Risk Management Plans and Process Safety Management

SCS Engineers Environmental Management Plans Systems

National Expert: Lee Pyle

 

Environmental compliance issues are more complex than ever. SCS’s Tracer Environmental Division has expertise in all aspects of environmental management, safety and risk analysis, and compliance. SCS Tracer’s Risk Management team focuses on compliance related to risk and process safety-based EPA and OSHA regulations. SCS also provides expertise with state-specific programs such as the California Accidental Release Prevention (CalARP) Program and Nevada’s Chemical Accident Prevention Program (CAPP).

Our specialized practice provides advanced environmental and engineering services regarding risk management and safety to both government and industry clients. SCS staff have expertise in all aspects of compiling Process Safety Management (PSM) and Risk Management Plans (RMP) documentation, such as piping and instrumentation diagram preparation, mechanical and compliance audits, process hazard analysis, and off-site consequence analysis and modeling.

Our Risk Management and Safety Group offers a comprehensive set of technical capabilities, including:

  • Risk and Safety Audits
  • Dispersion Modeling Studies
  • Process Hazard Analyses
  • Piping Diagrams
  • Process Safety Management Programs
  • Risk Management Plans (EPA)
  • Ammonia Refrigeration Mechanical Integrity Inspections
  • Operator, Custom & PSM/RMP Training
  • Ammonia Detector Testing and Calibration
  • Industrial Wastewater Pretreatment

SCS understands that project delays can translate into significant and unexpected operating costs. We offer proven fast-track techniques to respond rapidly to our clients’ needs and to ensure that technical objectives are completed on schedule and within budget.

To better serve the unique needs of our clients, we employ experienced staff with backgrounds in oil, petrochemical/chemical industries, aerospace, and manufacturing companies. Tracer’s service professionals are strategically located across the nation and perform the calibration in a wide range of ammonia refrigeration industries such as dairy, food, and beverages; ice arenas and ice manufacturing; cold storage warehouses; and for facilities using ammonia for metal/tooling heat treating, and fossil fuel plants with NOx systems. As an added service, we can provide consultation on your ammonia detection system based on the IIAR 2-2014 Standard and Recognized And Generally Accepted Good Engineering Practices (RAGAGEP).

Risk and Safety Audits

SCS conducts a variety of audits to evaluate facility compliance with current environmental and safety regulations. In particular, EPA’s Risk Management Program regulation and OSHA’s Process Safety Management standard require that facilities conduct compliance audits every three years to ensure the programs’ effectiveness.

An audit can verify that the training program is complete and that employees are being trained by reviewing employee records. SCS uses the American Institute of Chemical Engineers, “Guidelines for Auditing Process Safety Management Systems.” , Four essential tasks determine the effectiveness of a facility’s programs:

  • Understand Management Systems
  • Gather Audit Data
  • Evaluate Audit Data
  • Report Audit Findings

This audit process can be applied to EPA’s Risk Management Program and OSHA’s Process Safety Management Program as well as OSHA’s safety requirements included in Section 1910 (Cal-OSHA Title 8) such as Confined Spaces, Respirator Protection, Injury Illness and Prevention Program, Forklift Safety, Ladder Safety, Means of Egress, etc.

Process Hazard Analysis

SCS Engineers can prepare a Process Hazard Analysis (PHA) for your facility, to serve as the basis for many decisions and procedures associated with an effective risk and safety program. A PHA is a systematic effort to determine potential hazards and develop mitigation solutions, including equipment and procedural modifications, and training. An effective PHA analyzes potential consequences associated with a release of hazardous materials including fires, explosions, and exposure to toxic materials.

SCS recommends that a facility conduct a Hazard and Operability Study (HAZOP), based on the American Institute of Chemical Engineers (AIChE) HAZOP Guide Word method as described in their publication, “Guidelines for Hazard Evaluation Procedures,” along with a “What-If” Walkthrough analysis. Our experience shows that the HAZOP combined with a walkthrough prevents overlooking operator hazards. The walkthrough, following the design analysis, enables incorporating human factors such as lighting, accessibility, and overall working conditions into the analysis, which are entered into the Log Tables during the actual study.

Process Safety Management Programs

OSHA requires certain facilities to comply with its Process Safety Management (PSM) regulations. California (Cal/OSHA) has an equivalent program. SCS prepares complete Process Safety Management Programs for facilities that store or use regulated hazardous materials over the threshold amounts.

