basf psm and risk management plan

Title:

Process Safety Management and Risk Management Plan

Freeport Site Function: Ecology & Safety Standard No.: BCF020.033 Page: of 45

Reviewed: 6/14 Effective: 08/24/10 Supersedes: 06/98 Preparer: Owner: Approver: EHS Team Leader or Designee Director, Environ, Health & Safety SVP & General Manager

RECORD OF REVISIONS

Date Rev. # Details of Change 06/5/14 6 • added index for G-R-PRS-040 Documentation for Process Safety

• updated PSI, Site, #2 to show SDS terminology and to reflect the change to backup SDS accessibility based on the corporate SDS service provider changes

• added Dispersions as a covered process 08/01/13 5 • title corrections because of titles, roles, and responsibilities changes since

the last revision • PHA, #7, added “/redone in accordance to the PSM/RMP Guide” to comply

with changes made previously to the PSM/RMP Guide • added Excel version as an option

10/04/12 4 • updated titles to reflect ICON job descriptions • minor content updates in PSI and MI sections

05/15/12 3 • updated responsible person in the EHS Information & Mechanical Integrity section based on ICON changes

• updated Mechanical Integrity to reflect current standards and document locations

07/31/10 2 • minor edits for clarity; revised manager roles from “E&M Mech. Group Manager and Pressure Vessel Group Manager to new role and title “E&M MSG Group Manager;” revised “Loveland” to “INtools” database and/ or SAP

• revised references to related procedures such as but not limited to NP-EI-105, NP-MC-105, etc., and to related programs like SAP, electronic CAD, website, E&M, etc.

• added that PSSR should be filed with Job Books and in EHS Change Manager database

• added responsibilities for Area I/E Engineer in Element 8 • revised Document locations to reflect electronic locations (E&M, EHS web

pages) • updated information to include databases (MSDS, Change Manager,

AIMS) 05/31/07 1 This standard is being revised to bring it into compliance with the template and

formatting of the Corporate Safety Procedures. No major changes have been made. There are minor word revisions to accommodate the format.

Title:

Process Safety Management and Risk Management Plan

Freeport Site Function: Ecology & Safety Standard No.: BCF020.033 Page: of 45 Reviewed: 11/09 Effective: 08/24/2010 Supersedes: 06/98 Preparer: Owner: Approver: Team Member, Freeport Hub Manager, EHS VP & General Manager

INTRODUCTION

OSHA’s Process Safety Management (PSM) standard became effective on May 26, 1992. The EPA’s Risk Management Plan became effective on June 21, 1999. These standards require that covered processes implement management practices to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals and to protect the public health and environment.

The following document on PSM and RMP outline a roadmap of where programs are found, who the owners of the programs are for accountability, and those responsible for maintaining the programs.

Within each element are blanks that each unit with PSM/RMP processes must answer to show where program accountability and responsibilities are for the unit. The filled in document will be maintained electronically on the unit’s web page or copied and placed in a unit PSM/RMP notebook. If a hardcopy notebook is kept, it will be located in the control room

Many PSM/RMP requirements reference another section of the Loss Control Manual, Maintenance Practices Manual, etc., because these programs existed before regulatory requirements went into effect. While all PSM requirements apply to RMP covered units, not all PSM units are covered by RMP. Additional RMP requirements are shown in a separate block in each element.

Senior Production Managers/Directors are overall accountable for implementation and maintaining of unit PSM/RMP programs. Operational Directors / VPs are accountable for providing support and resources for implementation and maintenance of required programs.

This document also serves as the index of the process safety documentation required by BASF global standard G-R-PRS-040 Documentation for Process Safety.

Click here for the Excel version of the PSM/RMP roadmap.

http://www2.basf.us/DocSearchWeb/displaydoc?docbase=Freeport_TX_US&cabinet=EHS&folder=Standards&docname=033a.xlsx

Below is a list of plants that fall under OSHA PSM and EPA’s RMP at Freeport

PSM RMP and PSM

Acrylic Acid II Acrylic Acid II

Acrylic Acid III Acrylic Acid III

Oxo Oxo

PolyAlcohols PolyAlcohols

Caprolactam I Caprolactam I

Caprolactam II Caprolactam II

SAP

Cyclohexanone I Cyclohexanone I

Cyclohexanone II Cyclohexanone II

Hydroxylamine II Hydroxylamine II

Ammonia Terminal Ammonia Terminal

Butyl Acrylate

2-Ethylhexyl Acrylate

Dispersions Dispersions

BCF020.033 Process Safety Management and Risk Management Plan

PSM ELEMENT #1 – EMPLOYEE PARTICIPATION UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (c) and EPA 40 CFR 68.83

SITE PROGRAM Accountable for

Requirement Location of

Documentation References/ Comments

1. Safety Organization - Develop a written plan of action regarding employee’s participation. EHS Manager Loss Control Manual BCF020.028

UNIT LEVEL REQUIREMENTS

Responsible for Requirement

Location of Documentation

References/ Comments

1. Consult with employees on the conduct and development of Process Hazard Analyses. • Employees included on PHA team

__________________

________________

Participant List in Unit PSM/RMP PHA documentation

2. Consult with employees on the other elements of Process Safety Management.

___________________ Unit Safety and UST Meetings Job Books -Process Safety Reviews info.

Safety Standards Review/ Process Safety Reviews

3. Provide employees access to PHAs __________________

________________ Unit PSM documentation

4. Provide access to all other information required by OSHA PSM. See each section. __________________ ________________ Unit PSM/RMP documentation

RMP-Specific 40 CFR 5. Provide access to the RM plan, which contains the RMP worst case scenarios and the five-year

accident history. EHS Team Leader Office of EHS

Specialist for Technology and Environmental web page


PSM ELEMENT #2 - PROCESS SAFETY INFORMATION UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (d) and EPA 40 CFR 68.67 SITE REQUIREMENTS Accountable for

Requirement Location of Documentation References/Comments

1. Any new chemical to be used on site must be approved through the process outlined in BCF020.036 Management of Change (Attachment B). This reviews the reactivity, safety, industrial hygiene, and ecology factors of the chemical.

Sr. Production Mgr./ Dir. & Site

Lab Mgr.

2 Each Unit’s EHS representative is responsible to help maintain MSDS/SDS information. MSDSs/SDSs for new or changed chemicals shall be provided to the Unit’s EHS representative for electronic maintenance.

