CalARP Formal Evaluation Review


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CalARP FormalEvaluation Review
Presented By Beronia Beniamine Stanislaus
County Senior Hazardous Material Specialist
Greg Taylor Foster Farms Corp. PSM Specialist
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GENERAL CalARP REGUIREMENTS

• Process Applicability
• Management System
• Registration Information
• Qualified Person Certification
• Recordkeeping
• Hazard Assessment
• Emergency Response
• Program2/3 Requirements
• Updates

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Management System

• Does the facility have a CalARP/RMP management
  system
• Has a qualified person/position been assigned the
  responsibility for CalARP/RMP compliance
• Can the facility demonstrate that there is not a
  conflict of interest in their management program
  (e.g. is the person responsible for the programs
  also responsible for minimizing costs)

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Registration Information

• Are items (a-u) section 2740.1 of the CCR
  identified Please refer to the Formal Evaluation
  Checklist it includes all the June 24 2004
  changes.
• We have handouts with the Formal Evaluation
  Checklist that you can pick up at the end of our
  presentation.

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HAZARD ASSESSMENT

• Offsite Consequence Analysis Parameters
• Worst-Case Release Scenario Analysis
• Alternative Release Scenario Analysis
• Defining Offsite Impacts to the Population
• Defining Offsite Impacts to the Environment
• Offsite Consequence Analysis Review and Update
• Offsite Consequence Analysis Documentation
• Five-Year Accident History

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Offsite Consequence Analysis

• Was the analysis performed by qualified people
• Are the technical assumptions credible
• Was the source of the population estimate data
  identified
• Was the model used valid for the type of
  material
• Was the initiating event for the scenario derived
  from a valid resource (e.g. PHA/HR accident
  history industry evidence etc.)
• Does the analysis describe the impacts on local
  population and the environment
• Will any safeguards claimed withstand the event
  and still function

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Offsite Consequence Analysis

• Do the system operators know what will happen if
  a worst case scenario takes place
• Is the worst case scenario up to date (within 5
  years or within 6 months of a major change)
• Do the system operators know what will happen if
  an alternative case scenario takes place
• Is the alternative case scenario up to date
  (within 5 years or within 6 months of a major
  change)

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Emergency Response

• Emergency Response Applicability
• Emergency Action Plan
• Owner or operator whose employees will not
  respond to accidental releases of regulated
  substances need to meet the following
• Coordinate with community plan
• Coordinate with fire agencies for flammables.
• Procedures for notifying emergency responders.

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Emergency Response Program

• Emergency response program shall include the
  following
• Emergency Response/Action Plan
• Procedures for informing/interfacing
  w/agencies/public
• Documentation of first aid/medical monitoring
  treatment
• Post incident response procedures
• Procedures for equipment use inspection
  testing maintenance.
• Training in Incident Command System.
• Procedures in place to review and update plan
• Coordination w/community emergency response plan.
  

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Emergency Response Program

• If employees are involved in emergency response
  does the plan address the following
• Emergency recognition
• Safe distances and places of refuge
• Site security and control
• Are event specific plans (e.g. IAP and SSP)
  developed prior to entry into IDLH environments
  per CCR Title 8 Section 5192 requirements.
• Etc

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Sample Site Safety Plan (SSP)
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See Next!
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SOPs Refer to Example On Next!
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PROGRAM 3 REQUIREMENTS

• Executive Summary
• Process Safety Information
• Process Hazard Analysis
• Operating Procedures
• Training
• Mechanical Integrity
• Management of Change
• Pre-Startup Review

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PROGRAM 3 REQUIREMENTS

• Compliance Audits
• Incident Investigation
• Employee Participation
• Hot Work Permit
• Contractors

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What Process Safety Information Is Required

• Block flow diagram or simplified process flow
  diagram
• Process chemistry (e.g. M.S.D.S.)
• Maximum intended inventory
• Safe upper / lower limits - temp pressures
  flows compositions etc.
• Evaluation of the consequences of deviation (from
  the safe upper / lower limits)

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What Process Safety Information Is Required
(Cont.)

• Information on equipment used in the process
• Materials of construction (e.g. ASME certified
  vessels) documented
• Piping and instrument diagrams (PIDs current
  accurate)
• Electrical classification documented
• Relief system design and design basis documented
  
• Ventilation system design documented
• Design codes and standards employed to construct
  the process must be documented
• Safety systems (e.g. detection) documented
• Documented Safe upper / lower limits such as
  temp pressures flows compositions etc.

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What Process Safety Information Is Required
(Cont.)

