As I always say, we can not discuss MOC and PSSR as if they are separate systems… they go hand in hand 99% of the time. That is what I want to discuss: how a PSSR requirement defines how we manage our MOC system. We have discussed many times there are ONLY TWO (2) occasions where OSHA and EPA require a PSSR to be conducted:
- new facilities, and
- modified facilities when the modification is significant enough to require a change in the PSI
So when #2 above comes into play, what does OSHA/EPA mean when they say…
“modified facilities meet the requirements contained in management of change, paragraph (l)” (1910.119(i)(2)(iii)
It turns out that when doing a MOC, the MOC should generate an action list of the necessary actions to execute the MOC properly/safely. This list should define HOW the change is to be made. This is usually a listing of the RAGAGEPs that will dictate a physical change made to the process and a document list of the PSI, SOPs/ERPs, Training materials, etc., that must be created/updated based on the change. For example, adding a section of piping to a process may be viewed as a “simple change” by the engineering group, but the MOC could list dozens of documents that need to be created/updated to reflect this new run of pipe. Let’s look at this new 200′ run of pipe and its impacts.
The pipe material of construction was unchanged; the size was unchanged; however, this new run of pipe was through a new area of the plant. The pipe is carrying a liquified-pressurized flammable gas. This means the RAGAGEP requires hydrostatic relief valves in all locations where liquid can be trapped. We must update the MI program with these new hydrostatic RVs so they are serviced per their manufacturer’s frequency. And suppose we used a DIFFERENT manufacturer’s Hydrostatic RV. In that case, that is also a CHANGE that will need to be SPECIFICALLY evaluated within this MOC, or some organizations would do a separate MOC to get the new manufacturer approved BEFORE they attempted to do the New Pipe Run MOC. The RVs will need to be assigned parts/asset ID numbers so they can be entered into the CMMS and reflected upon the P&IDs. We can probably use our setpoints for the hydro’s based on the previous design basis since the size of the pipe has not changed. Still, we will want to verify there has been no change to the RAGAGEP that would require us to upgrade our Hydrostatic protection design for this new run of pipe.
This new run will pass through areas that are NOT designed to be a Hazardous Location (HAZLOC), so a thorough review of the pipe run through these areas to determine if the HAZLOC drawings will have to be updated AND what changes will be necessary for this area to now meet NFPA 70 or API 500/505. This may require new drawings to be created, the equipment is upgraded, ventilation installed, etc. Please note that this aspect could be HUGE and very problematic, so a thorough review of where the valves, vent/drain valves, any flanges, etc., are located in the run of pipe can dramatically impact the HAZLOC scope.
This new pipe run will either be a new “piping circuit,” or it will become part of an existing pipe circuit in terms of its inspection per API 570. Either way, we will create a new circuit and enter it into our CMMS, or we will revise the starting and ending point of an existing circuit, which will have to be reflected in the CMMS W.O. scope. It may not increase our inspection/testing costs; however, if the run is difficult to access, we may even want to revise our MI inspection/testing budget(s). Remember, we already have several new Hydrostatic RVs that will cost us to install and maintain every five (5) years, so we know we will have future costs for this latest run already.
This new run of pipe will have to be labeled per our RAGAGEP, usually ASME A13.1. Depending on the run of the pipe, this could be cheap and easy or costly and time-consuming. However, the MOC should define the number of labels, their size, and their locations on this new run of pipe.
This new run of pipe will have some new valves installed, which will have to appear on the revised (or new) Piping and Instrumentation Diagram (and possibly an Isometric Diagram if the organization requires this level of detail in their PSI or MI program). These new valves must be assigned an ID and entered into the CMMS W.O. system with an established inspection/testing frequency.
This new pipe run will change our PSM/RMP Battery Limits, which means we will need to update and retrain non-essential personnel and contractors on these new limits to control access to our battery limits. This may include updating the new employee orientation, the annual PSM/RMP overview materials, the Safe Work and/or Contractor Work Permit(s), and contractor orientation. We may even have drawings that may need to be updated to reflect this new battery limit of our covered process. And be sure that if this “new run of pipe” is connecting something to our existing covered process, we THOROUGHLY evaluate the new connected item for its inclusion in our PSM/RMP programs. Specifically, I am looking at this new run of pipe as a candidate for a Worst Case Release scenario. I have come across a scenario where the WCS vessel was a long way from the property line, but a 6″ diameter pipe that ran within 10 yards of the property line and had thousands of feet between valves contained as much of the HHC/EHS as the vessel chosen for their WCS. When it was all said and done, they had to update their RMP with a new WCS, which impacted 150,000 more residents. EPA had some inquiring minds when that update was uploaded!
This new pipe run may need a “facility siting” analysis performed. What is the actual run… can it be impacted by mobile equipment? Can the pipe racks handle this new load? Does this latest run of pipe require pipe racks to have fire protection?
I think you see my point—a simple addition of a pipe run is not all that simple! But once we are done with the MOC and BEFORE we put this new pipe run into service, we will perform our PSSR. One of the biggest misses in a PSSR is that someone does not verify that all the MOC needs that were identified for the change have been completed properly. This is, in fact, what someone is stating when they sign off on the PSSR line item we all have.
“modified facilities meet the requirements contained in management of change, paragraph (l)” (1910.119(i)(2)(iii)
If our MOCs do not generate a detailed scope of work necessary to execute this change PROPERLY and SAFELY, then how are we approving our MOCs, and more poignantly, how are we singing off on our PSSRs?