EHS Mgr./Sr. Production Mgr./Dir.

Computer database BCF020.050: Hazard Communications

Unit Level Requirement Responsible for


1 Written process safety information, as described in 2 and 3 below is compiled before performing a process hazard analysis.

PHA leader Technology Specialist

See locations in 2 and 3 below.

PHA leader is responsible for compiling process safety information prior to a PHA.

2 Information on the hazards of PSM-regulated chemicals in the process, including the information listed below, is available. a. toxicity information b. permissible exposure limits c. physical data d. reactivity data e. corrosivity data f. thermal & chemical stability g. hazardous effects of inadvertent mixing that could foreseeably occur.

a.______________ b.______________ c.______________ d.______________ e.______________ f._______________ g.______________

a.______________________ b.______________________ c.______________________ d.______________________ e.______________________ f.______________________ g.______________________

MSDS’s may be used to satisfy these requirements, to the extent that they contain the required information.

3 Information on the technology of the process, including at least the following information, is available. a. Block flow diagram or simplified process flow diagram b. Process chemistry c. Maximum intended inventory d. Safe upper and lower limits for such items as temperatures, pressures,

flows, compositions e. MOC, PSSRs and Incident Reports to be considered in the PHA or Revalidation

activities. f. An evaluation of consequences of deviations, including those affecting the safety and health of employees g. Facility Siting and Human Factors

a.______________ b.______________ c.______________ d.______________ e.______________ f. ______________ g.______________

a.______________________ b.______________________ c.______________________ d.______________________ e. EHS databases (Change Manager & AIMs) f. ______________________ g.______________________

Operator training information may be used to satisfy these requirements, to the extent that they contain the required information.


Reference: OSHA 1910.119 (d) and EPA 68.67 Unit Level Requirement Responsible for


4 Information pertaining to equipment in the process, including the following information, is available. a. Materials of construction b. Piping and Instrument Diagrams (P&ID’s) c. Electrical area classification d. Relief system design, design basis and MAWPs of equip. e. Building ventilation system design f. Design codes & standards employed g. Material & energy balances (for processes built after May 26, 1992) h. 1. Interlock documentation h. 2. Fire detection / protection system documentation h. 3. Gas/vapor detection system documentation h. 4. Backup power supply (UPS) documentation h. 5. Alarms (as part of site wide alarm system, i.e. emergency horns) h. 6. Breathing air systems

a. See Element 8 b. Production Technologist c. See Element 8 d. See Element 8 e. Engineering Design Mgr f. See Element 8 g.______________ h.1. See Elem. 8 h.2._____________ h.3._____________ h.4. See Elem. 8 h.5._____________ h.6. See Safety Standard BCF020.013

a. See Element 8 b. Master P&ID’s available in control room. c. See Element 8 d. See Element 8 e.______________________ f. See Element 8 g.______________________ h.1. See Element 8 h.2.____________________ h.3.____________________ h.4. See Element 8 h.5.____________________ h.6. See Safety Standard BCF020.013, “Respiratory Protection”.

* Refers to “PSM Element 8, Mechanical Integrity” section of this document. • All those who make

changes to the process are responsible for updating master P&ID’s. See Safety Standard BCF020.36, “Management of Change” in the Loss Control Manual. The Production Technologist coordinates updates of the Master P&IDs with CAD.

• The procedure for identification and marking of PSM items on P&ID’s is Section 7.4 of the “Procedures & Guidelines for Engineers” manual.

• Fire detection / suppression systems are addressed in BCF020.016 in the Loss Control Manual.

• Hand-held Gas / vapor detection systems are addressed in the Loss Control Manual.

• Site wide alarms are addressed in the Loss Control Manual.



5 Equipment complies with recognized and generally accepted good engineering See Element 8 See Element 8 * Refers to “PSM Element




practices.

8, Mechanical Integrity” section of this document.

6 Equipment designed and constructed to codes, standards, etc no longer in use is designed, maintained, inspected, tested and operated in a safe manner.

See Element 8 See Element 8 Refers to “PSM Element 8, Mechanical Integrity” section of this document.

RMP-Specific Requirements

Unit Specific Requirements Responsible for Requirement

Location of Document References/Comments

Determine RMP Boundaries for: • Flammables – Determine Processes that:

1. Have a 1% De Minimus Concentration and 2. Meets NFPA 4 Criteria for Flammability (Count entire mixture to threshold amount)

• Toxic’s – Determine Processes that:

1. Have a 1% De Minimus Concentration and 2. Have a partial pressure of 10mmHg or greater (Count only toxic component in Mixture)

Document boundary determination.

____________

PSM/RMP PHA Unit documentation


PSM ELEMENT #3 – PROCESS HAZARD ANALYSIS UNIT: ______________

DATE: ______________ Reference: OSHA 1910.119 (e) and EPA 68.67



1

Site Program EHS Manager In accordance with Process Safety Management & Risk

Management Program Guide on Process Safety Web Page.

UNIT PROGRAM Responsible for

Requirement Location of Documentation References /Comments

1 A schedule should exist to show to completion date of initial hazard analyses and scheduled and completed Revalidation dates.

________________ _______________________

2 The schedule mentioned above should have documentation that describes the rational for the prioritization of the PHAs. The factors to be considered in the prioritization are: • the extent of process hazards • number of potentially affected employees • age of process • operating history

________________

_______________________

3 The Process Hazard Analysis (PHA) will be conducted in accordance to the Process Safety Management & Risk Management Program Guide.

Technology Specialist/TL

PSM/RMP PHA documentation

4 The hazard analysis method used should address specific areas such as: • process hazards • previous incidents with likely potential for catastrophic consequences • consequences of failure of engineering and administrative controls • the applicability of engineering and administrative controls to the hazards • facility surroundings • human factors • an evaluation of possible safety and health effects of failure of controls on

employees in the workplace

PHA Leader

_______________________

5 The hazard analysis team members must include individuals with the following qualifications: • expertise in engineering • expertise process operations • experience and knowledge specific to the process being evaluated and


Procedures & Guidelines Manual for Engineers


PSM ELEMENT #3 – PROCESS HAZARD ANALYSIS UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (e) and EPA 68.67

knowledge of the specific PHA methodology being used Reference: OSHA 1910.119 (e) and EPA 68.67 UNIT PROGRAM Responsible for


6 A system must be in place to promptly address the team’s findings and recommendations. This system must: • Assure that the recommendations are resolved and documented in a timely

manner, • Document actions to be taken, • Ensure that actions are completed as soon as possible, • Develop a written schedule of when actions are to be completed, • And communicate the actions to operating, maintenance and other employees

whose work assignments are in the process and who may be affected by the recommendations or actions.