OSHA developed the PSM standard to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. SCS uses facility documentation, procedures and interviews with personnel to complete drafts of the fourteen prescribed PSM sections, prepared according to facility specifications. After facility review, we develop the final documentation for the facility.

SCS can prepare piping and instrumentation diagrams (P&IDs) which can be used for the Hazard and Operability Study or the Process Safety Information requirement within the PSM regulation. The P&IDs outline all equipment, valves, and level controls within the hazardous material system at the facility. The P&IDs also frequently show the valve numbers used within the operating procedures. For an overall understanding of the hazardous material system, we develop a process flow diagram.

The Risk Team at SCS Tracer have all attended the Ammonia Safety Training Institute (ASTI) 32-Hour Emergency Response and Planning Training. Our backgrounds and training include:

  • Comprehensive instruction on how ammonia acts in the atmosphere,
  • Toxic properties of ammonia and how it affects the body,
  • How to develop an excellent response to action-plan for live releases of ammonia.

Risk Management Plans (RMP)

The Clean Air Act Amendments of 1990 contain a provision for evaluating the potential public impact of an accidental release of acutely toxic, flammable, and explosive materials from industrial facilities. The EPA finalized regulations to implement this provision by requiring the preparation of a Risk Management Plan (RMP) for all facilities that store or utilize regulated substances in quantities that exceed the threshold quantity for specific materials.

SCS has extensive experience in the development of Risk Management Programs addressing Clean Air Act services (40 CFR Part 68), Chemical Accident Prevention Provisions. We have developed hundreds of plans for a variety of different types of industries, and we conduct the required ongoing maintenance and five-year revalidations and updates. We also prepare submittals and program documentation for new facilities wishing to use listed substances.

Environmental Compliance Auditing and Dispersion Modeling

SCS professionals work with your facility staff evaluating your environmental programs as they relate to local, state, and federal regulations. An environmental compliance audit will note observed deficiencies and make recommended corrective actions.

SCS prepares atmospheric dispersion modeling studies for risk assessments, or possible release scenarios developed during the facility’s Hazard and Operability
Study. Modeling studies evaluate the impact of various release scenarios on local air quality. Release scenarios consist of one or more sources located in flat or complex terrain. Our engineers conduct the analyses using the dispersion models (Gaussian, numerical, statistical, or empirical) that best suit each scenario. For improved accuracy, SCS develops proprietary models according to the specific needs and modeling conditions of our clients (e.g., neutral, buoyant, dense gas, etc.). SCS also validates dispersion models using specially developed techniques involving tracer gas sciences.

SCS Engineers Sample Map – Dispersion Modeling Results

To display the impacts simulated by the dispersion models, SCS overlays “isopleths” (contours of constant values) onto digitized maps. Our process ensures the accuracy of the results and reduces overall project costs. As shown here, a footprint of an ammonia release is superimposed over the area surrounding a subject facility.

PSM/RMP Training

SCS conducts PSM/RMP training, including outlining the responsibilities of the various PSM/RMP team members such as maintenance, safety, management, environmental, and facilities personnel. Our training covers:

  • PSM/RMP Regulatory Requirements
  • Ammonia Awareness
  • Implementation Strategies
  • Review / Completion of Required Forms

SCS has a diverse staff of well-qualified engineers, scientists, and technicians who can provide practical, cost-effective solutions to your complex regulatory problems.

Ammonia Refrigeration

Ammonia Refrigeration The SCS Tracer Environmental supports ammonia-refrigerated warehouses and manufacturing facilities throughout the United States. Our cumulative experience with ammonia-refrigerated facilities spans in excess of 100 years and includes operations, maintenance, and compliance. SCS employs RETA certified personnel (CARO, CIRO, RAI) to help facilities with compliance audits, SOP ...

Environmental Management Plans and Systems

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Operator, Custom, PSM/RMP Training

Operator, Custom,  PSM/RMP Training For additional information or answers about the SCS training listed here, to register please contact Mark Carlyle and Jodie Rukamp at NH3Training@scsengineers.com. Refrigeration Operator I & II Training SCS’s  Refrigeration Operator I & II Training Programs use the applicable RETA Industrial Refrigeration (IR) 1 & ...

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