Document M4kD9dYK84bDLrYzbbpx5jnk9

ASSESSMENT REPORT PROCESS SAFETY MANAGEMENT OF HIGHLY HAZARDOUS CHEMICALS 29 CFR 1910.119 FOR LOUISVILLE PVC FACILITLY LOUISVILLE, KENTUCKY Auditor Thomas M. Jones DECEMBER 12 THROUGH 16, 1994 Prepared By T. Michael Jones & Associates P. O. Box 890482 Houston, Texas NGC 12802 PROCESS SAFETY MANAGEMENT ASSESSMENT Louisville PVC Facility DECEMBER 12 THROUGH 16, 1994 The purpose for conducting this review was to audit the requirements of OSHA's 1910.119 Process Safety Management of Highly Hazardous Chemicals standard respective to the implementation status at the Louisville facility. Through this process, opportunities for improvement and recognition of exceptional safety systems already implemented to address the PSM standard would be achieved. An assessment of the implementation status for each element of the 1910.119 standard is included in this document. The implementation status corresponds to the following classification and is based on findings during the assessment process. Stage I: No action Stage II: Evaluating plant practices against system requirements Stage III: Developing plans to implement system requirements Stage IV: Implementing action plans Stage V: System in place Stage VI: Improvement reviewed and reaffirmed this year A narrative summary for each element of the process safety management standard is included in order to provide a rationale for the status of each element. The GEON Company and the Louisville PVC Facility were extremely cooperative during this assessment process. NGC 12803 Process Safety Management Assessment Louisville PVC Facility Page 2 I PROCESS SAFETY MANAGEMENT | Facility: Review Date: Reviewer: LOUISVILLE PVC FACILITY December 12 through 16, 1994 T, Michael Jones_______________ PSM ELEMENT Application Employee Participation Process Safety Information Process Hazard Analysis Operating Procedures Training Contractors Pre Start-Up Safety Review Mechanical Integrity Hot Work Permit Management of Change Incident Investigation Emergency Planning/Response Compliance Audit Trade Secret IMPLEMENTATION STATUS I II III IV V VI X X X X X X X X X X X X X X X NA EVAL DEV IMP IN REAFFIR PLC TMJ-JAN.1994 "Safety - A Continuous improvement Process" NGC 12804 Process Safety Management Assessment Louisville PVC Facility Page 3 PROCESS SAFETY MANAGEMENT ASSESSMENT SUMMARY Appucation: 1910.119(a) It is important for a facility to determine the extent to which it has identified PSM risks and characterized what it needs to do and know in order to manage these risks. Documented action of this activity is often times not properly achieved. The outcome of this documentation effort should include, 1) the method used to determine which processes are included in the PSM program at the facility or portion thereof, 2) the logic for exclusion of specific processes within a facility, 3) the intended method to develop and maintain a process management program, and 4) the regulations or requirements with which the facility must comply. There is an abundance of information available and considerable efforts have been expanded to create a hard copy data base containing this information. Recognition of the existence of this information should become a key part of the applications file. Therefore, it is important .that an index to the total process safety management program be developed to include physical location and responsible person or position required to address each element of the standard. (Opportunity No. A9401) Employee Participation: 1910.119(c) The intent of this paragraph is to assure employers afford their employees an opportunity to become involved in the process safety management activities at an elemental level. The plant's employee participation policy (General Notice SA-809, January, 1993) does not adequately address actions necessary to involve employees in development of the various elements of the PSM standard. Specifically, the procedure needs to include action that will allow for employee consultation in the following areas; 1) mechanical integrity, 2) pocess safety information, 3) hot work permit, 4) emergency planning and response, and 5) compliance audits. Documentation of all employee participation, recommendations, responsibility, action taken with a time line for completion and closure status will enhance this employee participation policy. (Opportunity No. EP9402) Process Safety Management Assessment Louisville PVC Facility Page 4 Process Safety Information: 1910.119(d) The intent of this paragraph is to provide complete and accurate information concerning the process which is essential for an effective process safety management program and for conducting process hazard analyses. Written safety information on process chemicals, process technology, and the process equipment involved is available at this site. The plant intends to deal with consequences of deviation and safe upper and lower limits involving the process through the W.P.S. System. An enhancement to this part of the PSM can be achieved by including a copy of the current MSDS on vinyl chloride, adding the vinyl chloride spheres to the block flow diagram and include the electrical classification drawing in this file. (Opportunity No. PSI9403) Due to the extensive amount of information required by this element, it is suggested that a subject index system be developed to address all subsections of this element. This will help to reduce the possibility of omitting critical data required by this section. Opportunity No. PSI9404) Process Hazard Analysis: 1910.119(e) Employers are required to develop a thorough, orderly, systematic approach for identifying, evaluating and controlling processes involving highly hazardous chemicals. There are six sections which must be considered to achieve minimum requirements outlined by this paragraph. 