Course Content

Course will include the following:

(1)Overview of the RMP and PSM

• Review of Regulatory Requirements
• History for Releases that promoted the Regulatory Requirements
• Refrigeration Equipment Components included in the RMP and PSM Program
• Responsible personnel at the facility
• The difference between the RMP and PSM Programs

(2) Risk Management Plan (EPA 40 CFR Part 68)

Overview of the Management System

• Persons responsible for the Program Management
• Organization Responsibilities

Hazard Review - Off-Site Consequence Analysis

• Using RMP Comp for Worst Case and Alternative Case Scenario
  Determining the Population around facility
  Distance to End Point

Prevention Program

• 14 Elements of OSHA Process Safety Management

Emergency Planning and Response

• Emergency Action Plan
  Emergency Response Program Requirements
  Coordinating Drills

Submitting the RMP Submittal to the EPA

• Setting up the Certifying Official and
• Preparer with MyCDX
• Process Inventory
• Latitude and Longitude
• Emergency Contact Information
• Gathering the dates and information for the
• RMP Submittal
• Requirements for updated or corrections to the RMP Submittal

(3) Prevention Program (OSHA 1910.119 Process Safety Management Program

Employee Participation - OSHA 1910.119 (c)

• Employee Involvement (From Production, Operations, Administration, Maintenace and Refrigeration Personnel)
• Levels of Responsibility
• Knowledge of PSM for all employees
• Knowledge of the Ammonia Refrigeration System

Process Safety Information - Required Documentation - OSHA 1910.119 (d)

• Piping and Instrumentation Diagrams (P&IDS)
• Block Flow Diagrams
• Equipment List
• Desired System Operating Ranges
• Safety Relief Calculations and Replacement Schedules
• Ventilation System Capacity (Ventilation Calculations)
• Equipment Installation, Operation and Maintenance Manuals (OEM’s)
• Inventory Calculations (based on Vessel Levels)
• Ammonia Delivery Log
• Ammonia System Maintenance Logs –
• Purging, Draining Oil, etc.
• Manufacturer Data Reports for Pressure Vessels
• Material and Energy Balances
• Design Codes and Standards
• Safety Data Sheets
• PLC Controls Operations
• Safety Systems and Their Functions

Process Hazard Analysis - OSHA 1910.119 (e)

• Overview of OSHA’s Process Hazard Analysis Standard
• PHA Methodology types
• A review of the different types of PHA Software
• Scheduling The PHA Team Sessions
• Pre-Study Documentation required.
• Following the Facilities PHA Procedures
• Types of Risk Matrix to use and the importance of using the correct Risk Matrix
• Leadership and Facilitator Skills
• PHA Team Requirements
• PHA Closing Meetings with PHA team and Senior Management including corporate personnel.
• Tracking PHA Action Items to Closure

Operating Procedures for Ammonia Process Equipment - OSHA 1910.119 (f)

• Table of Contents- Equipment List of SOPs needed.
• Safe Work Practices – (Confined Space, Hot Work, LOTO, Line Break)
• Overall System Operations
• Oil Draining
• Component SOP’s
• Charging the system with Ammonia
• IIAR-7 Formatting Templates

Training - OSHA 1910.119 (g)

• Initial and 3-Year Refresher Training
• RETA I and RETA II Operator Training
• Training for Operators to the Level of Responsibility
• Training Matrix Tables
• Emergency Response Training
• Small Releases vs Major Release and how to respond.

Contractor Program - OSHA 1910.119 (h)

• List of Approved Ammonia Contractors
• Annual Contractor Safety Awareness Training
• Certificate of Insurance
• Annual Review of Safety Performance and Programs
• Annual Review of Contractors
• Emergency Actions for Contractors
• Injury and Illness Log

Pre-startup Safety Review - OSHA 1910.119 (i)

• When is a PSSR Required?
• Who should perform the PSSR?
• Construction and Equipment is installed per
• Design Specifications
• Safety Procedures
• Operating Procedures
• Maintenance Procedures
• Emergency Response Procedures
  Training personnel in the above

Mechanical Integrity (3 Separate Chapters) - OSHA 1910.119 (j)

Preventative Maintenance

• IIAR-6 Preventative Maintenance Program Requirements (review)

Refrigeration Systems Safety Devices

• Compressors Cutouts (High Discharge, Suction, Oil Differential, Motor Amps)
• High Level Floats on Vessels (to prevent liquid ammonia from going back to the compressors)
• E-Stop Switches
• Emergency and Continuous Ventilation
• Ammonia Detectors and Alarms (Turns on Ventilations, Shutdown Compressors, etc.
• Emergency Shutdown Valves (ESD’s) Maintenance and Tagging, PIDs

Inspection and Testing

• Common Mechanical Integrity Deficiencies
• Missing Pipe Labeling and Valve Tagging
• Required Signage on Machine Room Doors
• E-Stop and Ventilation Switches on the outside of the main machine room door.
• Missing plugs
• Exposed Electrical
• SRV’s out of Date

Quality Assurance of new components (New and Existing Facilities)

• Introducing new components to the system
• Quality of materials used suitable for ammonia.
• Installation quality checks against IIAR-6
• Pre-Startup Review for each new component

PRIORITY MAINTENANCE ITEMS

Refrigeration Systems Safety Devices

• Compressors Cutouts (High Discharge, Suction, Oil Differential, Motor Amps)
  High Level Floats on Vessels (to prevent liquid ammonia from going back to the compressors)
• E-Stop Switches
• Emergency and Continuous Ventilation
• Ammonia Detectors and Alarms (Turns on Ventilations, Shutdown Compressors, etc.
  Emergency Shutdown Valves (ESD’s)
• Maintenance and Tagging, PIDs

Training for process maintenance activities.

• Written Maintenance Procedures (SMP’s)
• Maintenace Staff Training

Safe Work Practices - OSHA 1910.119 (k)

• Hot Work
• Confined Space
• Line Break Permit
• Power Equipment Permit
• Lock-Out Tag Out

Management of Change Procedures - OSHA 1910.119 (l)

• Minor Change
• Major Change
• Replacement in Kind

Incident Investigation Program

• Nuisance Odor Logs
• Incident Investigation Logs
• Near Misses

Emergency Response Program
Ammonia Odor Investigation (small release)

• Handheld Detector
• Respirators
• Fit Test
• Responding to a large Releasee