(64af) Compliance with Proposed Regulatory Requirements on Damage Mechanisms

As part of the proposed improvements to the California Process Safety Management (8 CCR, Division 1, Chapter 4, 5189.1) and Accidental Release Prevention Program (19 CCR Division 21, Chapter 4.5), California petroleum refineries will be required to conduct a Damage Mechanism Review (DMR) of all covered processes.  The DMR requirement of the regulations includes a strict review as well as documentation of the damage mechanisms that may affect the covered processes. 

The proposed DMR requirements can be summarized as identification of potential damage mechanisms, determination of existing safeguards, determination of vulnerabilities and recommendation of measures to reduce the risk associated with the mechanism.  To comply with the specifics of the regulations, a three step approach is proposed in this paper.  The intent of the approach is to generate a documented analysis that provides the required information for the specific damage mechanisms in a process. 

In the first step, existing engineering and metallurgy documents are collected and catalogued.  In the second step, the Process Hazard Analysis of the covered process is expanded to include detailed documentation of damage mechanism related scenarios.  In that process, the specifics of the damage mechanism and existing mitigative measures (i.e., inspection program) are identified and recorded within the PHA worksheets.  Doing so will establish potential vulnerabilities and identify whether recommended improvements are warranted.  In the third step, a separate report is generated based on the analysis completed in the second step to document the identified vulnerabilities, existing mitigative measures, and recommendations.  The report is organized such that the basis of the vulnerabilities and recommendations are clearly identified.  The report will provide operations and other affected personnel with a single living document summarizing the damage mechanism related concerns associated with the process that can be updated on a periodic basis.