Wenck has enhanced our compliance services for Process Safety Management (PSM) and Risk Management Plan (RMP) program subject facilities with additional focus on Ammonia Refrigeration. The PSM/RMP programs are for the management and safe operation of processes which use highly hazardous chemicals. Details of the PSM program are described in 40 CRF 1910.119 and details of the RMP program are described in 40 CFR 68.
Ammonia is highly hazardous as it affects the skin, eyes, and lungs and is classified as immediately dangerous to life and health at 300 parts per million concentration in the air. Liquid ammonia can also be extremely cold and ammonia gas is flammable/explosive.
The PSM and RMP programs are very similar and cover most of the same subjects with the RMP requiring a hazard assessment to quantify a worst-case and alternative case release scenario with an associated toxic release radius. Facilities that fall under the PSM and RMP programs have several compliance-related activities required by the programs: auditing, process hazard analysis revalidation, management of change/pre-startup safety reviews (MOC/PSSR), mechanical integrity items, and RMP updates/resubmittal.
Wenck can assist with the compliance activities. The compliance audit must be performed every three years and consists of a full review of all parts of the PSM program. The PHA revalidation must be performed every five years, or when sufficient change in the process warrants. A PHA revalidation consists of a series of scenarios/discussions around the various components of the process and the potential hazard frequency and severity they contain. The full PHA must also be performed before changing and starting up a new hazardous process.
The MOC/PSSR compliance activities take place when a potential change to the process is initiated and are fairly similar to the PHA activities. However, the MOC/PSSR compliance activities are centered only around the project or potential change instead of the entire process. Mechanical integrity compliance activities are annual and semiannual and consist of visual inspections, mechanical exercising of components/safety systems, and physical measurement of corrosion/wall thickness on piping and vessels. The RMP program requires resubmittal every five years and consists of a review of the entire program and revalidation of the hazard assessment.
Carl Enzenauer is Wenck’s leading PSM/RMP compliance specialist with support from more than four colleagues with PSM and/or RMP experience. Our team has performed numerous audits, PHA’s, MOC/PSSR reviews and RMP reviews for ammonia systems and other hazardous chemicals. Carl is a registered professional engineer in Minnesota and North Dakota and can be reached at 763-479-4282 or at firstname.lastname@example.org.