Implementation Strategies for PSM RMP CalARP Regulatory Updates

Transcription

1 Implementation Strategies for PSM RMP CalARP Regulatory Updates Steven T. Maher, PE CSP Risk Management Professionals U.S. (877)

2 Key Topics Addressing Key Elements of Regulatory Expansion/ Modernization Efforts (with implementation tips) General Implementation Strategies & Resources Questions?

3 Addressing Key Elements of CalARP, CalPSM-R, & RMP Regulatory Expansion/Modernization Efforts (with Implementation Tips)

4 Types of Changes Facility/ Program Applicability Elements Schedule

5 PSM Elements Employee Participation EP Process Safety Information CA PSI Process Hazard Analysis EP&R PHA Operating Procedures Training II PSM OP Contractors Pre-Startup Safety Review Mechanical Integrity MOC TRN Hot Work Permit Management of Change HWP CON Incident Investigation MI PSSR Emergency Planning & Response Compliance Audits (CA-IIPP)

6 Impact Categories Following table follows Draft Regulation Table of Contents Three Main Categories * indicates minimal changes to regulation or minimal effort needed for compliance ** indicates moderate changes to regulation or moderate effort needed for compliance *** indicates new element or significant effort needed for compliance

7 CalPSM-R Elements Process Safety Information MOOC CA PSMP PSI PHA Process Hazard Analysis Operating Procedures Training HF OP Contractors Pre-Startup Safety Review Mechanical Integrity PSCA EP PSM-R TRN CON Damage Mechanism Review Hierarchy of Hazard Control Analysis (IST/HCA/STAA) Hot Work Management of Change Incident Investigation - RCA EP&R PSSR Emergency Planning & Response Employee Participation Process Safety Culture Assessment II-RCA MI Human Factors MOC HW IST/ HCA/ STAA DMR Management of Organizational Change Compliance Audits PSM Program

8 Current Cal/OSHA, CalARP, & RMP Initiatives Program Element CalPSM-R (Draft) CalARP (P4-Draft) EPA-RMP (P2/3-Draft) Process Safety Information (PSI) * (d) Process Hazard Analysis (PHA) * Safeguard Protection Analysis (SPA) ** (CA-Only) (e) /67 Operating Procedures (OP) ** (f) Training (TRN) * (g) Contractors (CON) * (h) Pre-Startup Safety Review (PSSR) * (i) Mechanical Integrity (MI) * Damage Mechanism Review (DMR) *** (CA-Only) 5189.(j) (k) IST / HCA / STAA *** (l) Hot Work (HW) * (m) Management of Change (MOC) ** (n) Incident Inv. Root Cause Analysis (II-RCA) ** (o) Emergency Planning and Response (EP&R) *** (p) / /96 Employee Participation (EP) * (q) Process Safety Culture Assessment (PSCA) *** (r) Human Factors (HF) *** (s) Management of Organizational Change (MOOC) *** (t) Compliance Audits (CA) ** (Fed Rqmt. for 3 rd Party) (u) /59/79/80 Process Safety Management Program (PSMP) ** (v,w)

9 PHA-Related & MI-Related Elements PHA MI IST/HCA/STAA SPA DMR

10 Process Hazard Analysis (PHA) (CalPSM-R (e), CalARP ) (b) All portions of the petroleum refinery are covered except laboratories and low-hazard utilities. PHA must address: DMRs and their recommendations HCAs and their recommendations External events Incident investigation findings The Iterative HCA Method must be applied for all PHA recommendations that result from a scenario that identifies the potential for a major incident.

11 PHA Requirements (continued) Recommendation closure process & timing clarified: Not requiring a process shutdown within 30 months Requiring a process shutdown next scheduled turnaround Potential for death/serious physical harm immediately PHAs must be retained for the life of the process. Includes recommendations and their documented resolutions All new (i.e., not previously required) PHAs must be completed within 3 years of CalARP/CalPSM-R promulgation.

