Process Safety Management of Highly Hazardous & Explosive Chemicals

Process Safety Management of Highly Hazardous & Explosive Chemicals

EPA Clean Air Act - CAA 112 (r) Risk Management Plans

EPA Clean Air Act - CAA 112 (r) Risk Management Plans

Risk Management PlansRisk Management Plans

Many Times Companies Who Must Comply with PSM, must also Comply with the Requirements of EPA Risk Management Plans (RMP)

The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen!

Remember…PSM Protects the Workforce, RMP Protects the Community

Many Times Companies Who Must Comply with PSM, must also Comply with the Requirements of EPA Risk Management Plans (RMP)

The RMP Standard was to be a Mirror of the PSM Standard…Didn’t happen!

Remember…PSM Protects the Workforce, RMP Protects the Community

Could RMP Be Required Here?

Risk Management Plan

Mandated by CAAA, Section 112 (r), 40 CFR Part 68

Promulgated - May 24, 1996 Published Federal Register - June 20, 1996 More than 100,000 facilities affected Designed to help reduce risk of accidental

release of hazardous substances 3 years to implement

Risk Management Plan (continued)

Affects owners of a stationary source with regulated substances above a threshold quantity (TQ): 77 acutely toxic 63 flammable Department of Transportation (DOT) classified

explosive substances Focuses on lethal effects resulting from acute

exposures Includes mandated substances

Not the Same as PSM

Mandated Substances

Ammonia Anhydrous Ammonia Anhydrous Hydrogen

Chloride Anhydrous Sulfur Dioxide Bromine Chlorine Ethylene Oxide Hydrogen Cyanide

Hydrogen Fluoride Hydrogen Sulfide Methyl Chloride Methyl Isocyanate Phosgene Sulfur Trioxide Toluene Diisocyanate Vinyl Chloride

Toxic & Flammable SubstancesHow Did EPA Select Toxic & Flammable

Substances

Extremely hazardous substances under SARA Gases and highly volatile liquids Vapor pressure > 10 mmHg Thresholds ranging from 500-2,000 lbs. Thresholds based on toxicity and volatility NFPA 4 - Most dangerous Flammable gases and volatile flammable liquids that could create

vapor cloud explosions Thresholds set at 10,000 lbs.

Threshold Quantity Determination

Total quantity of a regulated substances contained in a process at any one time

Process included interconnected vessels or separate vessels that could be involved in a release (OSHA PSM definition)

EPA Risk Management Plans(RMP) Basics

CAA 112(r)

Requirements of 112 (r)

Established a general duty clause to:

Identify hazards that may result from releases Design and maintain a safe facility Minimize the consequences or releases

Requirements of 112 (r)

Management system for RMP Required Offsite consequence analysis must be

performed including: Worst-case scenario Alternative release scenario

Must Include 5-year accident history

Requirements of 112 (r)

Prevention program must be developedincluding: 7-elements “mini-PSM” program 14 elements OSHA-PSM program expanded to

address offsite effects Emergency response program is required Risk management plan Submission: Electronic submission to Federal EPA

Available to public (in the public record) Regulatory audits must be performed

Requirements of 112 (r)Requirements of 112 (r) Basic Requirements

Executive summary Registration Off-site consequence analysis Five-year accident history Emergency response plan Prevention program summary information Certification Submission

Sound Much Easier than PSM…Right?

Basic Requirements Executive summary Registration Off-site consequence analysis Five-year accident history Emergency response plan Prevention program summary information Certification Submission

Sound Much Easier than PSM…Right?

Requirements of 112 (r)

A summary (RMP) is Provided to: EPA

Indirectly to: States Locals Public

Manufacturing Industries Affected

Chemical manufacturers Industrial Organics & Inorganics Paints Pharmaceuticals Adhesives Sealants Fibers

Manufacturing Industries Affected

Petrochemical Products Refineries Industrial Gases Plastics and Resins Synthetic Rubber

Non-Manufacturing Affected

Non-Manufacturing Facilities affected Utilities

Electric and Gas (Anhydrous Ammonia) Public Sources

Drinking Water and Waste Water Treatment (Chlorine)

Agriculture Fertilizers, Pesticides (Anhydrous Ammonia)

Other Manufacturing

Electronics Semiconductors Paper Fabricated metals Industrial machinery Furniture Textiles

Other Industries

Food and Cold Storage Propane Retail Warehousing Wholesalers Federal sources

Military and Energy Installations

Hazard Assessment

Offsite consequence data Population estimate in the release plume Public receptors in the release plume Environmental receptors in the release plume

Performed at least every 5 years Performed Within 6 months of a change

that increases or decreased distance by a factor of 2 or more

Overview Worst-Case Scenario

Greatest release quantity from vessel or piping May include administrative controls

Toxic gases Quantity released in 10 minutes

Toxic liquids Instantaneous spill to ground; volatilization; passive

mitigation Toxic gases liquefied by refrigeration

Worst-Case Scenario (continued)

