Part 1 of 4: NEP Questions?

PSM regulation is over 20 years old and the National Emphasis Program running on 5 years, the regulators are not slowing down.  Recent alerts from EPA (Anhydrous Ammonia at Refrigeration Facilities under Scrutiny) and OSHA (RAGAGEP in PSM Enforcement) show their pursuant for compliance.  Obama has signed chemical executive orders and mandated re-writes of PSM/RMP regulations occurring now.  End users in our industry have to finally understand this is nothing more than a mandated maintenance management program.

Garden City Ammonia Program (GCAP) has been behind the scene working hard building a database of every question asked by OSHA.  It all started by filing “Freedom of Information Requests” for the last five years for all PSM citation incurred in the US.  We have amassed hundreds of NEP questions, pictures, videos, and testimony. This was the foundation to our research for our PSM/RMP book, “Implementing Process Safety Management for Ammonia Refrigeration 4th edition”.

GCAP is now ready to release their database of the hidden NEP questions to the industry.  GCAP has been supporting hands-on training and compliance since 2003.   If you have taken the class you have received the book, seen many of the citations, and have great digital tools for implementing a successful program.  The four top PSM violations the last two years running by element are: Mechanical Integrity, SOP’s, PHA’s, and Training.  This article is part one of four covering Mechanical Integrity.

1910.119(j) Mechanical Integrity: Questions for Maintenance/Operation Personnel

  1. Have you had any formal training with this company for any maintenance procedure/task?
  2. What types of maintenance training have you completed?
  3. Are maintenance materials, spare parts and equipment suitable for the process applications that they are intended?
  4. How are relief valve tests performed at this facility?
  5. How often are relief valves replaced at this facility?
  6. When installing new equipment/valves, are they installed according to manufacturing specifications including torque?
  7. How are repairs to pressure vessels accomplished?
  8. Where are inspections, testing, and maintenance records kept?
  9. How often are ammonia sensors replaced / recalibrated?
  10. Do you have/keep any kind of leak record/log?
  11. Are all areas ammonia piping and equipment located monitored with fixed ammonia leak detectors?
  12. How do you know the automatic emergency shutdown works?
  13. How do you know the manual emergency shutdown works?
  14. Is the emergency shutdown system tested/inspected routinely?
  15. Is the kill button inside or outside the engine room?
  16. Are pipes constructed of compatible materials?
  17. Are hoses used constructed of compatible materials?
  18. Do you know if the facility has any inspection and testing documentations for piping?
  19. Do you know if the facility has any inspection and testing documentations for vessels?
  20. Do you know if the facility has any inspection and testing documentations for hoses?
  21. Do you know if the facility has any inspection and testing documentation for insulation?
  22. Do you know if the facility has any inspection or testing records on pressure relief devices?
  23. Do you know if the facility has any records of vibration analysis on the compressors?
  24. Do you know if the facility has any records on oil analysis for the compressors?
  25. Do you know if the facility has any inspection or records for valves?
  26. How is oil draining performed at this facility?
  27. Does the facility allow oil draining from locations that do not have an oil pot or still?
  28. Are spring return closing valves used at all locations oil is drained?
  29. Does the facility keep logs of oil draining?

1910.119(j) Mechanical Integrity: Questions for Supervisors/Managers/Coordinators

