Clean Air Act 112(r] Risk Management Program (RMP' SPCC/FRP EPCRA November - December 2011 US EPA Region 10 Managing Change Abandoned Equipment RMP/PSM Standards RMP eSubmit Webinar RMP Training in 2012 CHEMICAL EMERGENCY PREVENTION & PLANNING Newsletter US EPA Region 10, ERU ECL-116 1200 6th Avenue, Suite 900 Seattle, Washington 98101 206.553.1255 Fax: 206.553.0124 R10 RMP Webpage Newsletter Contacts: For RMP: Javier Morales at morales.javier@epa.gov For SPCC/FRP: AK: Matt Carr at carr.matthew@epa.gov WA OR ID: Michael Sibley at sibley.michael@epa.gov For EPCRA: Suzanne Powers at powers.suzanne@epa.gov For free Subscription: allen.stephanie@epa.gov ©REPORLf CHEMICAL or OIL SPILLS to the NATIONAL RESPONSE CENTER 1-800-424-8802 Managing Change The Chemical Safety Board (CSB) urges organizations to review their Management of Change (MOC) policy to be sure it covers operational variances in addition to physical changes. If your organization doesn't have a systematic method for handling changes, develop and implement one. To maximize the effectiveness of your MOC system, the CSB suggests that the following activities be included: Define safe limits for process conditions, variables and activities and train personnel to recognize significant changes. Combined with knowledge of established operating procedures, this additional training will enable personnel to activate the MOC system when appropriate. Apply multidisciplinary and specialized expertise when analyzing deviations. Use appropriate hazard analysis techniques. Authorize changes at a level commensurate with risks and hazards. Communicate the essential elements of new operating procedures in writing. Communicate potential hazards and safe operating limits in writing. Provide training in new procedures commensurate with their complexity. Conduct periodic audits to determine if the program is effective. continued on page 3 Page 1 ------- Chemical Emergency Prevention & Planning Newsletter November - December 2011 Management of Change: Hazards from Abandoned Equipment (Reprinted from CCPS Process Safety Beacon 9/2011) Did you know? Plants often stop using equipment, piping, and even entire plants or production units for weeks, months, or even years. This can be because of economic conditions, seasonal variation in product demand, or changes in the process. Equipment which is not in use must be isolated from operating equipment, emptied of all chemicals, and de-energized. Your plant should have lock out - tag out procedures to provide guidance on what should be done. 1 When a process is modified and equipment is removed from service, it may be isolated during the plant modifications with the intent to remove it later. But, is it really ever removed? Is the old equipment left in place, rusting and deteriorating? What can you do? Always do a management of change review when removing equipment from service, either temporarily or permanently, or when removing abandoned equipment. Consider what isolation, de- inventorying, and de- energizing is required for equipment not in use. Follow your plant's lock out - tag out procedures. Make sure that equipment which is abandoned with the intention of "removing it later" is actually removed. Raise management awareness of unused piping or equipment. You may know about piping or equipment which is no longer used and has been forgotten. Periodically inspect equipment which is out of service to ensure that it doesn't create a hazard to operating equipment, or the environment. Look for signs of damage, corrosion, or leakage. Pay special attention to block valves, blinds, and other devices which isolate out of service equipment from operating equipment. Manage change when abandoning and removing equipment! In a Texas refinery in February 2007, propane leaked from cracked control station piping which had been out of service for 15 years. A huge fire resulted injuring four people, evacuating the refinery, shutting it down for 2 months, and causing losses of $50 million. In a food processing plant, piping was taken out of service because of asbestos insulation, but the piping was left in place. Eventually the block valves leaked resulting in product contamination. Water leaked into an abandoned electrical box causing a ground fault and a power system trip. A process using phosphorus trichloride (PCI3), a highly water- reactive material, was shut down. A PCI3 tank was supposed to be emptied and left in place. It was not completely emptied. Several years later there was a leak. The PCI3 reacted with water on the ground to create a toxic hydrogen chloride cloud. Page 2 ------- Chemical Emergency Prevention & Planning Newsletter November - December 2011 continued from page 1 Managing Change - Risk Management Program Standards Management of Change/ Pre- startup Safety Review For existing processes that have been shutdown for turnaround, or modification, etc., the employer must assure that any changes other than "replacement in kind" made to the process during shutdown go through the management of change procedures. P&IDs will need to be updated as necessary, as well as operating procedures and instructions. If the changes made to the process during shutdown are significant and impact the training program, then operating personnel as well as employees engaged in routine and nonroutine work in the process area may need some refresher or additional training in light of the changes. Any incident investigation recommendations, compliance audits or PHA recommendations need to be reviewed as well to see what impacts they may have on the process before beginning the startup. Management of Change Requirements (Program Level 3) MOC procedures must address: Technical basis for the change. Impact on safety and health. Modifications to operating procedures. Necessary time period for the change. Authorization requirements for proposed change. Employees affected by the change must: Be informed of the change before startup. Trained in the change before startup. Update process safety information if: A change covered by MOO procedures results in a change in any PSI required under EPA's rule (see § 67.65). Update operating procedures if: A change covered by MOO procedures results in a change in any operating procedure required under EPA's rule (see § 67.69). For more information: General Guidance On Risk Management Programs For Chemical Accident Prevention (40 CFR PART 68). EPA-550-B-04-001 April 2004 Pre-Startup Safety Review For new processes, the employer