All flammable substances Quantity for vapor cloud explosion

One worst case for each process One worse case representing all toxic

substances

Alternative Release Scenario (ARS)

Next likely release scenario Much reach endpoint offsite One scenario representative of all

flammables is required

ARS Selection

Past Accident history events Process hazard analysis events in PHA’s Worse case with mitigation Example scenarios:

Piping or hose failures Seal failures Vessel overfilling or venting

Offsite Consequence Analysis

Toxic endpoint must be identified Flammable endpoints must be identified Use appropriate models or guidance Within circle, identify

Public receptors and population Environmental receptors Hospitals, Nursing Homes, Schools,

Governmental Agencies

Receptor - Persons that could be affected by a release

Release Plume

All Public Facilities in this Release Plume Must beIdentified & Surveyed

Registration and Submittal

Submit a comprehensive RMP to: EPAIndirectly or Referred to: State Emergency Response Commission

(SERC) Local Emergency Planning Committee

(LEPC) The Chemical Safety and Hazard

Investigation Board With the New Administration - The Process Has Changed

Registration and Submittal (Continued)

Name, mailing address, telephone of stationary source

CAS number of all regulated substances greater than TQ

SIC code Dun and Bradstreet number Certification signed by owner or operator

Auditing the Program

Just Like PSM, You Must Audit the Program (at least every 3 years)

Conduct audits of the management system

RMP ExampleRMP Example

An Actual Example of a Submitted RMP

An Actual Example of a Submitted RMP

Basic Facility Info

Facility ID 100000060613Facility Name Dixie Cold StorageStreet Address Line 1 7199 W. BertCity New OrleansState LAZip Code 711222County Cadme ParishOwner or Operator Name Alan SmithParent Company Pride CorporationLatitude 39.435617Longitude -083.898650Number of RMP Submissions 4

Most Recent Submission Info

RMP ID 47270Submission Type correction for prior submissionSubmission Date 12/19/2006Reason For Submission New accident history informationDeregistration Date 12/29/2006Deregistration Effective Date 12/28/2006Deregistration Reason OtherDeregistration Reason (Other) Sold facilityProcess Toxic Amount Total (lbs) 13,200Process Flammable Amount Total (lbs) 0Process Amount Total (lbs) 13,200Number of Potential Offsite Consequence Processes 1Potential Offsite Consequence Toxic Amount Total (lbs) 13,200Potential Offsite Consequence Flammable Amount Total (lbs) 0Potential Offsite Consequence Amount Total (lbs) 13,200All Process NAICS 49312Exec Summary Submission Date 12/19/2006

Executive Summary

This Risk Management Plan (RMP) covers the Pride Storage Plant in New Orleans, LA. The reason for submitting this RMP is to comply with the mandatory five years update and to report the change of ownership from ACME Foods to Pride Corporation. This facility has two refrigeration systems using anhydrous ammonia as the refrigerant. The amount of anhydrous ammonia contained in only one of the systems is above the EPA threshold reporting quantity of 10,000 pounds.

Because anhydrous ammonia is listed by both the US Occupational Safety and Health Administration (OSHA) and the US Environmental Protection Agency (EPA) as a hazardous chemical, our accidental release prevention program is designed to comply with the Process Safety Management (PSM) and Risk Management Program (RMP) regulations of these two agencies. These regulations are designed to prevent the accidental release of ammonia and to minimize the negative consequences should a release occur…

Submission - Other Facility Info

Owner or Operator Name Alan SmithOwner or Operator Address Line 1 7199 W. BertOwner or Operator City ShreveportOwner or Operator State LAOwner or Operator Zip 711222Parent Dun and Bradstreet Number 7334170Second Parent Dun and Bradstreet Number 0Number of Full Time Employees

44Number of FTE CBI Flag NoCovered by OSHA PSM Standard YesCovered by EPCRA Section 302 YesCovered by CAA Title V NoLast Safety Inspection Date 02/16/2005Last Safety Inspection By State environmental agencyOSHA Star or Merit Ranking NoLEPC Name New Orleans / Cadme LEPC

Submission - Contact InfoOwner or Operator Phone 3186881212Facility URL www.pride.comFacility Phone 3186881222Facility Dun and Bradstreet Number 7444170RMP Contact Linda DarnellRMP Contact Title Corporate PSM DirectorRMP Contact Email Linda.Darnell@pride.com

Submission - Additional InfoRMP Complete Flag YesPredictive Filing NoNo RMP Accidents Last 5 Years NoComplete Check Date 12/20/2006Postmark Date 12/13/2006Anniversary Date 06/21/2009Confidential Business Information N

Submission - Lat/Long InfoLatitude 39.435617Longitude -083.898650Valid Lat/Long YesLat/Long Method GPS - UnspecifiedLat/Long Location Type Storage TankFRS Latitude 39.43FRS Longitude -83.89