  1. What procedures are in place to maintain the mechanical integrity of vessels?
  2. What procedures are in place to maintain the mechanical integrity of piping?
  3. What procedures are in place to maintain the mechanical integrity of insulation?
  4. What procedures are in place to maintain the mechanical integrity of valves?
  5. What procedures are in place to maintain the mechanical integrity of relief valves?
  6. What procedures are in place to maintain the mechanical integrity of emergency shutdown systems?
  7. What procedures are in place to maintain the mechanical integrity of ammonia detectors?
  8. What procedures are in place to maintain the mechanical integrity of safety pressure switches?
  9. What procedures are in place to maintain the mechanical integrity of level controls?
  10. What procedures are in place to maintain the mechanical integrity of temperature controls?
  11. What procedures are in place to maintain the mechanical integrity of alarms?
  12. What procedures are in place to maintain the mechanical integrity of interlocks?
  13. What procedures are in place to maintain the mechanical integrity of the ventilation system?
  14. What procedures are in place to ensure that there is no water mixed with your ammonia?
  15. What procedures are in place to ensure you have not lost the vapor barrier on insulated surfaces?
  16. What procedures are in place to ensure good housekeeping?
  17. What procedures are in place to ensure that valves are installed to manufactures recommendations including torque?
  18. What procedures are in place to ensure that operators do not create a hydrostatic condition?
  19. What procedures are in place to ensure that high level shutdowns are working?
  20. What procedures are in place to ensure that the facility is following Recognized and Generally Accepted Good Engineering Practices?
  21. What is RAGAGEP for this facilities mechanical integrity program?
  22. What does you facility do when a RAGAGEP is no longer in print, outdated, or has been superseded by another edition?
  23. Are there written procedures for each integrity task for the system?
  24. How often is testing done on all compressor safety cutout switches?
  25. Are valve gasket materials consistent with valve manufactures specifications?
  26. How are mechanical integrity procedures created for new pieces of equipment?
  27. How are mechanical integrity procedures changed if needed?
  28. If a safety device shut down part of the system, are there controls in place to assure that the operator does not override the safety device?
  29. Have you had any formal training with this company for any maintenance procedure?
  30. What types of maintenance training have you completed?
  31. Are maintenance materials and spare parts suitable for the process application for which they are intended?
  32. How are relief valve tests performed at this facility?
  33. When working on the system, what type of PPE is required?
  34. When adding/replacing relief valves to the system, what controls are used to assure that the discharge manifold and piping are adequately sized?
  35. What procedures are in place to replace pipe based upon erosion or corrosion?
  36. Are there detailed procedures for each oil drain point in the ammonia refrigeration system?
  37. What type of inspection/test is done daily?
  38. What type of inspection/test is done weekly?
  39. What type of inspection/test is done monthly?
  40. What type of inspection/test is done semi-annually?
  41. What type of inspection/test is done annually?
  42. What type of inspection/test is done every five years?
  43. Do you have any leak record logs?
  44. Do you have any logs for adding ammonia?
  45. Do you have any logs for adding oil?
  46. Do you have any logs for draining oil?
  47. Are hoses constructed of compatible materials and designed for ammonia?
  48. What procedures are in place for inspection and testing of hoses?
  49. Do you have any inspection records on relief devices?
  50. What are your procedures for testing pipes and vessels?
  51. Who is allowed to weld on the ammonia refrigeration system?
  52. How is training conducted for employees involved with the mechanical integrity of the process?

We hope that this article and others to come help you and your company.  Use these against your own program.  Does your guidelines address these questions? Are you ready for a NEP audit!!

www.AmmoniaTraining.com 

OSHA Region 7 PSM Update 2016

Region 7 OSHA gave the PSM update for 2016 @ GCAP’s 8th Annual Ammonia Safety Day this month.

GCAP OSHA PSM Safety Day

Much emphasis was placed on;

  • RAGAGEP (Recognized and Generally Accepted Good Engineering Practices) such as IIAR, ASHRAE, Center for Chemical Process Safety (CCPS), and others.
  • Retail Exemption Changes
  • Re-write of 1910.119
  • Emergency Planning and Response

View the presentation by clicking this link GCAP OSHA PSM 2016 Update Region 7

EPA RMP Region 7 2016 Update

This years 8th Annual Ammonia Safety Day in Kansas City for Region 7 was a great success.  Over 275 attendees, 27 exhibitors, and a live ammonia release including igniting ammonia in an explosion chamber.

Regions 7 EPA gave a yearly update and explained the new proposed rule, and top 10 list for EPA inspections.  They also explained Region 7 highest citations by element and examples of best practices.

