Document O3kEbXMm7V2NkrM7Z01JR6RqX

TO: Distribution Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles April 8, 1991 DRAFT MOC PROCESS GUIDELINES VISTA Attached is the most current draft of the MOC guidelines developed by the sub-team. As we have discussed, this can be used for discussion purposes but may change in detail depending on the upcoming management and plant manager meetings. T. G. Grumbles dlj PROCESS SAFETY TEAM Paul Warner, Jay Reid, R. B. Newton, B. Trego-Aber, Graham BaconLCVCM, Stan Allen-LCCP, T. Salah-LCLAB Jerry Stone, James Cummings, Eric Meyer Post-ItTM brand fax transmittal memo 7671 #oi pages /Y T Co. Dept. Fax# 4 )/7ASkJL*~S Fr"? &7l~ Co. Phone # Fax # VISTA MANAGEMENT OF CHANGE GUIDELINE TABLE OF CONTENTS Purpose Definition of Change Process Flov Diagrams a) Work Orders b) Designs - Capital Projects Documentation Requirements (From Proposed OSHA Standard) Proposed OSHA Process Safety Standard Appendix VVV 000006274 PURPOSE AND SUMMARY OF DOCUMENT The attached information should be considered as a guide and as a starting place for compliance with the OSHA Process Safety Standard. The attached procedures can be modified to meet the needs of the individual plants. However, we are recommending that a formal procedure be established to ensure that the appropriate steps are taken and that the required documentation is updated. The MOC system for capital projects is similar to what occurs in most of the plants with the following exceptions: 1. A hazard analysis step has been added to the process flow after the class A design has been completed. 2. A "final class A design" step has been added to represent the design after completion of the hazard analysis. 3. Operating manuals are prepared prior to the hazard analysis. 4. The approval process has been expanded. The work order system is affected by the Management of Change Process if the work order is defined as a change. If it is, then a separate process needs to be followed. Major changes included in the new procedure are: 1. Two decision steps have been added to determine the level of safety review required. 2. Several steps have been added to ensure that documentation has been updated. 3. Approval procedures have been modified to use a hazard level in addition to dollars to determine the approvals needed. Revisions to the approval process are intended to accomplish 2 main tasks. These are to (1) ensure that all departments affected by a change have the opportunity to give their input prior to moving on to the next step, and (2) have a check to make sure that the appropriate documentation has been updated. VVV 000006275 CHANGE DEFINITION FOR MANAGEMENT OF CHANGE "Change", WITH RESPECT TO WORKORDERS AND DESIGNS, shall be defined as any work done that is not an exact replacement in kind. Examples may include, but are not limited to, the following: Line size changes Revisions to pipe routings Changes of materials (pipe, gaskets, packing, seals, equipment, P.G. diaphragms, valves, linings, etc...)* Modifications to pumps or compressors that change their operating curves. Removal of any instrument from service Addition of any controlling instrument Adjustment affecting the operating range of any instrument Addition of a valve Removal of a valve Addition of a new line (jumpers) Revisions that change an equipment's service Changes to relief device settings vvv 000006276