8/30/2015. Presentation Goals. Process Safety Management (PSM) Risk Management Program (RMP) Chemical Facility Anti-Terrorism Standards (CFATS) Text

Transcription

1 August 31, 2015 Executive Order 13650, Improving Chemical Facility Safety and Security AHMP 2015 National Conference Scottsdale, AZ Presentation Goals What you should expect from today s presentation: Understand and its impact What RMP, PSM and CFATS changes to expect Current Common RMP/PSM/CFATS violations What I should do to prepare? ENVIRONMENTAL ENGINEERING COMPLIANCE Risk Management Program (RMP) Process Safety Management (PSM) The EPA s Risk Management Program (40 CFR 68) After 1984 Bhopal, India incident (water in MIC, cloud), EPA was directed to improve emergency planning 1986 EPCRA implemented for prevention and mitigation of high hazard chemical releases 1990 Clean Air Act Amendments required EPA to address dangers of hazardous chemicals released to environment Final Rule published June 20, 1996 OSHA s Process Safety Management (29 CFR ) Following EPCRA several industry organizations and states started to review process safety within plants that use Highly Hazardous Chemicals. Agencies noted a lack of preparedness or proper prevention throughout h various industries i therefore OSHA developed d the PSM rule with input from various industries. The Final Rule published February 24, 1992 Chemical Facility Anti-Terrorism Standards (CFATS) Text The DHS s CFATS Program (6 CFR 27): DHS obtained authority under Patriot Act to develop security regulations at industrial sites, institutions, chemical facilities, utilities and refineries to ensure proper security and prevent/combat home-grown terrorism. Requires applicable facilities i to inventory chemicals and select facilities to perform Site Vulnerability Assessments and develop Site Security Plans. The rule promulgated April 9, 2007 Text Text

2 April 17, 2013 Explosion at The West Fertilizer Company 12 Volunteer Fire Fighters, 2 Members of the Public Injured 160, damaged or destroyed 150 buildings What Went Wrong At The West Fertilizer Company? CSB April 22, 2014 Failure to avert a preventable fire Inability of federal, state, and local regulatory agencies to identify a serious hazards and correct them No State and County Fire Code; No ERP under EPCRA due to retail sales exemption, no prohibition of storage in wooden buildings without sprinklers Facility cited under , but not strong enough (wooden bins allowed) Recommended Store less material at one time (270T present, about 5 Tons TNT) Use safer blends Store in fireproof concrete structures Tianjin, China Warehouse storage of chemicals from the Port, prior to distribution August 12, 2015 Fire, then Explosions 700 tons of sodium cyanide 800 tons of ammonium nitrate 500 tons of potassium nitrate. Calcium carbide (plus water = acetylene gas). Used in PVV plastics 2 nd Blast 21 Tons of TNT 100 fatalities, dozens missing Directed the Federal Gov t to: Improve operational coordination with State, local, and tribal partners Enhance Federal Agency coordination and information sharing Modernize policies, regulations, and standards Work with stakeholders to identify best practices What government entities are involved? Department of Homeland Security (DHS) Local Emergency Planning Committees (LEPCs) Tribal Emergency Planning Committees (TEPCs) Environmental Protection Agency (EPA) Department of Transportation (DOT) Department of Labor (DOL) Federal Emergency Management Agency (FEMA) Chemical Safety Board (CSB) Alcohol, Tobacco, Firearms and Explosives (ATF) Occupational Safety and Health Administration (OSHA) Federal Interagency Working Group Formed EPA, DOL, DHS The Agencies determined the following actions need to be implemented to satisfy minimize risk: Strengthen community planning and preparedness; Enhance Federal operational coordination; Improve data management; Modernize policies and regulations; and Incorporate stakeholder feedback and develop best practices. 2