1. Setting Priorities: An initial hazard evaluation of the process has been completed. Rationale for the priority for completing PHA's was considered according to the standard however, this action needs to be documented. (Opportunity No. PHA9405) 2. Methodology: The plant utilizes Primatech's software to conduct process hazard analyses. What-if or check list are also employed based on complexity of the process to be reviewed. NGC 12806 Process Safety Management Assessment Louisville PVC Facility Page 5 3. Handling Team Findings: The plant's PHA process is thorough and covers all elements necessary for a process review. Interviews with plant employees indicate that recommendations are not always resolved in a timely manner. There is a need to communicate PHA recommendations to the appropriate plant personnel in a more thorough fashion. (Opportunity No. PHA9406) 4. Previous Incidents: Previous process related incidents are being considered during process hazard analyses, but this action is not always recorded. These "look back" opportunities can be a valuable resource to prevent recurrence. It is recommended that this type of information be added to the PHA documentation. (Opportunity No. PHA9407) 5. Process Hazard Analysis Team: Team membership includes experience from plant and process engineering, operating personnel, safety and environmental and at least one person skilled in the HAZOP methodology. The plant completes biographical information on each member of a PHA team. This data should become part of each PHA file. 6. Engineering / Code Standards: It is recommended that as the PHA's are being conducted, applicable standards and codes that are being used as part of the evaluation process be identified and included as part of the PHA documentation, (i.e., ASME, API, ANSI, or internal company engineering standards for piping specifications, materials for construction and other design parameters) (Opportunity No. PHA9408) Operating Procedures: 1910.119(f) The requirements of this section are for the employer to provide clear instructions for safely conducting activities involved in the covered processes consistent with the process safety information assembled by the Louisville PVC Plant. The PSM standard requires that operating procedures be reviewed as often as necessary to assure that they reflect current operating practices. In addition, these operating procedures are to be certified annually by the employer to insure the procedures, as written, actually reflect operating practice. (Opportunity No. OP9409) NGC 12807 Process Safety Management Assessment Louisville PVC Facility Page 6 The plant operating procedures must include operating limits that outline consequences of process deviation and steps required to correct or avoid these deviations. The plant will need to address this requirement in order to fully comply with this section of the PSM standard. (Opportunity No. OP9410) The plant should be commended as it moves toward ISO 9002 certification. Control copies of plant safety procedures were observed in the field. This greatly reduces the chances of an employee being guided by an out-of-date or unauthorized safety procedure. The entire ISO format lends itself nicely to the detailed documentation required by the PSM standard. Training: 1910.119(g) The intent of this section is to help employees understand the nature and causes of problems arising from process operations, and increases employee awareness with respect to the hazards of a particular process. An effective training program like the Louisville Plant has, can significantly reduce the number and severity of incidents arising from process operations. The training program can be instrumental in preventing small problems from becoming or leading to catastrophic events. Initial and refresher training has been accomplished with records of this activity available. It should be noted that the Louisville Plant chose to qualify all existing plant operating personnel using plant procedures rather than ''grandfather'' those employees involved in operating a covered process prior to May 26, 1992. One area of training which will require attention deals with operating limits or how to address consequences of deviation and steps to avoid these deviations. (Opportunity No. T9411) Contractors: 1910.119(h) The intent of this section is to require employers who use contractors to perform work in and around processes involving highly hazardous chemicals to establish a screening method to select