12 Safeguard Protection Analysis (SPA) (CalPSM-R (e), CalARP ) Objectives: Assess the effectiveness of existing and combined safeguards for each failure scenario identified in the PHA Assure that safeguards are independent of the initiating event and each other Evaluate: Passive, Active, or Procedural Safeguards Using LOPA or equally effective method Risk reductions achieved by existing safeguards and safeguards recommended in a PHA must be documented. Conduct SPA and complete report within 6 months of finalizing a PHA. The SPA report can be standalone or part of PHA. SPA reports must be retained for the life of the process.

13 SPA Implementation Tips Challenges Blending Issues is Human Nature Common-Mode Failures Between Causes & Safeguards Over-crediting Operator Response Reliability Practical Implementation Guidance Identify Root Transmitters for Causes & Safeguards Facilitator to Frequently Train the Team on Risk- Ranking Facilitator to Frequently Challenge the Team on Safeguard Effectiveness, Availability, & Reliability Partition Safeguards as IPLs Typically Group Alarms as a Single Safeguard Apply Risk-Graph & LOPA to Provide Additional Insights Apply Risk-Graph & LOPA for High Consequence/Risk Scenarios to Validate that a SIF is Not Needed

14 SPA Implementation Tips More Tips Operator Response to Alarms Reliability & Timing Present to Hear the Alarm Alarm Prioritization & Diagnosis Permission for Corrective Action Initiating the Corrective Action Time for the Corrective Action to Mitigate the Event Actions Prior to CalARP & CalPSM-R Promulgation SPA is effectively addressed by implementation of best PHA practices. Implement best PHA practices.

15 Mechanical Integrity (MI) (CalPSM-R (j), CalARP ) No discontinuities with current industry best practices Minimal substantive changes Clear instructions for safely conducting maintenance activities to be included in Mechanical Integrity Procedures Additional specificity on required documentation Clarification of records retention Additional specificity on availability of Mechanical Integrity Procedures and inspection documents Additional cross-referencing to Process Safety Information Addition of references to RAGAGEP For CalARP, DMR is located in (f)

16 Damage Mechanism Review (DMR) (CalPSM-R (k), CalARP (f)) Damage Mechanisms mechanical, chemical, physical or other process that results in equipment or material degradation Damage Mechanism Review (DMR) Timing: Prior to any PHA and prior to changes affecting chemistry, metallurgy, or operating limits Initial to take place at the earliest of the following: Initial DMR within 5 years (50% within 3 years of CalARP/CalPSM-R promulgation) Revalidated every 5 years or prior to a major change Reviewed as part of an incident investigation

17 DMR Requirements (continued) At minimum, evaluate the following: Mechanical Loading Failure Ductile fracture, brittle fracture, buckling, mechanical fatigue Erosion Abrasive wear, adhesive wear, fretting Corrosion Uniform corrosion, localized corrosion, pitting Thermal-Related Failure Creep, thermal fatigue, transformation Cracking Stress-corrosion cracking Embrittlement High Temperature Hydrogen Attack (HTHA) DMR reports must be retained for the life of the process.

18 DMR Implementation Spectrum Enhanced Contemporary Best Practices Prioritized DMR Approach ipha MI-Centered Risk-Based Assessment Less Effort Increased Effort, with Increased Insights

19 DMR Implementation Tips Challenges Ensure Regulatory Requirements are Met Effective Use of Facility Resources Minimizing Overlap with Other SMS Program Elements Maximizing Use of Efforts Completed for Other SMS Elements

20 DMR Implementation Tips Suggested Approaches Maintain your current SMS HAZOP/MI activities. Initiate high-value DMR activities in the form of a Prioritized DMR. Apply quantitative risk techniques (e.g., API RP 581) selectively. Address high priority improvements and potential vulnerabilities. Initiate transition of SMS HAZOP/MI Program to maintain progress towards long-term DMR objectives. A Prioritized DMR is a minor increment to current PHA & MI efforts, is easily expanded, and is expected to satisfy DMR objectives. Suggested actions Prior to CalARP & CalPSM-R Promulgation Migrate towards Prioritized DMR. Evaluate need for more detailed analysis.

