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Process Hazard Analysis Revalidations Requirements & Purpose What are the requirements? Revalidate and update the Process Hazard Analysis at least every five years after its initial or previous completion. Revalidation to be performed by a qualified team. What’s the purpose? Comply with the OSHA PSM [29 CFR (e)(6)] and EPA RMP [40 CFR 68.67(f)] regulations. Ensure that the PHA is consistent with the current process.

Process Hazard Analysis Revalidations Philosophy – To Re-do or Read Through? How should I decide? Thoroughness of the initial or previous PHA Did we re-do or read through five years ago? Who was present in the previous PHA? Changes to the process in the last five years – significant or minor?

Process Hazard Analysis Revalidations Philosophy – To Re-do or Read Through? OSHA Letter of Interpretation (June 28, 2998): “Employers must establish the scope and extent of their PHA updates and revalidations to include at least the following: evaluations of existing PHAs for accuracy and completeness using the criteria set forth in (e)(3); checks to ensure that modifications to processes since the last PHAs have gone through management of change procedures or PHAs when required and that those changes are reflected in the PHAs; an evaluation of process safety information (PSI) to ensure that it is complete, current and accurate; verifications to ensure PHA specified procedures are adequate, up-to-date and are being implemented; determinations that existing PHA recommendations have been documented in their required respective areas such as PSI, PHAs, and procedures (operating, mechanical integrity, emergency response, etc.) and have been implemented; a review of all incident investigation reports required by (m) to assure all affected PSI, procedures, training, etc., have been updated to reflect recommendations set forth in the subject reports and that appropriate information from those reports have been incorporated into the PHAs. Finally, OSHA intends that the PHA update and revalidation be documented.”

Process Hazard Analysis Revalidations Preparing for the PHA - Summary Review implementation status of previous PHA recommendations. Verify accuracy of PSI: – Piping diagrams – Normal operating conditions – Safety systems List any changes to the process in the last five years (i.e., MOC review). Review five year accident history / incident investigation records. Ensure SOPs are current.

Process Hazard Analysis Revalidations Preparing for the PHA – RAGAGEP Define recognized and generally accepted good engineering practices (RAGAGEPs) used to design, operate, and maintain your process. Mechanical, Fire, and Building Codes Standards – ANSI/ASHRAE 15, ANSI/IIAR 2 Guidelines – IIAR Bulletins Manufacturer’s Recommendations

Process Hazard Analysis Revalidations Preparing for the PHA – RAGAGEP IIAR Bulletin 109 – Safety System Inspections IIAR Bulletin 110 – Maintenance Schedules IIAR Bulletin 111 – Ventilation Design and Maintenance IIAR Bulletin 114 – Labeling ANSI / ASHRAE Standard 15 – Ammonia Relief Discharge Locations ANSI/IIAR 2 – Ammonia Sensor Settings and Actions ANSI/IIAR 2 – E Stop Locations EPA Ammonia Refrigeration System Alert Bulletin

The PHA methodology must be “appropriate to determine and evaluate the hazards of the process being analyzed.” [40 CFR 68.67(b) & 29 CFR (e)(2)] What If Analysis Develop “what if” questions around equipment failures, process upsets, and human factor issues. Hazard and Operability Study (HAZOP) Use of Guidewords to identify deviations from the design intention. Checklists Process Hazard Analysis Revalidations Preparing for the PHA – Selecting the PHA Methodology

Process Hazard Analysis Revalidations Preparing for the PHA – Who’s on your team? “The PHA shall be performed by a team with expertise in engineering and process operations, with at least one employee who has experience and knowledge specific to the process being analyzed. Also, one member of the team must be knowledgeable in the specific PHA methodology being used.” [40 CFR 68.67(d) & 29 CFR (e)(4)] Design Engineers Operations and Maintenance Personnel Refrigeration Contractor Safety / Environmental Management PHA Leader & Recorder Regulatory Representative

Process Hazard Analysis Revalidations Performing the PHA Identify hazards associated with the process using selected methodology. Determine causes and consequences of each potential hazard. Discuss any incidents that have occurred at your facility in relation to each potential hazard. Identify the administrative and engineering safeguards associated with each potential hazard. Determine risk ranking for each hazard discussed. Postulate mitigation measures to reduce the consequences and/or likelihood of each potential hazard.