contractors who will accomplish the task without compromising the safety of the Louisville facility. The contractor has responsibilities and must assure that their employees are trained on performing the job safely, the hazards relating to the job and understand the provisions of the owner's emergency response plan. NGC 12808 Process Safety Management Assessment Louisville PVC Facility Page 7 The plant's contractor screening and selection process considers prospective companies OSHA 200 Log, insurance experience modification rate, past performance and opinions of neighboring industrial facilities. (Opportunity No, 9412) The GEON plant's contractor orientation was attended to better understand what information is offered to contractors coming into the Louisville facility. This orientation program is used jointly with the BF Goodrich facility. The plant site actually encompasses three separate facilities (ZEON, BFG, GEON) with limited physical barriers in place to separate the facilities. The auditor was informed that a GEON Louisville site specific orientation video is forthcoming. An in-depth interview was conducted with superintendents from Marine Electric, ADEL Construction and Baumgardner to evaluate their knowledge and understanding of GEON's safety policies and procedures. All of these superintendents had been associated with this facility for several years and had a clear understanding of cardinal rule procedures. Pre Start-up Review: 1910.1190) New processes and modified processes which necessitate a change to the plant's process safety information dictate considerations before highly hazardous chemicals are introduced into the process. These requirements include a pre start-up review to confirm that the following actions have been addressed: Construction and equipment is according to design and specification. t Safety, operating, maintenance and emergency procedures are in place and adequate. A PHA or other hazard recognition methodology has been performed, recommendations have been resolved or implemented. Management of change (if required) and training of each employee and contractor involved in the process has been completed. Pre start-up reviews are being conducted. This activity should be documented complete with actions to resolve findings and made part of the project file. It is recommended that a document such as Figure 1 (see attached) be considered. (Opportunity No. PSSR9413) NGC 12809 Process Safety Management Assessment Louisville PVC Facility Page 8 Mechanical Integrity: 1910.119Q) This section establishes requirements to assure that equipment used to process, store, or handle highly hazardous chemicals is designed, constructed, and maintained to minimize the risk of a chemical release. The elements of a mechanical integrity program includes the identification and categorization of equipment and instrumentation, the development of written maintenance procedures, training for process maintenance activities, inspection, testing, correction of deficiencies outside of acceptable limits and a quality assurance program. The plant has very good individual mechanical integrity procedures to address all elements of this standard. Although all are not fully implemented, it is suffice to say that this subject is being addressed effectively. It should be noted that the relief valve and vessel inspection programs are being coordinated by Gordon Garrett, a maintenance employee who demonstrates a keen interest and ownership in this activity. The inspection of the piping system and associated components will also be coordinated by another maintenance employee Phil Fortwengler (pipefitter). This action demonstrates the willingness of the Louisville management to allow employees to participate in managing process safety and also illustrates the desire of plant employees to participate in this important program. The rationale or basis for inspecting and testing frequencies for specific types of service of process equipment included in the facility's mechanical integrity program including the two-year inspection internal for reactor relief valves and three-year cycle on inspection and testing of relief valves on vinyl spheres was not referenced or identified in the individual mechanical integrity procedure. (Opportunity No. MI9414) The mechanical integrity procedure(s) do not identify the training requirements of employees assigned to perform various job tasks included in the mechanical integrity processes. (Opportunity No. MI9415) The facilities written mechanical integrity procedures do not describe the responsibilities of the receiving department personnel, craft employees, project engineers and other plant personnel to assure that the quality of maintenance materials, spare parts and equipment is suitable for process application. (Opportunity No. MI9416) NGC 12810 Process Safety Management Assessment Louisville PVC Facility Page 9 Hot Work Permit: 1910.119(k) Employers must control, in a consistent manner, non-routine work in process areas covered by the standard. Specifically, this subsection is concerned about permitting hot work operations associated with welding and flame cutting in highly hazardous