21 HCA (CalPSM-R (l), CalARP ) Hierarchy of Hazard Control Analysis (HCA) ranking of prevention and control measures prioritized as follows: 1 st Order Inherent Safety (e.g., safer chemicals) prevents incident 2 nd Order Inherent Safety (e.g., inventory reduction, lower temperature) reduces severity/likelihood of incident Independent Protection Layer (IPL) Safeguards (passive, active, or procedural) Conduct the HCA for: All existing processes (50% within 3 years and all within 5 years of CalARP/CalPSM-R promulgation), with a 5-year revalidation PHA recommendations addressing a major incident potential Major changes (as part of MOC) Major incidents New processes (including making the HCA available to the public) At the request of UPA

22 HCA Requirements (continued) Objective To reduce each risk to the greatest extent feasible, Owner/Operator shall identify and evaluate all relevant inherent safety measures, e.g.: Control techniques or management systems that have been achieved in practice for petroleum refining or related industrial sectors Control techniques or management systems that have been required or recommended for petroleum refining and related industrial sectors Approach Iterative HCA Method defined in (z) Outcome Employer shall select and recommend 1 st & 2 nd Order Inherent Safety Measures, unless documented as infeasible and the proposed alternatives are justified. Requirement for HCA to be a standalone analysis Report to be completed within 90 days of HCA completion

23 HCA Implementation Tips Effective Implementation Briefing During PHA Synchronization Training List of ISD Considerations in the PHA Quick Reference: Minimize Substitute Moderate Simplify More Robust Simplify Human Factors Simplify Facility Siting Document Inherently Safer Systems Review as Separate Node Checklist for ISS Review on and from CCPS Guidebook

24 HCA Implementation Tips Timing As Early As Possible During the Design Phase Minimize Capital Costs As Early As Possible During Plant Operation Minimize Costs by Addressing Needs during Unit Turnarounds Actions Prior to CalARP & CalPSM-R Promulgation Apply ISS checklists during PHA. Ensure that technological advances are discussed/considered during PHA. Ensure that use of different metallurgy is considered during Prioritized DMR.

25 HCA Implementation References Textbooks CCPS Guidelines for Risk Based Process Safety Inherently Safer Chemical Processes: A Life Cycle Approach Process Plants: A Handbook for Inherently Safer Design CCPS Guidelines for Engineering Design for Process Safety Regulatory Guidance/Requirements Contra Costa County HSD NJ Toxic Catastrophe Prevention Act (TCPA) Checklists Available Within Textbooks & Regulatory Guidance Documents

26 Incident Investigation (CalPSM-R (o), CalARP ) Incident Investigation Root Cause Analysis Implement an effective Root Cause Analysis (RCA) Team must include a person with RCA expertise and oversight Team must investigate underlying management system causes (including organizational and safety culture) Review results of HCA and DMR as part of II Conduct DMR, PHA, HCA, and SPA (demonstrate if an analysis is not applicable) Developing recommendations conduct DMR, PHA, HCA, and SPA. Recommendations have same implementation requirements as PHA. Timelines: Assemble Team within 48 hours Initial Report within 90 days Final Report within 6 months

27 Process Safety Culture Assessment (PSCA) (CalPSM-R (r), CalARP ) PSCA Program should address: Encouragement for reporting safety concerns Rewards do not deter reporting safety concerns Ensure safety is not compromised by production Process Safety Leadership at all levels Human Factors Program to be included for all PSM elements Written PSCA Program should include: Methods used to assess PSC Conclusions from the PSCA Rationale of the conclusions Recommendations and action plan from PSCA Report to be completed within 90 days of PSCA end Signed off by refinery manager