________________

_______________________

Target dates and completion dates can be reviewed in the unit PHA documentation

7 The PHA’s must be updated and revalidated/redone in accordance to the PSM/RMP Guide by a PHA team at least every five years to assure that the process hazard analysis is consistent with the current process.

________________

_______________________

8 The initial PHA’s updates or revalidations and documented resolutions of recommendations must be kept for the life of the process. • Most recent PHA and action items • Previous PHAs and action items.

________________ ________________

_______________________ _______________________

Unit PSM Manual may contain all PHAs or just most recent updates/ re-validations.

RMP-Specific Requirements UNIT PROGRAM Responsible for


1. The owner or operator shall perform an initial process hazard analysis (hazard evaluation) before start-up of new RMP covered processes. For new processes under PSM because of the RMP rule, the priority on which the analysis will be conducted will be based on the potential for off-site consequences. Process analyses completed to comply with 1910.119(e) are acceptable initial process hazard analyses (these do not have to be re-prioritized based on off-site consequences). The prioritization shall be located in the PSM/RMP PHA documentation. Items 4-8 above must also be met for RMP hazard analysis. These PHA’s must be re-evaluated every 5 years.

_______________

_______________________

2. PHAs conducted on RMP processes must include a qualitative evaluation of the off-site consequences. See the Corp. Process Safety PSM/RMP Guide for standard phrasing.

_______________

_______________________


PSM ELEMENT #4 - OPERATING PROCEDURES UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (f) SITE PROGRAM Accountable for


1 Site Program for Written Job Instructions EHS Manager Loss Control Manual BCF020.017 2 Safe work practices must be developed and implemented for employees and

contractors to control hazards during operations such as: • Lock out/tag out. • Confined space entry. • Opening process equipment or piping. • Personal Protective Equipment (PPE) • Hot Work

Control over entrance into a facility by maintenance, contractor, laboratory or other support personnel.

a. Development b. Implementation

a. EHS Manager b. Production Execution Manager

a. Loss Control Manual b. See Permits

BCF020.012 BCF020.002 BCF020.039 BCF020.019 BCF020.023

BCF500.001 BCF020.001



1 a. There must be written operating procedures for each covered process that provides clear instructions for conducting activities safely.

b. Operating instructions must address, as a minimum, steps for each operating phase, including: 1. Initial start-up. 2. Normal operations. 3. Temporary operations. 4. Emergency shutdowns. * Conditions requiring emergency shutdown. * Assignment of shutdown responsibility to qualified operators. 5. Emergency operations. 6. Normal shutdown.

Start-ups following a turnaround or emergency shutdown. c. Operating procedures must include operating limits that outline

consequences of process deviation and steps required to correct or avoid deviations.

Safety and health considerations must be included in the operating procedures that include at a minimum:

a. _____________ b1. _____________ b2. _____________ b3. _____________ b4. _____________ b5. _____________ b6. _____________ c. _____________ d. _____________

a. _____________ b1. _____________ b2. _____________ b3. _____________ b4. _____________ b5. _____________ b6. _____________ c. _____________ d. _____________

BCF020.017: Written Job Instructions


Reference: OSHA 1910.119 (f) Unit Level Requirement Responsible for


• Properties of, and hazards presented by, chemicals used in the process.

• Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment.

• Control measures to be taken if physical contact or airborne exposure occurs.

• Quality control for raw materials and control of hazardous chemical inventory levels.

Any special or unique hazards. e. Safety systems and their functions must be included in the operating

procedures. f. The operating instructions must be consistent with the process safety

information. g. The operating procedures must be readily accessible to employees who

work in or maintain a process.

e. _____________ f. _____________ g. _____________

e. _____________ f. _____________ g. _____________

2 The operating procedures must be reviewed as often as necessary to assure that they reflect current operating practice. At a minimum they must be certified annually and must reflect changes resulting from changes in: • Process chemicals • Technology • Equipment • Facilities

_______________

On cover page of each procedure. (In manuals or online)

Reference; OSHA 1910.119 (f) RMP Specific 40 CFR 68.69 Unit Level Requirement Responsible for


1. The consequences of deviation evaluation for Operating procedures for RMP processes must consider the potential off-site impacts to human health and the environment. If deviations could produce off-site impacts to human health and the environment, this will be noted in the procedure. The steps to correct or avoid the deviation must be explained.

_______________

_____________________

Unit Operating Procedures

2. Operating procedures must include: Discharge or release control, containment, and recovery procedures

________________

_____________________


PSM ELEMENT #5 – TRAINING UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (g) and EPA 40 CFR 68.71




1. Technician Training Program Site Training Coordinator Employee Training Files and/or Mockingbird Online Database (MBO)




1. Employees shall be trained in an overview of the process and in the operating procedures as specific in OSHA PSM. Training shall include emphasis on the specific safety and health hazards, emergency operations and safe work practices applicable to the employees’ job task.

_________________

______________

2. In lieu of initial training for those employees already involved in an operating process on May 26, 1992, an employer may certify, in writing, that the employee has the required knowledge, skills and abilities to safely carry out the duties and responsibilities, as specified in the operating procedures. This documentation is kept in each employees training file.

_________________

Employee Training Files and/or MBO

3. Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in an operating process to assure that the employee understands and adheres to the current operating procedures of a process. Unit Training Procedures

__________________

______________

4. The employer shall ascertain that each employee involved in an operating process has received and understands the training required by OSHA PSM. The Verification Process is defined by the unit training program.

__________________

______________

5. A record shall be kept which contains the identity of the employee, the date of training, and the means to verify that the employee understood the training. This is kept in the employee’s training file.

__________________

Employee’s Training Files and/or MBO

RMP-Specific 40 CFR 68.71

Unit Level Requirement Responsible for Requirement



Training requirements are the same as PSM for verification, retraining requirements, and documentation.

