2 Issues that surround the storage of anhydrous ammonia 1. Government Audit/Citation Exposure a. OSHA i. NEP ii. PQV b. EPA 2. Safety Issues a. Burns b. Respiratory c. Explosive hazards i. Trapped liquid in piping ii. Over-pressurized storage vessel(s) 3. Information Management a. Systems integration b. Information Retrieval (evidence of compliance) c. Mechanical integrity i. Published schedule: preventative maintenance ii. Corrective maintenance iii. Inspection system a. Schedule adherence b. Deficiency tracking issues iv. Reporting d. Training Documentation 2
3 Government Audit/Citation Exposure 3
4 OSHA PSM Elements A PSM program consists of the following 14 elements; 1. Employee Participation 2. Process Safety Information 3. Process Hazard Analysis 4. Operating Procedures 5. Operator Training 6. Contractors 7. Pre-Startup Safety Review 8. Mechanical Integrity 9. Hot Work Permit 10. Management of Change 11. Incident Investigation 12. Emergency Planning and Response 13. Compliance Audits 14. Trade Secrets
5 OSHA National Emphasis Program (NEP) November 29, 2011 Nationwide Acceptance (Finalized) This directive marked the evolution of the pilot NEP on covered facilities - in operation since the summer of from a pilot program to a nationwide program. The new NEP is effective immediately (as of 11/29/2011) and inspections under the program may begin at any time. As expected, the NEP will be implemented nationwide, including the mandatory adoption, or equivalent adoption, by state OSH programs.
6 OSHA National Emphasis Program (NEP) The Inspection Process 1. NEP Inspection is different from the program-quality-verification (PQV) Inspections done using the PQV are broad and open-ended, while inspections using this notice rely on specific investigative questions. The investigative questions are designed to gather facts related to requirements of the PSM standard, and include guidance for reviewing documents, interviewing employees, and verifying implementation.
7 OSHA National Emphasis Program (NEP) The Inspection Process 2. Emphasis on Implementation over Documentation Based on past inspection history at refineries and large chemical plants, OSHA has found that employers may have an extensive written process safety management program, but insufficient program implementation. Therefore, inspections will verify the implementation of PSM elements to ensure that the employer s actual program is consistent with their written program.
8 EPA RMP Elements Subpart A General Scope Definitions Applicability General Requirements Management Subpart B Hazard Assessment Applicability Offsite Consequence Parameters Worst Case Release Scenario Analysis Alternative Case Release Scenario Analysis Defining Offsite Impacts - Population Defining Offsite Impacts - Environment Review and Update Documentation Five Year Accident History Subpart C Prevention Program PSM Program Subpart E Emergency Response Applicability Emergency Response Program Subpart F Regulated Substances for Accidental Release Prevention Purpose Threshold Determination Petition Process Exemptions Exclusions List of Substances Subpart G Risk Management Plan Submission Assertion of Claims Substantiating Claims Executive Summary Registration Offsite Consequence Analysis Five Year Accident History Prevention Program Level 2/3 Emergency Response Program Certification Updates Required Corrections Subpart H Other Requirements Recordkeeping Availability of information to the public Permit Content Audits Appendix
9 Safety Issues 9
10 Burns SKIN CONTACT: Contact with vapor concentrations higher than the IDLH value can result in irritation to moist areas of the body. Any contact with liquid ammonia can result in severe damage to mucous membranes and tissues. Exposure to ammonia can result in hemoptysis, pharyngitis, pulmonary edema, and bronchiectasis. INGESTION: Swallowing liquid ammonia will result in immediate pain and burns to the mouth and esophagus.
11 Respiratory Problems INHALATION: Ammonia gas is extremely odorous and is readily detectable at levels well below those which cause lasting effects. It is extremely irritating to the mucous membranes and lung tissues and inhalation of ammonia vapor will result in pain and burns to the mouth and esophagus
12 Flammability of Ammonia (Outdoors) Ammonia is very difficult to ignite and is a relatively stable compound. It begins to dissociate at approximately 850 F at atmospheric pressure. Experiments conducted by a nationally recognized laboratory showed that an ammonia-air mixture in a standard quartz test container does not ignite lower than 1562 F. Ammonia gas is flammable in air in the range of 16%-25% by volume. Some recent studies indicate that the flammable range may be as low as 15%-28%.
13 Flammability of Ammonia (Indoors) Conditions favorable for ignition are seldom encountered during normal operations due to the high lower limit, narrow range, and the high ignition temperature required. However, the release of ammonia gas into a tightly enclosed or inadequately ventilated space may result in the accumulation of a flammable mixture that can cause a combustion explosion if a high temperature ignition source is present. An ammonia release outside is not likely to constitute a flammable hazard but an ammonia release in a closed room may permit a 16% to 25% concentration of ammonia to develop and is a serious explosive or flammable hazard.