Process Hazard Analysis Revalidations Performing the PHA HAZOP Guide Words No Flow Reverse Flow More Flow Less Flow More Level Less Level More Pressure Less Pressure More Temperature Less Temperature More Viscosity Less Viscosity Agitation Composition Change Contamination Relief Instrumentation Sampling Corrosion/Erosion/Materials of Construction Service Failure Abnormal Operation Maintenance Ignition Spare Equipment Safety

Process Hazard Analysis Revalidations Performing the PHA Risk Ranking Qualitative Definitions of Probability of Occurrence of an Accident (Frequency Ranking) AFrequent0 to 1 years More than once per year BPeriodicalEvery 1 to 10 years At Least once each decade COccasionalEvery 10 to 100 years Probably during the life of the plant DPossibleEvery 100 to 10,000 years Not expected at this plant, but could occur EImprobableNot for 10,000 or more years Not expected or likely to occur at all

Process Hazard Analysis Revalidations Performing the PHA Risk Ranking Qualitative Definitions of Severity of Consequences to People During an Accident (Criticality Ranking) ICatastrophicResults in death (or damage and production losses > $1,000,000) IISevereResults in multiple injuries (or losses between $100,000 and $1,000,000) IIIModerateResults in a single injury (or losses between $10,000 and $100,000) IVSlightResults in operational problems only (or losses <$10,000)

Process Hazard Analysis Revalidations Performing the PHA Consequences Frequency A: Frequent B: Periodical C: Occasional D: Possible E: Improbable I: Catastrophic II: Severe III: Moderate IV: Slight RISK MATRIX RISK CODE 1 - Critical 2 - Undesirable 3 - Acceptable with controls 4 - Acceptable

RISK MATRIX Risk Code: 1: CriticalMust be improved Mitigate within six months with administrative or engineering controls (to reduce the risk code to 3 or more) 2: Undesirable Should be improved Mitigate within one year with administrative or engineering controls (to reduce the risk code to 3 or more) 3: AcceptableWith Controls Verify need for engineering controls, or that administrative controls are in place for hazard 4: Acceptable No mitigating action required for identified hazard Process Hazard Analysis Revalidations Performing the PHA

DeviationCausesConsequencesCSafeguardsFRRecommendations / Comments Design Notes No Flow Less Flow More Flow Reverse Flow More Level Less Level More Pressure Less Pressure More Temperature Less Temperature Viscosity Agitation Project Title:Project No:Date: P&ID Title:Drawing No:HAZOP Session: Drawing Revision No:HAZOP Leader: Process Description: Node A:

Process Hazard Analysis Revalidations Performing the PHA

Ensure the previous PHA adequately satisfied the requirements of a PHA: Previous incidents Safeguards and the consequences of the safeguard failing. Engineering and administrative control relationships. Facility Siting Engine Room exhaust vs. Ventilation Intake Roof Hazards Access to Eyewash / Safety Showers Human Factors Qualitative Assessment of Frequency and Consequences

Process Hazard Analysis Revalidations Recommendation Tracking Develop a written schedule for completing action items. Assign responsibilities. Meet periodically to review status of recommendations and ensure progress is being made. Document recommendation review meetings and actions taken to implement recommendations. Maintain evidence that shows progress or completion of action items. Review status/outcomes with operating, maintenance, and any other persons who are affected by the recommendations.

Process Hazard Analysis Revalidations Documentation All Process Hazard Analysis Study reports must be maintained for the life of the process. – Including recommendation resolution. – Sign In Sheets. – Piping Diagrams from the date of the study. – Team Leader Qualifications. – Methodology. – Regulatory Invites as applicable.

Process Hazard Analysis Revalidations What Can Be Learned… Safety improvements. Operability improvements. Operator “wish list”. Engineering and administrative controls in place for handling releases or potential releases. Clarify emergency response / action procedures. Operator training program. Alternative Release Scenarios.