Same as above Same as above


PSM ELEMENT #6 - CONTRACTORS UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (h)




1. Contractor Safety Program EHS Manager LCM - Contractor Safety

2. Site Program - Site Specific/Block Orientation EHS Manager Security Policy # 5

3. Documentation of employee’s site specific orientation

EHS Manager Documentation at ABC Contractor Safety Council

4. Obtain and evaluate information regarding the contract employer’s safety performance and programs. a. Annual Review b. Document Storage c. Monthly Performance Review

a. PIC (Contractor Pre-entry Auditors) b. Procurement SM c. MAT

a. PIC Website b. PIC Website c. MAT files, Safety Dept.

BC032.002: Contractor/Agency EHS Qualifications & Oversight RCMS Work Process

5. Develop and implement safe work practices consistent to control the entrance, presence and exit of contract employers and employees.

EHS Manager

Security Proc. BCF500.001, and Contractor Safety #1,2,&4

6. Periodically evaluate the performance of contract employees in fulfilling their obligations in Process Safety Management. a. Conduct annual 7-Element audits of on-site contractors b. Conduct random audit of other contractors, based on activity data from units/safety observations.

a. EHS Annual Management Reviews/Safety Team Member - contractors b. EHS

a. Safety Dept. MAT files b. Safety Dept. files

7. Maintain a contractor employee injury/illness log related to the contractor’s work in process areas.

EHS Manager Safety Dept. files

BCF020.033 Process Safety Management and Risk Management Plan PSM ELEMENT #6 - CONTRACTORS UNIT: ______________ DATE: ______________ Reference: OSHA 1910.119 (h)

Reference: OSHA 1910.119 (h)

UNIT LEVEL REQUIREMENTS Responsible for Requirement



1. Inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractors work and the process. a. Unit Program - Block Orientation b. Documentation of employees attending block orientation for

1. Alliance Contractors 2. All other Contractors

a. ________________ b1. Contractor Supt. b2. _______________

a. _____________ b1. On-Site Contr. Office b2.____________

2. Explain to contract employees the applicable provisions of the emergency action plan. a. Site Specific orientation b. Block Orientation c. Safe Work Permit

a. See Item #1 b. See Item #1 c. Permit Issuers/ Permit Receivers

a. See Item #1 b. See Item #1 c. LCM - BCF020.001

RMP Specific 40 CFR 68.87





Requirements for Contractors under RMP are the Same as PSM See above See above


PSM ELEMENT #7 - PRE-STARTUP SAFETY REVIEW UNIT: ______________ DATE: _____________ Reference OSHA 1910/119 (i)

SITE PROGRAMS Accountable for Requirement

Location of Documentation References/Comments

1. 95% Review (Pre-Startup Program) for Capital Projects and large maintenance jobs.

EHS Manager BCF020.025 In accordance with Process Safety Management & Risk Management Program Guide on Process Safety Web Page.



1. A pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.

________________

_______________________

Documentation is kept with Project Files (Job Books) and on the EHS Change Manager Database

2. The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process: a. Construction and equipment is in accordance with design specifications; b. Safety, operation, maintenance and emergency procedures are in place

and are adequate; c. For new facilities, a process hazard analysis has been performed and

recommendations have been resolved or implemented before startup d. Modified facilities have been subject to management of change process e. Training of each employee involved in operating a process has been

completed.

a. _____________ b. _____________ c. See Element #3 and #10 d. See Element #10 e. _____________

a. ____________________ b. ____________________ c. See Element #3 & #10 d. See Element #10 e. See Element #10 (EHS Change Manager Database)


PSM ELEMENT #7 - PRE-STARTUP SAFETY REVIEW UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (i)

RMP-Specific 40 CFR 68.75 Unit Level Requirement Responsible for


The RM Plan shall be reviewed, revised, and updated as listed below. The Unit is responsible to notify the Environmental Department when changes below occur and initiate an RM Plan update. a) Within five years of its initial submission or most recent update, whichever is

later, b) No later than three years after a newly regulated substance is first listed by

EPA, c) No later than the date on which a regulated substance is first present in an

already covered process above a threshold quantity, d) No later than the date on which a regulated substance is first present above a

threshold quantity in a new process, e) Within six months of a change that requires a revised PHA or hazard review, f) Within six months of a change that requires a revised offsite consequence

analysis, (see 40 CFR 68.36, when quantities of stored material may increase or decrease the distance to the endpoint by a factor of 2 or more)

g) When a unit is no longer subject to RMP requirements a revised registration must submitted with six months.


Project Files and EHS Change Manager Database


PSM ELEMENT #8 - MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)

SITE PROGRAM Accountable for Requirement


1. Establish and implement written procedures to maintain the ongoing integrity of process equipment. a. Pressure vessels b. Storage tanks b. Piping systems & components c. Relief and vent systems and devices d. Emergency shutdown systems e. Controls (including monitoring devices and sensors, alarms and

interlocks) and f. Pumps

EHS Manager

Maintenance Director

Loss Control Manual BASF Technical Rules Web Page

Freeport Mechanical Integrity Program - BCF020.031

2. Technician training program for employees involved in maintaining the ongoing integrity of process equipment.

E&M L&D Coordinator

Employee’s Training Files and/ or MBO

3. In the construction of new plants and equipment, the employer shall ensure that equipment, as it is fabricated, is suitable for the process application for which they will be used.

EHS Manager

VP Tech Engr Svc


Freeport Mechanical Integrity Program

4. The employee shall ensure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used.

EHS Manager

Maintenance Director


Freeport Mechanical Integrity Program




Location of Documentation References /Comments

TRAINING 1. Train each employee involved in maintaining the ongoing integrity of process

equipment in an overview of that process and its hazards. Area Maintenance Mgr

_______________________

Production & E&M L&D Coordinators also supports

2. Train each BASF employee involved in maintaining the ongoing integrity of process equipment in the procedures applicable to the employee’s job task, to ensure that the employee can perform the job tasks in a safe manner.

Maintenance Supervisors

_______________________

E&M L&D Coordinator also supports

3. Train each contractor employee involved in maintaining the ongoing integrity of process equipment in the procedures applicable to the employee’s job task, to ensure that the employee can perform the job tasks in a safe manner.

