CalARP Formal Evaluation Review

1. CalARP FormalEvaluation Review Presented By: Beronia Beniamine, Stanislaus County, Senior Hazardous Material Specialist & Greg Taylor, Foster Farms, Corp. PSM Specialist

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

3. 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)?

4. 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.

5. 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

6. 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?

7. 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)?

12. 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.

13. 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.

14. 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…

16. Sample Site Safety Plan(SSP)

19. See Next Slide!

21. SOP’s Refer to Example On Next Slide!

23. PROGRAM 3 REQUIREMENTS • Executive Summary • Process Safety Information • Process Hazard Analysis • Operating Procedures • Training • Mechanical Integrity • Management of Change • Pre-Startup Review

24. PROGRAM 3 REQUIREMENTS • Compliance Audits • Incident Investigation • Employee Participation • Hot Work Permit • Contractors

25. 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)?

26. 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 (P&ID’s 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.

27. 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?

28. 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,

29. 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?

30. 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?

31. 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.

32. 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?

33. 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?

34. 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.

35. 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?

36. 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?

37. 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 manufacturer’s recommendations, & suitable spare parts available).

38. 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.

39. 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 manufacture's recommendations), • Criteria for acceptable test results, • Methods to analyze inspection and testing results to assure that equipment deficiencies are corrected when outside acceptable limits.

40. 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.

41. 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.

42. 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.

43. Management of Change and What Should Be Documented? • Is the technical basis for ALL proposed changes, such asbut 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?

44. 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?

45. 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?

46. 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?

47. 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

48. 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?

49. 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.

50. 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?