• Documentation showing equipment complies with
  recognized engineering practices
• Or documentation showing existing equipment is
  designed maintained inspected tested and
  operated in safe manner

Should a Process Hazard Analysis or Hazard Review
be accepted if the Process Safety Information was
unavailable or inaccurate
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What Should the Process Hazard Analysis Address

• Hazards of process
• Previous incidents (not just reportable releases)
  with the potential for accidents including near
  misses
• Engineering and administrative controls
• Consequences of failure of engineering and
  administrative controls including safe operating
  limits
• Stationary source sitting
• Human factors
• Qualitative evaluation of health and safety
  effects of failure of controls

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What Should the Process Hazard Analysis Address
(Cont.)

• External events
• Were external events such as fires floods
  earthquakes transportation accidents extreme
  wind or tornadoes fog and extreme temperatures
  discussed
• Were external events such as site security
  related to sabotage terrorism and theft
  discussed
• Were external events such as site security
  related to the potential for adjacent facilities
  or systems to impact the process discussed
• Did the PHA and or Re-validation address
  procedural steps where appropriate (e.g. hot gas
  defrost cycle on an ammonia evaporator)
• Was PHA performed by a knowledgeable team

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What Follow Up Is Required for Process Hazard
Analysis Recommendations

• Is a system established to promptly address
  findings and recommendations
• Is there a written schedule of when these actions
  are to be completed
• Have the recommendations been resolved in a
  timely manner
• Are the resolutions documented
• Have actions been completed as soon as possible
• Has PHA or Hazard Review been done for major
  changes or additions to the process
• Has PHA been re-validated at least every 5-years

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Process Hazard Analysis Recommendation Withdrawal

• Employer can justifiably decline to adopt a
  recommendation where the employer can document
  in writing and based upon adequate evidence that
  one or more of the following conditions are true
• analysis contains material factual errors
• recommendation is not necessary to protect health
  safety of employees owner and/or contractors
• an alternative measure would provide sufficient
  level of protection or
• recommendation is infeasible.

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Operating Procedures

• Initial startup
• Normal Operations
• Temporary operations
• Emergency shutdown
• Emergency operations
• Normal shutdown
• Startup following a turnaround or after emergency
  shutdown

Which SOPs reasonably apply to most processes
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What Other Operating Procedures Must a Facility
Have

• Written operating procedures which address
• Deviation from Normal Operating limits
• Consequences of deviation
• Steps required to correct or avoid deviation
• Regular review/annual certification of operating
  procedures
• Is a periodic review of written prevention
  programs such as EAP/ERP MOC PM Program
  Incident Investigation Contractor Safety
  Programs done

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What Safe Work Practices Should The Facility Have
In Place

• Hot Work Permit Program
• Lockout/Tagout program
• Opening Process Equipment Program (i.e. Line
  Break Permit)
• Confined Space Permit and Rescue Programs
• Medical Surveillance Program (respiratory
  protection program) and
• HazCom Program.
• Written evaluations and training records.
• Proper maintenance of emergency response
  equipment.

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What Training Is Required

• Is refresher training provided at least every
  three years and more often if necessary
• Are employees consulted with concerning the
  frequency and need for refresher training
• Documented training on SOPs maintenance
  procedures operating limits safety systems
  hazards emergency procedures safe work
  practices etc.
• Is the same level of training provided to an
  employee prior to a new job assignment
• Is training provided to contractors who maintain
  or operate the system or process

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What Training Documentation Is Required

• Does training documentation include
• Documentation that employee received and
  understood training
• Identity of employee
• Date training occurred
• Means used to verify employee training (e.g.
  testing observation demonstration etc.)
  comprehension

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What Should Be Included In A Mechanical Integrity
Program

• Written procedures to maintain the on-going
  integrity of ALL process equipment
• Planned (preventive predictive and proactive
  but not reactive) and corrective maintenance
  procedures
• Training for process maintenance activities
• Inspection and testing of process equipment
• Prompt correction of equipment deficiencies
• Quality assurance (e.g. appropriate checks and
  inspections performed according to manufacturers
  recommendations suitable spare parts
  available).

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What Documentation Should Be Included In The
Mechanical Integrity Program

• Is the program documented
• Including the date of each inspection or test
• The name of the person who performed the
  inspection or test
• The serial number or other identifier of the
  equipment on which the inspection or test was
  performed
• A description of the inspection or test
  performed
• The results of the inspection or test and
• Actions taken to correct deficiencies.

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Mechanical Integrity Program

• Do the written testing and inspection procedures
  follow recognized and generally accepted good
  engineering practices including but not limited
  to
• Appropriate frequencies for testing and
  inspection of process equipment (e.g. API IIAR
  NFPA ANSI ASME etc guidelines or
  manufactures recommendations)
• Criteria for acceptable test results
• Methods to analyze inspection and testing results
  to assure that equipment deficiencies are
  corrected when outside acceptable limits.

