Part 1 of 4: NEP Questions?

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!!

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