3 Strengthening community planning and preparedness: EPA/FEMA/DHS to provide Emergency Response Training and ensure proper coordination with LEPCs and TEPCs Training and outreach for LEPCs roles and responsibilities and interaction with facilities during emergency response Develop new tools for information management and storage for LEPCs EPA to update Computer-Aided Management of Emergency Operations (CAMEO) software Expand public outreach and information sharing around chemical facilities Enhancing Federal operational coordination: Implemented pilot program in NY/NJ to enhance coordination between Federal and state Agencies Agencies reviewing interagency procedures to streamline and identify areas of improvement Establish SOPs for Federal coordination Cross train Federal chemical facility safety and security personnel (focus on frequent or critical violations) Improving data management: Update and share EPA/DHS/OSHA databases to determine potential non-compliances EPA Region 8 developed Pilot Planner system that aggregates data and displays on GIS Develop cross agency identification system and single web-based interface for internal data collection Improve information tools for regulated chemicals Modernizing Policies and Regulations EPA/OSHA/DHS to review regulations and identify potential changes - promulgate during Fries issued OSHA Dec 2013, Closed March 2014 EPA July 2014, Closed October 2014 DHS conducted 100s of Audits during 2014 to determine if CFATS sites were in compliance EPA expanded inspector training to include advanced process safety training, engineering codes/standards, root cause analysis, and human error prevention EPA revised inspector guidance ensure employee representatives participate Build a stronger CFATS Program and develop better outreach programs Seek Congressional approval to strengthen CFATS and OSHA fines and penalties PSM/RMP/CFATS Updates Incorporating stakeholder feedback and developing best practices: Developed first Presidential Report by soliciting 1,800 participants i t across 25 states t for responses to intended d changes Developed online repository Conduct outreach throughout PSM Changes for Stakeholder Input Revised retail exemption (July 2015 Memo) List of covered chemicals Plan Content Proposed Changes Incident Review (historical and global) Use Recognized and Generally Accepted Good Engineering i Practices (RAGAGEP) More stringent mechanical integrity Better coordination Emergency Action Plan Enhanced employee involvement (increased awareness and indolentannual training vs. 3 years) Mandatory 3 rd party audits Further harmonizing with RMP (thresholds, elements) Periodic analysis of safer technology 3

4 PSM/RMP/CFATS Update PSM/RMP/CFATS Update RMP Changes for Stakeholder Input (Draft Rule 2016?) Include Mechanical integrity review of safety Systems Enhanced monitoring and Performance requirements for automated monitoring systems Conduct Root Cause Analysis for Process Incidents Implement Stop Work Procedure for threats of Real Damage Strengthen contractor safety Periodic analysis of safer technology Mandatory 3 rd party audits More frequent and reduced trigger for PHAs Enhanced Public Outreach Reduce off-site consequence thresholds (0.14mg/l to mg/l) CFATS (expect draft rule Winter 2015) Review list of Chemicals of Interest Additional review of previously submitted Top-Screen Analysis, Site Security Plans (SSP) and Site Vulnerability Assessment (SVA) Identify facilities that should have submitted a CFATS Top-Screen but failed to do so Develop enforcement actions for program What Do Existing Plans Need to Do? New Plans Ensure PSI is up to date Gather process design codes and standards and compare to current industry standards Review incidents (onsite and industry) and if they could occur onsite Gather/document process utilities and safety systems Start to develop written Mechanical Integrity Procedures Review Safety Systems, Waste Gas Ducting Preventing Deficiencies in 4 Steps Understand Your Plan 1. Understand your plan 2. Ensure you have a good plan 3. Ensure you have the right people in the right positions 4. Review your plan often Read/Review the Plan Provide team member training on role and responsibilities Don t just do the 3-year training on the RMP/PSM regulation and the plan RMP/PSM plan is a living document Don t take short-cuts! Whatever you say in your plan is the gold standard! 4

5 Ensure You Have a Good Plan Incorporate Company Culture. A good plan will fit around existing procedures or adopt ones that are part of the company culture. Have multiple parties review plan (i.e. corporate, outside consultants, staff) Review what other businesses in your industry may have for a plan or what they do When you note the same deficiencies, not only should you correct them, but evaluate the cause, since it keeps coming up. Are the Right People in the Right Positions? IT TAKES A TEAM Who do you have assigned to do the following: SOPs (Annual Reviews, Creating the SOPs) Process Safety Information (i.e. drawings, mass & energy balances) Management of Change NIOSH Engineer Comment Delegate specific tasks: Mass Balance Process Design Engineers SOP Creation Production Managers and Production personnel Review Your Plan Often Other Tips & Tweaks The Plant or EHS Managers should be overseers not implementers Implement review system review plan sections on a monthly or quarterly basis Perform audits more than once every three years Practice: Run through likely Managements of Change Perform Pre-Startup Safety Reviews Consolidation of forms Use/modify existing forms Conduct regular RMP/PSM Plan Management Meetings Make separate binders Use RMP/PSM language in all safety trainings i and meetings Follow-up on Outstanding Items Review the Audits Questions & Answers THANK YOU. Jesse Zahn, CHMM Senior Project Engineer HRP Associates, Inc. 1 Fairchild Square, Suite 110 Clifton Park, NY jesse.zahn@hrpassociates.com Photograph Credits: china tianjin explosion ethnic games world war ii museum/ 5