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Mechanical Integrity Program (Cont.)

• Is data collected and documented during normal
  daily walk around including but not limited to
• Liquid levels in all vessels
• Inspections of equipment and tasks to be
  performed such as defrosting evaporators
• Instrument readings such and operating conditions
  (e.g. temperature pressure flow level etc.)
  and
• System upsets including operating outside normal
  operating limits and what corrective actions were
  taken.

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Mechanical Integrity Program (Cont.)

• Are Equipment Deficiencies discovered during
  routine maintenance and daily walk around
  corrected
• The employer shall correct deficiencies in
  equipment which are outside acceptable limits
  defined by the process safety information or
  manufacturers recommendations before further use
  or in a safe and timely manner provided means are
  taken to assure safe operations.

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Management of Change and What Is Considered
Change

• Change - Any modification which affects the
  capability of a process to maintain control of
  the physical and chemical transformations taking
  place including all modifications to equipment
  procedures raw materials and processing
  conditions other than replacement-in-kind.
• For example (this list is not to be considered
  all inclusive)
• Substitution of a material of construction with a
  different material. For example a process vessel
  and/or section of piping is designed with black
  carbon steel. Replacement of a section of the
  equipment with stainless steel would constitute a
  change.
• Replacement of a vessel with one of a different
  pressure rating.
• Replacing a gasket with one of a different
  material.

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Management of Change and What Should Be
Documented

• Is the technical basis for ALL proposed changes
  such as but not necessarily limited to the
  reasons for performing the work desired results
  technical design and appropriate implementation
  instructions documented including but not limited
  to
• Changes in process safety information being
  updated prior to any change
• Changes in operating procedures or practices
  being updated prior to change being put into
  service
• Training completed prior to startup of the
  changed process
• Maintenance routines developed prior to change
  being put in to service

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Compliance Audits and What Should Be Documented

• Are compliance audits conducted at least every
  3-years
• Are audits conducted by at least one qualified
  person knowledgeable in the process
• Is a system established to promptly address
  findings and recommendations
• Is there a written schedule of when these actions
  are to be completed
• Have the recommendations been resolved in a
  timely manner

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Compliance Audits and What Should Be Documented
(Cont.)

• Are the two most recent audits and audit
  responses available for review
• Did the audit adequately address previous
  Compliance Audit PHA and Independent Audit
  recommendations that have not been corrected or
  resolved
• Have actions been completed as soon as possible
• Are actions to be taken and their status
  communicated to employees

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Incident Investigations and What Should Be
Documented

• Is each incident which resulted in or could
  reasonably have resulted in a catastrophic
  release of a highly hazardous chemical (including
  near-misses and minor releases) investigated
• Are near-misses such as excursion of process
  operating parameters damaged piping and
  corrosion investigated
• Are incident report findings and recommendations
  promptly addressed and resolved
• Did a contractor employee if the incident
  involved work of a contractor participate in the
  investigation
• Was a system established to prevent a
  reoccurrence
• Are incidents reports retained for at least five
  years

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Contractor Safety Program and What Should Be
Documented

• Does the program include all contractors who work
  on or adjacent to covered process(s)
• Have contract employers safety performance and
  programs been evaluated and documented
• Is the entrance presence and exit of
  contractors and contract employees controlled
• Have contract employees been periodically
  audited
• Been properly trained in and utilizing safe work
  practices
• Know potential fire explosion or toxic release
  hazards and applicable provisions of the plants
  emergency action/response plan

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Contractor Safety Program and What Should Be
Documented

• Contractor notified of fire explosion and
  release hazards at facility
• Contractor performance periodically evaluated
• Contractor provided training for their employees
  
• Contractor informs their employees of the hazards
  and emergency response plan at the facility
• Contractor advised facility of hazards presented
  by contract work
• Contractor advised facility of any hazards found
• Contractor assured facility that employees
  followed its safety rules

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CalARP/RMP Program Updates

• Within five years of its initial submission or
  most recent update whichever is later.
• No later than three years after a newly regulated
  substance is first listed by USEPA or OES.
• No later than the date on which a new regulated
  substance is first present in an already covered
  process.
• No later than the date on which a regulated
  substance is first present above a threshold
  quantity in a new process.
• Within 30 days of change in emergency contact
  information.
• Within 6 months of a reportable release.

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CalARP/RMP Program Updates (Cont.)

• Within 6 months of a change that requires a
  revised PHA or hazard review
• Within 6 months of a change that requires a
  revised offsite consequence analysis.
• Within 6 months of a change that alters the
  Program level that applies to any covered
  process.
• Within 6 months of a change that alters the
  Program level that applies to any covered
  process.

What are some examples of changes that would
require a revised Process Hazard Analysis or
Offsite Consequence Analysis