowitz Offices throughout New England www.tighebond.com
Editor's Notes
- Methanol mentioned only because of the incident at the Bethune treatment plant in Daytona Beach Florida. Maintenance of flame arrestor, proper materials of construction, and hot work program.
- Effects of release On-site Off-site Simple modeling RMP*Comp Impacts to the community Schools and other places of assembly Fire / Police Nearby industrial processes Incident investigation
- Pulp mill, petroleum refinery, petrochemical mfg, alkali / chlorine mfg, inorganic chemicals, Cyclic Crude and Intermediate Manufacturing, resin, fertilizers, pesticide
- Pulp mill, petroleum refinery, petrochemical mfg, alkali / chlorine mfg, inorganic chemicals, Cyclic Crude and Intermediate Manufacturing, resin, fertilizers, pesticide
- Pulp mill, petroleum refinery, petrochemical mfg, alkali / chlorine mfg, inorganic chemicals, Cyclic Crude and Intermediate Manufacturing, resin, fertilizers, pesticide
- Intent to inspect all registered facilities.
- Includes EPA inspector, consultant, retired chemist.
- TR-16 and PWS guidance say 60 air exchanges / hr.
- What am I supposed to do with that?
- Components of the system Inspection, maintenance or replacement schedule Based on Manufacturer recommendations Established regulatory or consensus standards History with similar equipment Good engineering practices Up to date schedule Show components were serviced and maintained Have a paper trail
- Any change other than replacement “in kind” Review the impact of the change Safety and reliability of the system Checklist for completion Significant changes require pre-startup review May need a limited PHA
- Material and energy balances Mechanical integrity schedules Operating procedures Piping and instrumentation diagrams Safety and alarm systems Emergency preparedness A management system is like an organism, a change in one affects the whole.
- Up to date call list Trained personnel Response objectives Staffing Training Equipment Passes the “straight face” test Coordinated with Local Fire Department Local Emergency Planning Commission Outside contractors Have the right strategy
- Tied to the off-site consequence analysis Plan for a worst-case event All entities must agree Is contractor involvement realistic Level of response Responsiveness
- Sign-in Who was trained When were they trained What was provided Training handout Syllabus or agenda Assessment Demonstration Quiz Trainer qualifications Trainer resume
- You can be nice and still commit to nothing. Argue your case. Take great notes Maintain a cooperative tone Develop and submit an action plan Provide verification if requested Show “good faith” wherever you can Don’t assume the inspector is right
- Regulatory expectations have changed EPA “broad brush” approach Internal audits need to change with it Communicate the risk to clients Attention to detail is key Consolidate paperwork