GCAP Safety Day

Top 10 List by EPA for Inspection:

  1. Releases
  2. Facilities that have EHS Chemicals
  3.  Poorly maintained equipment / poor chemical housekeeping
  4. Chemical staining, spillage, dumping, burial
  5. Vessels/containers leaking and no action being taken
  6. Appearance of dumping untreated waste/chemicals down drains, storm sewers, or waterways
  7. More than 500 pounds of NH3, 100 pounds of chlorine gas, or 10,000 pounds of any chemical and local responders do not know
  8. No emergency procedures/plans in the event of a chemical spill
  9. Significant tankage of oil/petroleum without secondary containment
  10. Visual dense smoke or dust (not steam) leaving facility

Region 7 Highest Citation by Element for last rolling year

  1.  Process Hazard Analysis (11%)
  2.  Compliance Audits (10%)
  3.  Process Safety Information (9%)
  4.  Standard Operating Procedures (7%)
  5.  Mechanical Integrity (6%)
  6.  Training (5%)

For more information download EPA’s presentation: EPA RMP Region 7 Update 2016

OSHA’s update will be posted as soon as we get permission from the regional office.

Update: Proposed OSHA PSM Standard Revisions

OSHA has recently released some information to their proposed changes to the PSM rule.  Whom attended the IIAR conference in Orlando was made aware during the government panel and whom attend GCAP’s Safety Day in Kansas City will also receive some of the updates.

Some will directly have affect on our industry and some are unrelated.

The government website url released is having maintenance going on and wont be available till May 14, 2016.  For the time being please visit this reliable source.

Here is a brief overview of additions/changes

  • Atmospheric Storage Tanks
  • Oil and Gas-Well Drilling, Servicing, and Production
  • Chemical Reactivity
  • Safer Technology and Alternatives
  • Additions to Appendix A Chemicals
  • Dismantling/Disposal of Explosives
  • Define/Updating RAGAGEP
  • Mechanical Integrity
  • Employee Participation
  • Emergency Planning
  • Third-party Audits
  • Stop Work Authority
  • Root Cause Analysis
  • Other Management System Components
  • Additional Minor Modifications

Thank you Bryan Haywood for posting.

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Brian Caron Memorial Fund

brian caron

A tragic ammonia accident occurred last week in Massachusetts. Brian Caron, 43, died Wednesday in an ammonia leak at a Stavis Seafoods warehouse in South Boston, where he worked as the facilities manager. Caron was overcome by ammonia fumes inside the cold storage warehouse on Channel Street in South Boston. He was one of five workers who smelled the fumes just as their shift ended Wednesday at 6 p.m.

The workers pushed an emergency switch in hopes of stopping the leak, then rushed out the door. Four workers made it out safely, but Caron could not. A hazmat team found his body in a stairwell on the second floor.

The ammonia leak was found in a ruptured 1½-inch metal pipe, said Steve MacDonald, a spokesman for the Boston Fire Department. The department is investigating the fatal leak, along with the federal Occupational Safety and Health Administration.

Investigators are trying to determine what caused the pipe to burst, but it could take several weeks, MacDonald said. Here is a link to the report.

Brian was a member of the GCAP family. Our prayers are with his family and dear friends. There is no words that can say what we feel at this time of lost. Here is a link for a chance to donate to his memorial fund for his wife, and two daughters during this time of need.

Brian Caron Memorial Fund

Proposed Changes to the EPA RMP Rule

The U.S. Environmental Protection Agency (EPA) is proposing to amend the Accidental Release Prevention Requirements of Risk Management Programs (RMP) under the Clean Air Act, Section 112(r)(7). The proposed revisions aim to modernize its chemical safety and security regulations, guidance, and policies are required under Executive Order (EO) 13650. EO 13650 directs the federal government to carry out a number of tasks intended to prevent chemical accidents, such as the explosion in West, Texas on April 17, 2013.

The proposed revisions include several changes to the accident prevention program requirements, including:

  • An additional requirement for the process hazard analysis (PHA) required for Program 3 processes,
  • Enhancements to the emergency preparedness requirements,
  • Increased public availability of chemical hazard information, and
  • Several other changes to certain regulatory definitions and data elements submitted in the RMPs.

Comments are due 60 days after the date of publication in the Federal Register.

Link to EPA article 

epa rmp

GCAP Ammonia Safety Day

8th Annual Region 7 Ammonia Safety Day

Don’t miss this years 8th annual ammonia safety day.  If you from Kansas, Nebraska, Iowa, Missouri, or Arkansas and anywhere else come join us for a great chance of education and building relationships within the industry.   If you been before, come back and continue the education. If you have never made a GCAP hosted safety day, we encourage you make this years. Last year over 350 participants, 35 vendors, and guest speakers. Must pre-register for the event.