Contractor Supervision

Contractor-Maintained Records

Reference: OSHA 1910.119 (j)

QUALITY ASSURANCE 1. Appropriate checks and inspections shall be performed to assure that

equipment is installed properly and consistent with design specifications and the manufacturer’s instructions. • During installations

• 95% Review (Pre-Startup)

• Non-Capital Projects

Project Manager

Project Manager

E&M

_______________________

See PSM Element #7 & #9

Equipment Files

Maintenance and Reliability Engineers need to be involved

BCF020.033 Process Safety Management and Risk Management Plan PSM ELEMENT #8 - MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)


Location of Documentation References /Comments

MECHANICAL INTEGRITY 1. Listing of PSM-affected PRESSURE VESSELS is maintained, in the

following format: (indicate the system chosen to maintain up-to-date list ) ____a. Unit-generated list or database ____b. P&ID’s

a. Mechanical

Services Group (MSG)

b. Technology Specialist

a. B-611 MSG b. Master Stick in the Control Room

2. Equipment files for Pressure Vessels are maintained. ____a. Inspection records ____b. Operations equipment files

a. Mech. Svcs. Mgr. b. Maintenance Supervisor

a. B-611 MSG b. _________________

See FP-P-ME-02, “Equipment Files” in the Maintenance Procedures Manual.

3. The design basis / requirements for existing Pressure Vessels are available. These are kept in : (indicate all that apply) ____a. Job books ____b. Equipment specifications ____c. Equipment files ____d. BASF Technical Standards

a. Technology Specialist b. Technology Specialist c. Maintenance Supervisor d. VP Tech Engr. Svcs.

a. _____________________ b. _____________________ c. _____________________ d. BASF Technical Rules

Web Page

4. The required inspections and inspection frequencies are identified for individual Pressure Vessels. (Record the “keeper” and location of the monthly printout here.)

Mech. Svcs. Mgr.

SAP Inspection types and frequencies are recorded by the E&M MSG and produced on monthly printouts

5. Procedures are available for obtaining / scheduling inspections of Pressure Vessels. (Record the “keeper” and location of the Maintenance Policies & Procedures Manual here.)

MSG Manager BASF Technical Rules Web Page

• N-G-MC-105, “Risk Based Inspection”

• Procedures are in N-P-MC-105, “Equipment Inspection Procedures” in the Maintenance Policies & TJA’s. North America Procedures and Guidelines Section




6. Pressure Vessel inspections follow good engineering practice Mech. Svcs. Mgr. See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)

• Inspection / E&Mt procedures are based on the API-510 Code, and operating / inspection experience.

• E&Mt methods are based upon ASNT-TC-1A.

7. Acceptance criteria for Pressure Vessel inspections are established.

Mech. Svcs. Mgr. See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)

The principles of the ASME Code and the National Board Inspection Code (NBIC) shall be used to determine fitness for service.

8. Procedures for Pressure Vessel repair or alteration follow good engineering practice.


Procedures are based upon the API-510 Code and the NBIC, and repair / alteration experience.

9. Documentation of Pressure Vessels: a. inspections, b. repairs c. alterations Is maintained in equipment files.

a. Mech. Svcs. Mgr. b._____________ c._____________

a. MSG Files b. Equip. Files in plant c. __________________

Official Inspection records are maintained in the MSG files. All others are the responsibility of the Owner.

10. A list of Storage Tanks is maintained. Mech. Svcs. Mgr. Maint. Equipment files/E&M MSG files

Official inspection records for registered Storage Tanks are maintained in the Mech. Group Files. Owners are responsible for all others.

11.

Equipment files for Storage Tanks are maintained. a. inspections, b. repairs c. alterations Is maintained in equipment files.

a. Mech. Svcs. Mgr. b._____________ c._____________

a. MSG Files b. Equip. Files in plant c. __________________

See FP-P-ME-02, “Equipment Files” in the Maintenance Procedures Manual.





12. The design basis / requirements for existing Storage Tanks are available. These are kept in : (indicate all that apply) ____a. Job books ____b. Equipment specifications ____c. Equipment files ____d. BASF Technical Standards

a. Technology Specialist b. Technology Specialist c. Maintenance Supervisor d. VP Tech Engr. Svcs.

a. _____________________ b. _____________________ c. _____________________ d. BASF Technical Rules Web Page

13. The required inspections and inspection frequencies are identified for individual Storage Tanks. (Record the “keeper” and location of the monthly printout here.)

MSG

SAP

Inspection types and frequencies are by the MSG, and produced on monthly printouts.

14. Procedures are available for obtaining / scheduling inspections of Storage Tanks. (Record the “keeper” and location of the Maintenance Policies & Procedures Manual here.)

MSG

Freeport E&M Web Page, Procedures and Guidelines

Procedures are in FP-P-MC-08 in the Maintenance Policies & Procedures Manual. Information for Pressure Vessels also applies to Storage Tanks.

15. Storage Tank inspections follow good engineering practice.


• Inspection / test procedures are based on the API-653 standard, and operating / inspection experience.

• Test methods are based upon ASNT-TC-1A.

16. Acceptance criteria for Storage Tank inspections are established.


The principles of the applicable API standard (12D, 12F, 650,

620, etc.) are used to determine if repairs are needed.

17. Procedures for Storage Tank repair or alteration follow good engineering practice.


Procedures are based upon the API-653 standard, and repair / alteration experience.




18. Listing of PSM-affected PIPING SYSTEMS is maintained, in the following format: (indicate the system chosen to maintain up-to-date list ) ____a. Unit-generated list or database ____b. P&ID’s

a. Mech. Svcs. Mgr. b. Technology Specialist

a. 611 MSG Files b. Master Stick in Control Rooms

19. Equipment files for registered Piping Systems are maintained.

MSG SAP Procedures are in M-P-MC-105-Stationary Equipment and Piping Systems Inspection Procedure

20. The design basis/requirements for existing Piping Systems are available. These are kept in: (indicate all that apply) ____a. Job books ____b. Equipment files ____c. Unit Pipe Service Index ____d. BASF Technical Standards ____e. Unit Line List

a._______________ b._______________ c. Technology Specialist d. NCE Design Services Manager e.________________

a.________________ b.________________ c.________________ d. BASF Technical Rules Web Page e.________________

21. The required inspections and inspection frequencies are identified for individual Piping Systems. (Record the “keeper” and location of the monthly printout here.)

Mech. Svcs. Mgr. MSG Files Inspection types and frequencies are recorded by the MSG, and produced on monthly printouts

22. Procedures are available for obtaining / scheduling inspections of Piping Systems. (Record the “keeper” and location of the Maintenance Policies & Procedures Manual here.)

