(82a) Application of PSM to Non-Regulated Industrial Facilities and Operations - Case Studies and Success Stories

Application of PSM to
Non-Regulated Industrial Facilities and Operations
Case Studies and Success Stories
Peter A. McKnight and Ronald B. Melucci
Engineering Planning and Management Inc. (EPM)
AND
Janet Persechino
Operational Risk Advisor, NC and NE Regions,
Process Safety and Operational Risk Management Group
Enbridge, Inc.

Abstract
Most industrial facilities and operations that process hazardous materials are below the threshold quantities of OSHA 29 CFR Part 1910.119; Process Safety Management (PSM) or the EPA 40 CFR Part 68 Risk Management Program (RMP) requirements. However, many of these companies can benefit from the risk reduction that is realized by applying some, if not all of the elements of PSM, such as enhancing safety culture, reducing risks that can cause incidents (loss of containment, personnel injuries and near misses), improving technical documentation, developing and maintaining formal SOPs, implementing formal employee and contractor training, conducting hazard analyses and implementing a management of change program to reduce risks from executing changes. Also, most regulators now view PSM/RMP as a best practice and expect these practices to be implemented under general duty clauses.

Many companies have realized the benefits of these risk reduction activities, most of which are well known in the industry, e.g., insurance premium savings, continuity of operations, public perception/reputation and many more. Perhaps one of the lesser known benefits of “voluntarily” implementing some elements of PSM is achieving fire code compliance. Many companies are not aware of these fire code requirements, which are intended to address not just fire but all chemical hazards. Even for “small” hazardous processes, some degree of process safety management is required by the US (and many international) fire codes which are either based on NFPA 1 or the International Fire Code (IFC). Local fire departments have the authority to require PSM for permit applications at any time, with supporting documentation to demonstrate that the required elements of PSM are met.

Nuclear power plants are regulated by the Nuclear Regulatory Commission (NRC). Many rooms and areas in nuclear power plants contain equipment such as electrical cabinets, control panels, motor control centers and cable trays that are critical for maintaining cooling systems and safe shutdown of the reactor core. Analyses are necessary to ensure there are multiple redundant “trains” (success paths) to eliminate single-point failures and minimize likelihood of reactor core damage.

The authors will discuss specific case studies and recent success stories from industries such as gas transmission, plastics manufacturing and nuclear power plants to demonstrate:
• How application of HAZOP, HAZID and PSM audits have been used to expertly plan for and implement elements of PSM that greatly benefit facilities and operations even for those facilities not required to implement PSM
• How innovative approaches can be applied to implement the most beneficial tools of PSM on a prioritized basis
• How companies that are not “required” to apply PSM or RMP, found multiple benefits in these approaches to achieve risk improvement/reduction
• How implementation of elements of PSM have been used to satisfy the requirements of the local fire authorities and other regulatory agencies such as NRC. Specific fire code and regulatory verbiage will be reviewed.