Submission - Counts and TotalsNumber of RMP Accidents 1Number of Processes 1Number of Process Chemicals 1Number of Toxic Worst-case Scenarios 1Number of Toxic Alternate Case Scenarios 1Number of Flammable Worst-case Scenarios 0Number of Flammable Alternate Case Scenarios 0RMP Accident Flammable Total (lbs) 0RMP Accident Toxic Total (lbs) 2,530RMP Accident Amount Total (lbs) 2,530Total RMP Accident Deaths 0Total RMP Accident Injuries 0Total RMP Accident Evacuated/Sheltering In Place 0Total RMP Accident Property Damage $

ProcessesProcess Description Ammonia RefrigerationProgram Level 3Confidential Business Information NoToxic Amount Total (lbs) 13,200Flammable Amount Total (lbs) 0Process Amount Total (lbs) 13,200Number of Process Chemicals 1Number of Toxic Worst-Case Scenarios 1Number of Toxic Alternate Scenarios 1Number of Flammable Worst-Case Scenarios 0Number of Flammable Alternate Scenarios 0

Process ChemicalsProcess Chemical ID Ammonia (anhydrous)CAS number 007664417Chemical Type ToxicProcess Chemical Amount (lbs) 13,200Confidential Business Information N

Worst-Case Toxic Scenarios

Percent Weight (Within Mixture) 0Physical State Gas liquified by pressureModel Used EPA's RMP*Comp(TM)Release Duration (minutes) 10Wind Speed (meters/sec) 1.5Atmospheric Stability Class FTopography UrbanPassive Mitigation - Dikes NoPassive Mitigation - Enclosures NoPassive Mitigation - Berms NoPassive Mitigation - Drains NoPassive Mitigation - Sumps NoConfidential Business Information No

Alternate Case Toxic Scenarios

Percent Weight (Within Mixture) 0Physical State Gas liquified by pressureModel Used EPA's RMP*Comp(TM)Wind Speed 3Atmospheric Stability Class DTopography UrbanPassive Mitigation - Dikes NoPassive Mitigation - Enclosures NoPassive Mitigation - Berms No

Prevention Program 3

Safety Info Review Date 04/01/2004PHA Update Date 03/31/2002PHA Technique - What If NoPHA Technique - Checklist NoPHA Technique - What If/Checklist NoPHA Technique - HAZOP YesPHA Technique - FMEA NoPHA Technique - FTA NoPHA Change Completion Date 03/31/2005

Accidents

Accident Date 09/12/2006Accident Time 0540Number of Chemicals 1Flammable Amount Total (lbs) 0Toxic Amount Total (lbs) 2,530Released Amount Total (lbs) 2,530Number of Deaths 0Number of Injuries 0Number Evacuated / Sheltered 0Total Property Damage $0Environmental Damage YesNAICS of Process Involved 49312Release Event - Spill NoRelease Event - Fire NoRelease Event - Explosion

Emergency Response Plan Info

Facility In Community Plan YesFacility Own Response Plan YesSpecific Facility Response Plan YesInform. Procedures in Response Plan YesEmergency Care in Response Plan YesPlan Review Date 04/01/2004Response Training Date 04/28/2004Local Response Agency Shreveport Fire Department

EPA RMP 1998 ChangesCompliance Elements

EPA RMP 1998 ChangesCompliance Elements

Follow-up / completion of PHA recommendation

Re-validation of your PHA every 5 years Compliance audits (required every 3

years) Follow-up / completion of compliance audit

recommendations

Follow-up / completion of PHA recommendation

Re-validation of your PHA every 5 years Compliance audits (required every 3

years) Follow-up / completion of compliance audit

recommendations

EPA RMP 1998 ChangesCompliance Elements

EPA RMP 1998 ChangesCompliance Elements

Annual review and certification of operating procedures

Employee training Updates related to system modifications,

inventory changes, operational changes Off-site consequence analysis Updated

Annual review and certification of operating procedures

Employee training Updates related to system modifications,

inventory changes, operational changes Off-site consequence analysis Updated

EPA RMP SummaryEPA RMP Summary

Not all PSM sites are RMP sites and vice versa

Chemical Substances and TQ’s are Not the Same for PSM

Focused on Protecting the Surrounding Community - Off Site Consequence

Electronically submitted to EPA

Not all PSM sites are RMP sites and vice versa

Chemical Substances and TQ’s are Not the Same for PSM

Focused on Protecting the Surrounding Community - Off Site Consequence

Electronically submitted to EPA

PSM & RMP- Why?PSM & RMP- Why?

To Protect the WorkforceTo Protect the Surrounding CommunityTo Maintain System IntegrityTo Comply with the Law

It’s Not About a Program, It’s About People!

What’s NextWhat’s Next

Course Summary References & Resources

Georgia Tech Research Institute 100% Guarantee

Final Questions Certificates

Course Summary References & Resources

Georgia Tech Research Institute 100% Guarantee

Final Questions Certificates