Mech. Svcs. Mgr. North America E&M Web Page

Inspection types and frequencies are recorded by the MSG, and produced on monthly printouts (N-P-MC-105)

23. PIPING SYSTEM inspections follow good engineering practice.


• Inspection / test procedures are based on the API-570 Code, BASF Technical Standards, and operating / inspection experience (N-P-MC-105).

• Test methods are based upon ASNT-TC-1A and BASF Technical Standards.





24. Acceptance criteria for Piping System inspections are established.


The principles of the applicable ASME/ANSI code (B31.1, B31.3, etc), as well as BASF Technical Standard requirements are used to determine if repairs are needed.

25. Procedures for Piping System repair or alteration follow good engineering practice.


Procedures are based upon the API-570 code, and repair / alteration experience (N-G-MC-100).

26. Documentation of Piping System: a. Inspections b. repairs c. alterations

a. Mech. Svcs. Mgr. b._______________ c._______________

a. MSG Files b._______________ c._______________

Procedures are in N-P-MC-105-Stationary Equipment and Piping Systems Inspection Procedure. Are maintained in equipment files

27. A program for hose and hose fitting selection, maintenance and inspection is in place. Unit Process Hose Selection Chart

EHS Manager _______________

EHS web page Loss Control Manual _____________________

See BCF020.007, Hose and Hose Fittings

28. Listing of PSM-affected INSTRUMENTS is maintained, in the following format; (indicate the system chosen to maintain up-to-date list) Unit-generated list or database (INtools) ____

Area I&E Maintenance Engineer

INTools Identification for typical PSM instrumentation is in N-P-EI-105: Instrument PM/PdM Procedure (for example, the Safety Critical instruments of Risk Class B, C, D )

29. The design basis / requirements for existing Instruments are available. These are kept in : (indicate all that apply) ____a. Job books ____b. Equipment specifications ____c. Equipment files ____d. BASF Technical Standards

a. _____ b. Area I&E Supervisor c. Area I&E Supervisor d. NCE Design Services Director

a. _____________________ b. INTools c. _____________ d. BASF Technical Rules Web Page


PSM ELEMENT #8 – MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________ Reference: OSHA 1910.119 (j)



30. The required inspections and inspection frequencies are identified for individual Instruments, in the following format; (indicate all that apply) ____a. Unit critical instrument program ____ b. Safety instrumented systems _____c. I&E Asset management tool

a. Area Maint. Engr. & Area I&E Supervisor b. SIS Responsible Engr. & Area I&E Supervisor c. Area I&E Maint. Engr. & Area I&E Supervisor

a. INtools b.INtools c. ____________________

Procedures for typical inspection methods and inspection frequencies are in N-P-EI-105

31. Instrument inspections follow good engineering practice, utilizing the following; (indicate all that apply) __X_a. N-P-EI-105 ____b. Manufacturer’s instruction manuals ____c. Other procedures

a. NCE Instrument & Control CoE b. I/E Techs c. I/E Techs

a. BASF Technical Rules Web Page b. I/E files c. I/E files

• In-line or in-vessel Instruments shall be tested for containment per the Piping System inspection requirements.

• Function tests shall be in accordance with BASF G-P-EI-201M guidelines and manufacturer’s instruction manuals.

32. Acceptance criteria for Instrument inspections are established. NCE Instrument & Control CoE

Same as above. • In-line or in-vessel Instruments shall use Piping System acceptance criteria.

• For function testing, the manufacturer’s instruction manual, G-P-EI-201M guidelines or other test procedures will determine acceptance criteria.

33. Procedures for Instrument repair or alteration follow good engineering practice.

NCE Instrument & Control CoE

See site BCF020.031: Mechanical Integrity Program (Freeport EHS web page - LCM)

Equipment will be repaired using manufacturer’s instruction manuals / recommendations.





34. Documentation of Instrument inspections, repairs and alterations is maintained in ; (indicate all that apply) ____a. Equipment files ____b. INtools database ____c. SAP

a. I/E Techs b.______________ c.______________

a. _____________________ b.______________________ c.______________________

35. Electrical classification drawings are maintained. ____a. Drawings ____b. Chemical list that forms the basis for the drawings ____c. Written description of justifications followed

Area I/E Maintenance Engineer

a. E&M CAD files b. _____________ c. _____________

N-G-EI-902: Electrical Area Classification Guidelines for Drawings and Documents on BASF Technical Rules Web Page and NFPA 497

36. Ground grid drawings and test documentation are maintained. Area I&E Maintenance Engineer

E&M CAD files Procedure is in N-G-EI-903- Facilities Grounding Drawings and Documents BASF Technical Rules Web Page

37. Safety interlock and shutdown system descriptions and test procedures are maintained.

Area I&E Maintenance Engineer

_______________

38. UPS systems are maintained. Area I&E Supervisor ______________ Typically, system maintenance is performed by outside contractors. Scheduling of system maintenance is a BASF responsibility.

39. UPS system design basis is documented. Area I&E Maintenance Engr.

_____________

40. Listing of PSM-affected PUMPS AND ROTATING/RECIPROCATING EQUIPMENT is maintained, in the following format: (indicate the system chosen to maintain up-to-date list ) ____a. P&ID’s (Master Stick) ____b. Rotating Equipment List (SAP)

a. Production Technologist b. Area Mechanical Maint. Engr.

a. Control Room b. SAP

41. A Rotating Equipment List with pertinent reference information is maintained.

Area Mechanical Maint. Engr.

SAP





42. Equipment files are maintained for Pumps and Rotating / Reciprocating Equipment. (repair checksheets and other maintenance repair documents)

Area Rotating Equipment Supervisor

_______________________ Procedure is in N-G-MC-005: Guideline Mechanical/ Equipment Equipment Files ” on the BASF Technical Rules web page

43. The design basis / requirements for existing Pumps and Rotating / Reciprocating Equipment are available. These are kept in : (indicate all that apply) ____a. Equipment files ____b. Job books ____c. Equipment specifications ____d. BASF Technical Standards

a. Area Rotating Equipment Supervisor b. Technology Specialist c. ___________ d. NCE Design Services Director

a. _____________________ b. _____________________ c. ______________ d. BASF Technical Rules Web Page

c. reference N-P-PM-503:

Project Job Files and Job Books on BASF Technical Rules Web Page

44. Predictive and/or preventive maintenance inspections are performed on Pumps and Rotating / Reciprocating Equipment.


Equipment Files (per N-G-MC-5)

Inspection / test frequencies are determined by manufacturer’s recommendations, operating / inspection experience, repair frequency reports and repair history information.

