US EPA Presentation 4/28/2017

Transcription

1 Overview Chemical Accident Prevention Program Requirements - PSM/RMP/CalARP and GDC Requirements USEPA Region 9 Prevention of Chemical Releases at Ammonia Facilities Application at ammonia refrigeration facilities USEPA Inspection process Inspection Photos the Good, Bad and Ugly 1 CAA 112(r)(1) established General Duty Clause CAA 112(r)(7) required EPA to: List at least 100 regulated substances (140 now listed) Develop regulations and guidance to prevent, detect & respond to accidental releases Manage risk management plans (RMPs) submitted by facilities & to make plans available to government officials & public Also required finalization of OSHA s proposed Process Safety Management Standard 33 The Risk Management Program (RMP) is designed to: Prevent accidental chemical releases to air Minimize the consequences of releases that do occur Provide information about chemical hazards to public & government officials toxic & 63 flammable substances Toxic mixtures w/ >1% listed toxic substance and partial pressure > 10 mm Hg Flammable mixtures w/ >1% listed flammable substance in mixture exceeding NFPA 4 flammability criteria Substances with specified concentrations: Nitric Acid ( 80%) Hydrofluoric Acid ( 50%) Hydrochloric Acid ( 37%) Aqueous Ammonia ( 20%) Process safety information Process hazard analysis Operating procedures Training Mechanical integrity Management of change Pre-startup review Compliance audits Incident Investigations Employee participation Hot work permit Contractor management 5 6 RETA Safety Day 1

2 Anhydrous Ammonia National RMP # s 3 rd largest by amount of chemical 9.97 billion pounds Largest No. of Facilities 7,111 Largest No. of Processes 7,600 PSM RMP CalARP GDC Anhydrous 10,000 10, Any Aqueous (>1%) Any Aqueous (>20%,<44%) - 20, Any Aqueous (>44%) 15,000 20, Any Chlorine 1,500 2, Any 7 9 Year US CA Total RETA Safety Day 2

3 RMP Ammonia Refrigeration Incidents Section 112(r)(1) of the Clean Air Act 1,253 Total Releases Owners and operators of facilities utilizing hazardous substances have a General Duty to: Identify hazards that may result from accidental releases using appropriate hazard assessment techniques, Design and maintain a safe facility taking any necessary steps to prevent releases, and Minimize the consequences of accidental releases that do occur. Note - Not limited to specific list of chemicals or threshold quantities Determining Compliance with the General Duty Clause Facilities with any extremely hazardous substance must adhere to: 1) Recognized and generally accepted good engineering practices (RAGAGEPs) and 2) Applicable state & local regulations Note In CA the GDC would clearly apply to ammonia facilities with between 500 and 10,000 pounds Examples: What is RAGAGEP? Widely adopted codes IIAR, ANSI, ASHRAE, NFPA, CMC, NMC Consensus documents API Standards ASME NBIC BPVC Good practices Chlorine Institute pamphlets Mfrs recommendations Internal standards 18 RETA Safety Day 3

4 Typically annually >4% of 1037 Regional Total RMP (~42) Targeting Focus on High Risk facilities Approx. 150 in Region 9 > 35% of total inspections (~15) Refineries, ammonia refrigeration as emphasis areas Releases and other RMP Reportable Accidents Inspect within 6 months CUPA, other referrals 1 day on-site for most Notice typically given (~ 1 week) Team Approach CUPAs/PAs always invited Entry with CUPA (preferrably) Opening meeting with facility Meet with employee representative(s) Facility Process Walk-thru Interview & Doc Review Close-out meeting Notice of Inspection Findings Finding of Violation Administrative Order (Unilateral or on Consent) Administrative Penalties Civil Judicial Referral Criminal January 31, Coming in FY17 5 Sectors Ammonia Refrigeration Fertilizer Distribution Refineries Chemical Manufacturing Gas Processing Goals Reduce risk from chemical accidents Improve corporate & sector-wide safety/compliance Via innovative accident prevention measures and improving response capabilities. Deficient Annual Inspections and/or 5-year MI audits MI deficiencies PRVs Corrosion Inadequate ventilation / lack of system design basis Lack of Relief system design basis Inadequate component labeling Deficient SOPs 23 RETA Safety Day 4

5 Not a good written emergency shut-down procedure! RETA Safety Day 5

6 Pipes Used for Pipe Supports Standard - 5 year replacement for PRVs on ammonia refrigeration systems RETA Safety Day 6

7 Continu9ng Challenge Thus 8 June 2016 RETA Safety Day 7