will find a PHA helpful in improving the design and construction of the process from a reliability and guality point of view. The safe operation of the new process will be enhanced by making use of the PHA recommendations before final installations are completed. P&IDs are to be completed along with having the operating procedures in place and the operating staff trained to run the process before startup. The initial startup procedures and normal operating procedures need to be fully evaluated as part of the pre-startup review to assure a safe transfer into the normal operating mode for meeting the process parameters. continued on page 4 RMP/PSM Requirements for Management of Change MOC procedures must address: Technical basis for the change Impact on safety and health Modifications to operating procedures Necessary time period for the change Authorization reguirements for proposed change Affected employees must be informed and trained before startup Update process safety information if affected by the change Update operating procedures if affected by the change Page 3 ------- Chemical Emergency Prevention & Planning Newsletter November - December 2011 Upcoming RMP*eSubmit Webinar We are pleased to announce that EPA will be holding another RMP*eSubmit Webinar on Wednesday November 9, 2011 at 1:00 PM EST. Space is limited so register as soon as possible. Please register at: http://www.eventbrite.com/event/2l01677173 continued from page 3 Interrelationship of Process Safety Management (PSM) Elements An essential part of verifying program implementation is to audit the flow of information and activities among the Process Safety Management elements. When information in one element is changed or when action takes place in one element that affects other elements, the Safety Compliance Officers or Health Compliance Officers (SCO/HCO) shall review a sample of the related elements to see if the appropriate changes and followup actions have taken place. The following example demonstrates the interrelationship among the elements: During a routine inspection of equipment (Mechanical Integrity), the maintenance worker discovers a valve that no longer meets the applicable code and must be changed. Because the type of valve is no longer made, a different type of valve must be selected and installed (Management of Change). The type of valve selected may mandate different steps for the operators (Operating Procedures) who will require training and verification in the new procedures (Training). The rationale for selecting the type of valve must be made available for review by employees and their representatives (Employee Participation). When the new valve is installed by the supplier (Contractors), it will involve shutting down part of the process (Pre-startup Safety Review) as well as brazing some of the lines (Hot Work Permit). The employer must review the response plan (Emergency Planning) to ensure that procedures are adequate for the installation hazards. Although Management of Change provisions cover interim changes, after the new valve is in place the Process Safety Information will have to be updated before the Process Hazard Analysis is updated or revalidated, to account for potential hazards associated with the new equipment. Also, inspection and maintenance procedures and training will need to be updated (Mechanical Integrity). In summary, 11 PSM elements can be affected by changing one valve. A Health and Safety Compliance Officer would check a representative number of these 11 elements to confirm that the required followup activities have been implemented for the new valve. Source: Process Safety Management of Highly Hazardous Chemicals, OREGON OCCUPATIONAL SAFETY AND HEALTH DIVISION DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, Program Directive A-177, Issued April 5, 1993, Revised August 15, 2000. Page 4 ------- Chemical Emergency Prevention & Planning Newsletter November - December 2011 Upcoming RMP Training in 2012 The Region 10 Risk Management Team is planning next year's training and would like to hear from our facilities/community/ readers. If you would like the training scheduled in your area, or have suggestions of RMP topics needing more explanation, please send your suggestions to Stephanie Allen (allen.stephanie@epa.gov). Where Do I Go For More Information RMP Reporting Materials EPA's Web site: http://www.epa.gov/ emergencies/content/rmp/index.htm includes the Risk Management Program rule, Off-Site Consequence Analysis specific guidance and calculator, the list of regulated substances, fact sheets, guidance documents, industry-specific model plans, FAQs, this RMP*eSubmit Users' Manual, and other information. Superfund, TRI, EPCRA, RMP & Oil Information Center Regulatory Questions Contact the RCRA, Superfund, and EPCRA Call Center for your policy, regulatory compliance, and reporting requirements questions. 800-424-9346 Toll Free 800-553-7672 TDD Monday - Thursday: 10:00 AM - 3:00 PM ET Extended Hours of Operation (May, June and July): Monday - Friday: 9:00 AM - 5:00 PM ET Closed Federal Holidays RMP*eSubmit Software Support Contact the RMP Reporting Center for specific software questions about RMP*eSubmit. (703) 227-7650 (phone) Monday - Friday: 8:00 a.m. -4:30 PM ET. Closed Federal Holidays RMPRC@epacdx.net (e-mail) EPA Region 10 RMP Coordinator: Javier Morales 206-553- 1255 EPA Region 10 RMP Website LISTSERVS EPA maintains numerous listservs to keep the public, state and local officials, and industry up to date, including several that pertain to emergency management. You can sign up for our listserve to receive periodic updates. This newsletter provides information on the EPA Risk Management Program, EPCRA, PCC/FRP and other issues relating to Accidental Release Prevention Requirements. The articles contained herein are provided for general purposes only. EPA does not accept responsibility for any errors or omissions or results of any actions based upon this information. Please consult the applicable regulations when determining compliance. Mention of trade names, products, or services does not convey, and should not be interpreted as conveying official EPA approval, endorsement, or recommendation. The information should be used as a reference tool, not as a definitive source of compliance information. Compliance regulations are published in 40 CFR Part 68 for CAA section 112(r) Risk Management Program, 40 CFR Part 355/370 for EPCRA, and 40 CFR Part 112.2 for SPCC/FRP Page 5 ------- |