45. Pump and Rotating / Reciprocating Equipment inspections follow good engineering and maintenance practices.

Area Mechanical Maint. & Reliability Engrs..


Inspection / test procedures are based on manufacturer’s recommendations, equipment check sheets, predictive & preventive maintenance procedures, BASF Technical Standards, and operating / inspection experience.

PSM ELEMENT #8 – MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________


Reference: OSHA 1910.119 (j)



46. Pump and Rotating / Reciprocating Equipment inspection acceptance criteria follow good engineering and Maint.enance practices.

Area Mechanical Maint. & Reliability Engrs.


• Inspection / test acceptance criteria are based upon manufacturer’s instruction manuals, Mechanical TJA’s, and BASF Technical Standard requirements. Piping System acceptance criteria apply to flange and valve connections.

47. Checksheets for Pump and Rotating / Reciprocating Equipment repairs are available.


___________________ N-G-MC-005

48. Pump and Rotating /Reciprocating Equipment repairs and alterations follow good engineering and Maint.enance practices.

Area Mechanical Maint. & Reliability Engrs.


Equipment is repaired based on manufacturer’s specifications, BASF specifications, Maintenance procedures and TJA’s, established mechanical engineering / maintenance practices, and repair / alteration experience.

49. Documentation of Pump and Rotating / Reciprocating Equipment inspections, repairs and alterations is maintained in the following format; (check all that apply) ____a. Inspection / repair reports ____b. Checksheets ____c. Equipment files

a. Area Rotating Equipment Supervisor b. Area Rotating Equipment Supervisor c. Area Rotating Equipment Supervisor

a. _____________ b. _____________ c. _____________

N-G-MC-5

50. Listing of PSM-affected VENT AND RELIEF SYSTEMS is maintained, in the following format: (indicate the system chosen to maintain up-to-date list) ____a. SAP ____b. P&ID’s

a. Mech. Svcs. Mgr. b. Technology Specialist

a. SAP b. Control Room Master Stick





51. The design basis / requirements for existing Vent and Relief Systems are available. These are kept in : (indicate all that apply) ____a. Job books ____b. Equipment files ____c. Equipment specifications ____d. Unit relief device calculations

a. Technology Specialist b. Area Fixed Equipment Supervisor c. Technology Specialist d. Area Process Eng.

a. ________________ b. ________________ c. ________________ d. _________________

• Designs are per applicable codes (ASME Code, API RP520 & RP2000, NFPA Code, etc.), equipment specification sheets, manufacturer’s recommendations, and design / operation experience.

52. The required inspections and inspection frequencies are identified for Vent and Relief Systems. (Record the “keeper” and location of the monthly printout here.)

Mech. Svcs. Mgr. ____________________ • Inspection types and frequencies are recorded by the E&M MSG, and produced on monthly printouts.

53. Procedures are available for obtaining / scheduling inspections of Vent and Relief Systems. (Record the “keeper” and location of the Maintenance Policies & Procedures Manual here.)

Mech. Svcs. Mgr. BASF Technical Rules Web Page

Procedures are in N-G-MC-110: Relief and Flashback Protection Device Inspection, FP-P-MC-09: Relief Device Inspection and FP-P-MC-12: Relief Device Shop Testing and Repair Also refer to FP-P-MC-09 and FP-P- MC-12.

54. Vent and Relief System inspections follow good engineering practice. Mech. Svcs. Mgr. See site Mechanical Integrity Program document in the Loss Control Manual

Inspection / test procedures are based on the National Board Inspection Code (NBIC), API-510 Code, and operating / inspection experience. Consult references in 53.


PSM ELEMENT #8 – MECHANICAL INTEGRITY UNIT: ______________ DATE: _____________



55. Acceptance criteria for VENT AND RELIEF SYSTEM inspections are established.

Mech. Svcs. Mgr.

See site Mechanical Integrity Program document in the Loss Control Manual

Principles of the NBIC, repair shop procedures, manufacturer’s recommendations and BASF established practices are used to determine if repairs are needed FP-P-MC-09 and FP-P-MC-12.

56. Procedures for Vent or Relief System repair or alteration follow good engineering practice.

Mech. Svcs. Mgr. See site Mechanical Integrity Program document in the Loss Control Manual

Procedures are based on NBIC, Manufacturer’s recommendations, repair shop practices, and BASF established practices.

57. Documentation of Vent and Relief Systems: a. Inspections b. Repairs c. Alterations Are maintained in equipment files.

a. Technology Specialist b. Technology Specialist c. Maintenance Supervisor

a. ___________ b. ___________ c. ___________

RMP-Specific 40 CFR 68.73

UNIT LEVEL REQUIREMENTS Responsible for Requirement



Requirements for Mechanical Integrity under RMP are the same as PSM See above See above


PSM ELEMENT #9 - HOT WORK PERMIT UNIT: ________________ DATE: ________________ Reference OSHA 1910.119(k) SITE PROGRAM Accountable for

Requirement Location of Documentation Reference/Comments

1. Safety Standard #BCF020.023: Hot Work EHS Manager Freeport EHS web page - LCM

BC032.016: Hot Work, 29 CFR 1910.252General Requirements for Welding, 29 CFR1910.119(k) Hot Work Permit, 40 CFR 68.85 Hot Work Permit (RMP)



1. The employer shall issue a hot work permit for hot work operations conducted on or near a covered process.

________________

_______________________

See Site Program above

2. The permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations ‘It shall indicate the date(s) authorized for hot work’ and identify the object on which hot work is to be performed. The permit shall be kept on file until completion of the hot work operations and permit review.

_______________________

See Site Program above





Requirements for Hot Work under RMP are the same as PSM See above See above


PSM ELEMENT #10 - MANAGEMENT OF CHANGE UNIT: _______________ DATE: _______________ Reference OSHA 1910.119(l) and EPA RMP 40 CFR 68.75 SITE REQUIREMENTS Accountable for


1 BCF020.036, “Management of Change”

EHS Manager Freeport EHS web page - LCM

Process Safety PSM/RMP Guide III Management System Elements: Management of Change



1 Implementation of procedures for managing changes (except for “replacements in kind”) in the technology of manufacturing, process chemicals, and related equipment, or a change in the procedures of operating the process and related equipment outside of the established safe operating parameters.