chemical process areas. Minimum requirements to comply with this section includes meeting OSHA's 1910.252(a) General Requirement Standard. The plant's safety procedure number SA-201, Hot Work Authorization meets the requirements of OSHA's 1910.252 Standard. Rigid controls are in place which must be followed in order to weld or burn in any area of the Louisville Plant. The hot work authorization policy requires written permit and approval before work can be performed in the plant. Instruments used to verify L.E.L. readings are maintained by the instrument department on a regular basis. Contractors (verified by interviews) are knowledgeable respective to obtaining permits, complying with specific requirements and feel free to offer suggestions to do a specific job safely. No recommendations are thought necessary. Management of Change: 191 o.i 19(1) Careful consideration of all modifications to equipment, procedures, raw materials and process conditions other than "replacement in kind" must be controlled by identifying and reviewing prior to implementing a change. The plant has a management of change procedure which functions very well. The policy is specific with justifications as to when the M.O.C. is required. All other changes are included in the M.O.C. policy and is utilized plant-wide rather than PSM areas only. Clear responsibilities for administration of the program is specified by the plant's SA-807 management of change policy. There is a need to inform specific contractors on a "need to know basis" about management of changes if the contractor has to perform work in the covered process where the M.O.C. is required. fOpportun/fy No. MOC9417) Process Safety Management assessment Louisville PVC Facility Page 10 Incident Investigation: 19to.119(m) The plant is required to investigate each incident which results in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace. The plant is accustom to reporting any incident with potential as part of their safety culture for preventing accidents. The preparation of narrative reports to document the investigation activities includes causal analysis (management system investigation) to pinpoint the root causes is a normal course of action at this plant. Careful tracking of action item recommendations to closure and making this information available for use when PHA's are conducted will pay long term dividends. (Opportunity No. 119418) Emergency planning and Response: I910.ll9(n) This paragraph requires employers to address what actions employees are to take when there is an accidental release of highly hazardous chemicals. The plant has several stand alone procedures that address part of the requirements of this section. It is recommended that a site emergency response plan be developed which will include all or portions of the following plant safety or environmental procedures; SA402, 404, 405, and EV-7. (Opportunity No. EPR9419) The plan, as a minimum, must include actions to address 1) escape procedures and routes, 2) headcount, 3) preferred means to report emergencies, 4) duties and procedures of employees who remain to operate critical equipment, perform rescue and medical duties, 5) the name or locations to contact for more action plan information and 6) employee alarm systems. The plant presently does not have personnel trained to respond to HAZMAT type incidents beyond their assigned work areas. This is considered a first responder awareness level employee. It is recommended that a core group of GEON Louisville employees be trained to the first responder operations level so as to facilitate plant wide response capabilities. (Opportunity No. EPR9420) Additionally, the plant's testing frequency for non-supervised alarm systems should be reviewed to verify compliance with OSHA's 1910.165 - employee alarm system requirements. (Opportunity No. EPR9421) NGC 12812 Process Safety Management Assessment Louisville PVC Facility Page 11 Compliance Audit: 1910.119(o) Employers are required to audit (self evaluate) the effectiveness of their PSM program to identify improvement opportunities and take appropriate corrective action to resolve deficiencies. Minimum requirements include: * Audit at least every three years * Maintain at least the last two audits plus current. * Track to completion the audit findings and document the closure action. Trade Secrets: I9l0.ll9(p) This section requires employers to provide all information necessary to comply with personnel developing sections (d) process safety information, (e) PHA's, (f) operating procedures, (n) emergency planning and response, and (o) compliance audits without regard to possible trade secrets. The GEON Company and the Louisville PVC facility have provided all information requested to conduct the 1910.119 Process Safety Management Audit. The one recommendation thought to improve the trade secret section would be to develop a secrecy agreement document for specific contract employees that work in sensitive areas of the plant. (Opportunity No. TS9422) Figure l Pre-Startup Safety Review 1910.119(1) Note: Pre-startup reviews are required for new facilities and modified facilities where the modification is significant enough to require a change in the process safety information. The following conditions have been met: before the introduction of highly hazardous chemicals into the workplace. Initial if Complete 1. A pre-startup safety review was held on this project. 