28 Management of Organizational Change (CalPSM-R (t), CalARP (i)) Include MOOC assessment to address: Experience levels of employees before and after the proposed change Describe the change, team make-up, team rationale, and actions required to make the change Ensure job functions are up-to-date and accurate for all affected positions Document the following: Results of analysis Team make up What factors were considered Decision to implement the change or not Basis for decision Necessary actions required to move forward with the change Shall include Human Factors analysis Employees potentially affected by change shall be given information prior to implementation

29 Human Factors (CalPSM-R (s), CalARP ) Develop, implement & maintain written program Program should evaluate: Staffing levels Complexity of and length of time needed to complete tasks Level of training and expertise of employees Human-machine interface and human-system interface Physical challenges of the work environment Employee fatigue and shiftwork/overtime Communications Understandability and clarity of SOPs and Maintenance Procedures Analysis of human factor controls on process equipment in incident investigation, PHAs, MOOCs, SPA, or HCAs (e.g., error proof mechanisms, automatic alerts, automatic system shutdowns for critical operational errors)

30 Human Factors (continued) Assess human factors in new SOPs and maintenance procedures Assess human factors in existing SOPs and maintenance procedures Revise procedures accordingly 50% assessment complete within 2 years (following effective date of regulation) 100% assessment complete within 3 years (following effective date of regulation) Provide training to operations and maintenance personnel Ensure employee/representation in the development, implementation, and maintenance of the Human Factors Program

31 New Regulatory Updates From OSHA Interpretation Letters (June-July 2015): RAGAGEP Enforcement Guidance on how to document RAGAGEP Retail Exemption If the facility does not fall under SIC 44 or 45, it is not eligible for the exemption Enforcement begins mid-july 2016 (12 months) Covered Concentration Uses EPA s 1% policy, rather than commercial grade Other Enforcement/Interpretation Letters are reported to follow

32 New Regulatory Updates From California: SB-612: UPA General Duty Clause New mapping requirements Other changes to UPA Programs for UST/AST, SPCC, hazardous waste t.xhtml?bill_id= sb612

33 General Implementation Strategies & Resources

34 Key Modernization Activities (Onshore Facilities) CSB CalOES/CalEPA IRTF EPA CCC & CoR OSHA Cal/OSHA CalOES: California Office of Emergency Services; Cal/OSHA: California Occupational Safety & Health Administration; CSB: Chemical Safety Board; EPA: United States Environmental Protection Agency; IRTF: Interagency Refinery Task Force; OSHA: U.S. Occupational Safety & Health Administration; CalEPA: California Environmental Protection Agency; CCC: Contra Costa County; CoR: City of Richmond

35 Status and What to Expect Chemical Safety Board (CSB) April 2013, October 2014, January 2015 All 3 Investigation Reports Published Investigation Completed, Recommendations Tracked U.S. EPA 14Mar16 Proposed Rule Making for RMP Updates Published 13May16 Deadline for Comments Final Regulation Promulgation Estimated Summer 2017 Federal OSHA RFI Comments to be Processed Draft Regulations to be Generated Timeline Years, not Months Small Business Regulatory Flexibility Review Act

36 Status and What to Expect Contra Costa County & City of Richmond June 2014 Issued ISO ( Risk Management ) & Analogous CoR ISO Current Initiative to Increase Involvement of Community Oversight Group in Process Safety Culture Assessments California Interagency Refinery Task Force (IRTF) Agency Meetings Continue Additional Reports Not Planned Cal/OSHA CalPSM-R 24Sep15 Updated Draft Issued Final Regulation Promulgation Estimated Spring 2017 Initially, 2 Separate PSM Regulations in California Initially, No Planned Synchronization w/federal PSM/RMP

37 Status and What to Expect CalEPA & CalOES CalARP 01Jan15 Promulgation of Minor Update to CalARP 24Sep15 Draft of Additional Update to Align with Draft Final Regulation Promulgation Estimated Spring 2017 Single CalARP Regulation with Additional Requirements (Program 4) for High Hazard Facilities (NAICS 32411) Initially, Harmonization with , but No Synchronization w/federal PSM/RMP