  • June 2, 2016
  • @ Kansas City Community College @ Kansas City, KS
  • $35.00 per attendee
  • $400.00 per exhibitor

If interested in sponsoring please contact us, have available breakfast sponsorship, lunch sponsorships, and general sponsors.

Click here to register today

GCAP-Ammonia-Safety-Day

Dangerously Close

Explosion In West, Texas

CSB Safety Video on the April 17, 2013, fire and explosion at the West Fertilizer Company in West, Texas, which resulted in 15 fatalities, 260 injuries, and widespread community damage. The deadly fire and explosion occurred when about thirty tons of fertilizer grade ammonium nitrate exploded after being heated by a fire at the storage and distribution facility.

YouTube Preview Image

Chairperson Sutherland said, “This tragic accident should not have happened. We hope that this video, by sharing lessons learned from our West Fertilizer Company investigation, will help raise awareness of the hazards of fertilizer grade ammonium nitrate so that a similar accident can be avoided in the future.”

The CSB’s investigation found that several factors contributed to the severity of the explosion, including poor hazard awareness and fact that nearby homes and business were built in close proximity to the West Fertilizer Company over the years prior to the accident. The video explains that there was a stockpile of 40 to 60 tons of ammonium nitrate stored at the facility in plywood bins on the night of the explosion. And although FGAN is stable under normal conditions, it can violently detonate when exposed to contaminants in a fire.

In the video, Team Lead Johnnie Banks says, “We found that as the city of West crept closer and closer to the facility, the surrounding community was not made aware of the serious explosion hazard in their midst. And the West Fertilizer Company underestimated the danger of storing fertilizer grade ammonium nitrate in ordinary combustible structures.”

The CSB investigation concludes that this lack of awareness was due to several factors, including gaps in federal regulatory coverage of ammonium nitrate storage facilities. The video details safety recommendations made to OSHA and the EPA to strengthen their regulations to protect the public from hazards posed by FGAN.

Finally, the video explains how inadequate emergency planning contributed to the tragic accident. The CSB found that the West Volunteer Fire Department was not required to perform pre-incident planning for an ammonium nitrate-related emergency, nor were the volunteer firefighters required to attend training on responding to fires involving hazardous chemicals. As a result, the CSB made several safety recommendations to various stakeholders, including the EPA, to better inform and train emergency responders on the hazards of FGAN and other hazardous chemicals.

IIAR RAGAGEP

Many years back IIAR (International Institute of Ammonia Refrigeration) allowed members access to all IIAR printed RAGAGEP on their website as long as they are a member.  Just recently we logged in to access the new IIAR 2 2014 (published in 2016) to print a copy while waiting for our purchased one to arrive.

Looking at the document, it was not uploaded in a PDF but only as a template for each section. All previous RAGAGEP was uploaded for one single PDF download per document.  IIAR is in the process of only making them read only by section on the website. This should make it a lot easier to view from phones and tablets.  However, you will not be able to download them to a device of choice.  If you are a member, get your library together digitally before it becomes difficult to save and becomes read only access.

ragagep

2016 PSM/RMP Training Opportunities

GCAP is still offering many locations for the PSM/RMP training tour.  Here our some locations coming up including at GCAP.

  • February 29 – March 3, 2016 @ GCAP
  • March 7 – 10, 2016 @ Logan, UT
  • March 21-24, 2016 @ Cassville, MO FULL
  • March 28 – 31, 2016 @ GCAP
  • April 11 – 14, 2016 @ McDonough, GA
  • May 2 – 5, 2016 @ GCAP
  • May 9 – 12, 2016 @ Bakersfield, CA
  • June 6 – 9, 2016 @ GCAP
  • July 18 – 21, 2016 @ Southwest City, MO FULL
  • August 8 – 11, 2016 @ Fort Worth, TX

For more info click here

Implementing Process Safety Management for Ammonia Refrigeration is in our 5th Edition. This book is received with taking GCAP’s PSM/RMP course or can be purchased for $895.00.  Please contact Kristen De La Pena of GCAP at 620.271.0037 or ammonia@pld.com.   The look at a detailed index of the book please visit this link.

PSM Book Cover