14 Pressure/Temperature Relationship When ammonia liquid and vapor both exist in a closed container, they exhibit the classic equilibrium relationship between pressure and temperature: u Pressure u Pressure, Temperature, Temperature
15 Thermal Expansion Liquid ammonia that exists in pipes or containers without a vapor phase present will exert tremendous pressure from thermal expansion. This thermal expansion (hydrostatic expansion) has been the cause of many ruptured cylinders and piping systems.
16 Over-pressurization of Storage Vessel(s) Great care must be taken to avoid trapping liquid ammonia between closed block valves or over-filling tanks or other containment vessels. Industry standards permit filling of storage tanks to only 86.5% to accommodate potential liquid expansion due to temperature increases without eliminating all vapor space and creating a "skin-tight" full condition.
17 Eye Exposure EYE CONTACT: The eye is 90% water and is the body organ most vulnerable to damage from ammonia. Above the IDLH value there will be extreme eye irritation with involuntary closure of the eyes and visual impairment. Liquid ammonia will very rapidly cause serious burns to the eye and can result in permanent blindness.
18 Information Management 18
19 Systems Integration Safety and compliance documentation for the equipment utilized in the ammonia process as well as the operators who maintain the process, should be integrated with other systems, as they pertain to evidence of compliance, in order to prevent duplication of effort and inaccuracies in data. Systems could include document management, maintenance management, control/dcs, and possibly other systems. 19
20 Information (Evidence of Compliance) All of the information related to the process and evidence of compliance with the standards should be available at any time for operators, managers, auditors or inspectors, 20
21 Overall compliance program should be reviewed and improved regularly.
22 Tasks that originate from compliance activities should be tracked (and documented) to full resolution. 22
23 Mechanical Integrity The purpose of mechanical integrity is to assure that the equipment used to process, store, or handle ammonia is designed, constructed, installed, and maintained to minimize the risk of a release. 23
24 Mechanical Integrity Program Mechanical integrity includes both Preventive and Corrective maintenance for specific types of equipment such as: Pressure vessels and storage tanks. Piping systems (including valves) Pressure relief and vent systems. Emergency shutdown systems. Controls and interlocks (includes monitoring devices and sensor, alarms and interlocks). Pumps
25 Mechanical Integrity Program Your Mechanical Integrity (PM) program should include a published schedule of all required maintenance activity.
26 Mechanical Integrity Program A Mechanical Integrity Program must include: Written Maintenance Procedures - The employer shall establish and implement written procedures to maintain the ongoing integrity of process equipment. Training for maintenance activities The employer shall train each employee involved in maintaining the ongoing integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee s job tasks to assure that the employee can perform the job safely.
27 Mechanical Integrity Program Documented Inspections and Tests These shall follow the recognized and generally accepted good engineering practices (frequency shall be consistent with manufacturers recommendations, and more frequently if determined by operating experience). Documentation of the inspections and tests shall be kept, and also identify the date of the inspection or test, the name of the person performing the inspection, and the serial number or other identifier of the equipment being tested, a description of the test being performed, and the results.
28 Mechanical Integrity Program Equipment Deficiencies The employer shall correct deficiencies in equipment that are outside the acceptable limits (defined by PSI) before further use or in a safe and timely manner when necessary means are taken to assure safe operation. Quality Assurance The employer shall assure that the equipment as it is fabricated is suitable for the process application for which it will be used. Appropriate checks shall be performed to assure that equipment is installed properly. Assure that maintenance materials, spare parts and equipment are suitable for the process application in which they will be used.
29 Reporting Sample PM task list 29
30 Work orders and recurring series should be edited and reassigned easily. Operator (or contractor) comments should be captured along with steps, parts, labor, and supporting documentation or references. 30
31 Training Documentation Training is required to help employees understand the nature and causes of problems arising from hazardous chemical operations, and increase employee awareness with respect to their hazards. 31
32 Training Requirements The purpose of this element is to help employees understand the nature and causes of problems arising from hazardous chemical operations, and increase employee awareness with respect to their hazards.
33 Training Requirements PSM/RMP regulations require orientation training to be given to all employees (and contract employees) before they receive job responsibilities involving the hazardous chemical. This training should include an overview of the process and SOPs. PSM/PMP regulations also require refresher training be given to all employees who have chemical related work responsibilities. Employees should be consulted to determine the appropriate frequency for refresher training.
34 Training should include, but is not limited to the following areas; Handling hazardous chemicals safely Chemical Properties Training (MSDS, First Aid, etc.) PSM/RMP Principles Safe Work Practices Emergency Response Program Principles of the Chemical Process Chemical awareness training must also indicate what actions employees should take in response to the presence of the chemical.
35 Training Documentation The employer shall ascertain that each employee involved in operating a process has received and understood the training required. All training documentation shall include: The identity of the employee The date of the training The means used to verify that the employee understood the training
36 Training reports can be generated to view company wide training status, or by individuals 36
37 Continuous Improvement 37
38 (Issue Tracking) Create Incident/Initiative with scope and timeline details Assignment and Scheduling Closeout by Authorized Personnel
39 List View List view will display all items created by including the system, status, category, due date, and assignments.
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