38 Overlap of Key Current CA SMS Programs (Onshore Facilities) PSM CalARP/RMP M i n i m a l PSI EP MI CON MOC PHA CA TRN II PSSR HWP OP EPR HA

39 Overlap of Post-2016 CA SMS Programs (Onshore Petroleum Refineries) Fed-RMP Post 2016 CalPSM-R (5189.1) PSI OP EP CA-1 TRN EPR Schedule & Other Minor Differences HF IST/HCA/STAA HW CON II-RCA PSSR CA-3 EPR HA MOC --- MOOC MI --- DMR PHA --- SPA PSCA Schedule & Other Minor Differences PSMP EPR CalARP

40 What Should I be Doing Now? All California CalARP-Covered Facilities Adherence to New 01Jan15 CalARP Requirements Contra Costa County & City of Richmond 9 Facilities Adherence to June 2014 CCC ISO & Analogous CoR ISO California Petroleum Refineries Recommendation from a Key Regulator Begin Applying High-Value/Priority Elements of CalPSM-R & New CalARP Now Once promulgated, schedules will be tight, and if substantial progress has been made addressing the spirit of the new requirements, selective- grandfathering may be allowed. Tight schedules could result in a shortage of qualified resources. Some elements (e.g., IST/HCA/STAA) are significantly more cost-effective in the design-phase, or at the earliest possible opportunity.

41 What Should I be Doing Now? U.S. PSM/RMP-Covered Petroleum Processing Facilities Awareness of CalPSM-R for Best Practices for High Hazard Facilities All Closely Monitor Regulatory Changes Potential For Later expansion to other highly-hazardous facilities in California Later expansion to non-california petroleum refineries & others Inference to new requirements as best practice General Duty Clause Correlation - SB 612 clarifies Owner/Operator responsibilities.

42 Resources for Handling Evolving Requirements HAZOP/LOPA Facilitation Webinar Series (Module 10) Effective approaches to handling CSB recommendations and PSM and CalARP changes DMR SPA Inherently Safer Technology/Design (i.e., IST/HCA/STAA) 2015 Global Congress on Process Safety Papers Maher, Nour, Schultz, Effectively Addressing New PSM/RMP Damage Mechanism Review Requirements with an Integrated PHA (ipha) 2016 Global Congress on Process Safety Papers Maher, Metulev, PSM/RMP Modernization Programs in California New Developments & Correlation to Evolution at the Federal Level Webinars Updates on the PSM/RMP Regulatory Modernization Programs 19Aug14 25Sep14 22Jan15 09Apr15 25Jun15 30Jul15 27Aug15 29Oct15 Regional Seminar Simulcast as Webinar Webinar DMR and the Integrated PHA (ipha) Approach 26Mar15 & 27Aug15 (w/simpifications) Links are provided on

43 Summary & Conclusion Agencies have taken a fresh look at SMS Programs. California and Refineries have biggest changes. Potential For: Expansion Link to General Duty Clause & Best Practices Initial promulgation will not be synchronized with federal requirements, but plan to harmonize CalARP & CalPSM-R. Potential for long-term movement towards synchronization. There are easy steps to take now to infuse some of the new requirements into your PSM/RMP/CalARP activities.

44 Summary & Conclusion Recommendation from a Key Regulator Begin Applying High-Value/Priority Elements of CalPSM-R Now Once promulgated, schedule will be tight, and if substantial progress has been made, selective- grandfathering may be allowed. Tight schedules could result in a resource shortage. In addition, some elements (e.g., IST/HCA/STAA) are significantly more cost-effective in the design-phase, or at the earliest possible opportunity. Risk Management & Process Safety Professionals should: Carefully monitor modernization programs. Focus on charting the course for the long-term success of your facility s programs. Develop a strategy for effective implementation.

45 Questions? Steven T. Maher, PE CSP (949) (877)