2. Safety, operating, maintenance, and emergency procedures are in place and adequate. 3. Training of each impacted employee has been completed and documented. 4. Construction is in accordance with design specifications. Representative samples of incoming material and equipment have been checked to verify the proper materials of construction have been used. 5. For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup. 6. Modified facilities meet the plant's management of change requirement. 7. A field walk-through has been completed and potential startup and operational hazards that were detected have been corrected. Project Description:. Operations Superintendent: Project Engineer:. Date: Date: TMJ PRE-STRT.FRM NGC 12814 PSM AUDIT 1 Element Application 1910.119(a) Employee Participation 1910.119(c) Process Safety Information 1910.113(d) Process Hazard Analysis 1910.119(e) IMPROVEMENT OPPORTUNITIES LOUISVILLE PVC FACILITY 1994- jar i ' A9401 Develop an index for the plant's PSM program which includes the /ogic for including and excluding processes and person/position responsible for managing the program. * ResfOWSlBILlTY l Target Date i (L EP9402 PSI9403 PSI9404 PHA9405 PHA9406 PHA9407 Recommend that SA-809 employee participation procedure be revised to more clearly outline how employees are ! consulted for their participation in the PSM program. Include current VCM MS DS, electrical classification drawing in the process information file. Also add VCM spheres to block flow diagram. Develop a comprehensive index to the process information filing system to address each subpart of this paragraph. Document rationale for priority utilized to complete HAZOP's. Provide a system to resolve PHA recommendations in a timely manner and communicate findings to appropriate plant people. Previous incidents are being considered, but this action is not always documented nor is an explanation of how the information will be included. <z_ NGC 128 Operating Procedures 1910.119(f) OP9409 OP9410 Certify annually all operating procedures represent actual field operations and current technology. Address consequences of process deviation and steps required to correct or avoid these deviations, Improvement Opportunities -1994 Louisville PVC Facility Page 2 Element Training 1910.119(g) Contractors 1910.119(h) Pre Start-Up Safely Review 1910.119(1) Mechanical Integrity 1910.119{j) Management of Change 1910.119(1) Incident Investigation 1910.119(m) Emergency Planning and Response 1910.119(n) Trade Secrets 1 910.119(p) Target 10* Description Response urr Date T9411 C9412 PSSR9413 Address training needs associated with operating limits, i.e., consequences of deviation and how to avoid. Complete post ]ob evaluation on all contractors that perform work In a PSM area. | Consider using "project safety walk-through" form to document process safety start-up review (Figure 1). MI9414 MJ9415 MI9416 MOC9417 119418 EPR9419 EPR9420 EPR9421 TS9422 Document rationale for frequency or basis for inspection and/or testing. Identify and document ihe training requirements of employees assigned to perform various tasks in the mechanical integrity processes. Document responsibilities of personnel required to assure quality of materials, parts and equipment. Inform specific contractors on a "need to know basis" about M.O.C.'s that take place in their work area. Establish a system to insure action item recommendations are resolved and closed with proper documentation. Develop a site specific emergency response plan for the Louisville Plant. Train core group of Louisville employees to the first responder operations level so as to provide plant wide inhouse response capabilities. Review test frequency on non-supervised pfant alarm systems to assure compliance with OSHA's 1910.165 Standard, Suggest plant develop secrecy agreement with contractors that work in restricted plant areas. O 0P TP C C c NGC 12816 AUDITOR QUALIFICATIONS T. Michael Jones: Mike Jones has worked in the petrochemical industry with The BFGoodrich Chemical Company, Diamond Shamrock Chemicals, Cain Chemical and Occidental Chemical Corporation for 29 years. He was the Corporate Manager - Facility Safety and Industrial Hygiene for OxyChem until he elected early retirement in September, 1993, to form the company of T.Michael Jones & Associates. Mike is a Certified Safety Professional with extensive experience in plant operations, maintenance, engineering design/construction, safety, industrial hygiene, emergency management, and process safety management. Product manufacturing experience includes synthetic rubber, PVC resin, vinyl chloride monomer, olefins and aromatics, ethylene dichloride, caustic soda, chlorine, and ethylene oxides/derivatives. He holds a B.S. Degree in Industrial Arts and Chemistry from Stephen F. Austin University and a M.S. Degree in Engineering Management from Louisiana State University Baton Rouge. NGC 12817