Sr. Production Manager/Director

Freeport EHS web page - LCM

BCF020.036: Management of Change

2 A form or checklist is used which addresses the aspects of change management required by OSHA 1910.119 (l) including: The technical basis for the proposed change; Impact of change on safety and health; Modifications to operating procedures; Necessary time period for the change; and, Authorization requirements for the proposed change. Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the process or affected part of the process.


EHS Change Manager Database

BCF020.036: Management of Change

3 Management of change forms / checklists are retained in EHS Database: Change Manager and Change Manager Archive

EHS EHS Change Manager/ Change Manager Archive Databases


PSM ELEMENT #10 - MANAGEMENT OF CHANGE UNIT: _______________ DATE: ________________ Reference OSHA 1910.119(l) and EPA RMP 40 CFR 68.75

RMP Specific 40 CFR 68.75, 68.190

REQUIREMENTS Responsible for Requirement


References / Comments

1. The RM Plan shall be reviewed, revised, and updated as listed below. The Unit is responsible to notify the EHS when changes below occur and initiate update. a) Within five years of its initial submission or most recent update, whichever is

later, b) No later than three years after a newly regulated substance is first listed by

EPA, c) No later than the date on which a regulated substance is first present in an

already covered process above a threshold quantity, d) No later than the date on which a regulated substance is first present above a

threshold quantity in a new process, e) Within six months of a change that requires a revised PHA or hazard review, f) Within six months of a change that requires a revised offsite consequence

analysis, (see 68.36, when quantities of stored material may increase or decrease the distance to the endpoint by a factor of 2 or more)

g) When a unit is no longer subject to RMP requirements a revised registration must submitted with six months.

_____________

______________________

Freeport EHS web page – Environmental : Risk Management Program


PSM ELEMENT #11 - INCIDENT INVESTIGATION UNIT: ___________________ DATE: ___________________ Reference OSHA 1910.119(m) and EPA 40 CFR 68.81 SITE REQUIREMENTS Accountable for

Requirement Location of Documentation References / Comments

1 BC032.010 Incident Notification & Reporting BCF030.003 Environmental Response and Reporting Procedure

EHS Manager EHS Manager

Link on Freeport EHS web page – LCM and Freeport EHS web page - Environmental

2 Written procedures are implemented for investigation of incidents which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals.

EHS Manager BC032.010 Incident Notification & Reporting


Requirement Location of Documentation References / Comments

1 Incident reports are developed which capture the incident information as required in OSHA 1910.119 (m).

Production Execution Manager

EHS Accident Incident Management System (AIMS) Database

2 Incident investigation reports for incidents involving or potentially involving PSM chemicals are retained for 5 years.

EHS

EHS AIMS and AIMS Archive Databases

Reference OSHA 1910.119(m) and EPA 40 CFR 68.81

RMP Specific 40 CFR 68.81 and 68.42 Unit Level Requirement Responsible for


Documentation References / Comments

1. Each Incident shall be investigated which resulted in, or could reasonably have resulted in a catastrophic release of an RMP regulated material as soon as possible but not later than 48 hours.

_____________

EHS AIMS Database

BC030.003 Environmental Response and Reporting Procedure

2. The incident investigation team shall consist of at least one person knowledgeable in the process, including a contract employee if the incident involved the work of a contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.


EHS AIMS Database

3. The report shall be reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable.


_____________________ BCF020.047: Safety Meeting and Emergency Drill (UST Requirements)

4. The investigation must include and document in addition to current required


information: a) The potential offsite impact to human health and the environment. b) Onsite impacts (injuries and significant property damage) c) Offsite impacts (injuries, evacuation, sheltering in place, property damage, and

environmental damage) d) If offsite responders were notified (fire, LEPC, i.e. Level 2 or 3) e) Duration of release, f) Weather Conditions (wind speed, wind direction, cloudy or clear, humidity,

rainfall amounts, temperature)


EHS AIMS Database


PSM ELEMENT #12 - EMERGENCY PLANNING AND RESPONSE UNIT: ________________ DATE: ________________

Reference OSHA 1910.119(n) and EPA 40 CFR 68.95 Site Program

Accountable for


Documentation References/Comments

1 The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38 (a).

EHS Manager Freeport EHS web page - Emergency Plans



1 The emergency action plan shall include procedures for handling small releases. Employees covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120 (a), (p) and (q).

_________________

_______________________

Freeport Site and Unit Emergency Plans


PSM ELEMENT #12 - EMERGENCY PLANNING AND RESPONSE UNIT: ________________ DATE: ________________ Reference OSHA 1910.119(n) and EPA 40 CFR 68.95

RMP Specific 40 CFR 68.95 Requirement Responsible for


1 The emergency response program shall include procedures for the purpose of protecting the public health and environment. This plan shall contain the following: a) Procedures for informing the public and local emergency response

agencies about accidental releases b) Documentation of proper first aid and emergency medical treatment

necessary to treat accidental human exposures, c) Procedures and measures for emergency response after an accidental

release of a regulated substance, d) Procedures for the use of emergency response equipment and for its

inspection, testing, and maintenance, e) Training for all employees in relevant procedures f) Procedures to review and update, as appropriate, the emergency

response plan to reflect changes at the stationary source and ensure that employees are informed of changes

EHS Manager EHS Manager _________________ _________________ _________________ EHS Manager/ Production Execution Manager

Freeport EHS Web page - Emergency Plans Site Emergency Plan, BCF020.009: Site Safety Rules _______________________ _______________________ __________________

Site Emergency Plan Also, see Site Emergency Plan Also, see Site Emergency Plan Site Emergency Plan BCF020:036: Management of Change

2. Site Emergency Response Plan is coordinated with local emergency response officials.

EHS Manager Freeport EHS Web page - Emergency Plans


PSM ELEMENT #13 -COMPLIANCE AUDITS UNIT: ___________________ DATE: ___________________ Reference OSHA 1910.119(o)

SITE/UNIT PROGRAM Accountable for

Requirement Type/Location of Documentation

References/Comments

1 Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.

EHS Audit Leader/Sr. Production Manager/Director

______________________

This is the Units corporate audit report.

2 The compliance audit shall be conducted by at least one person knowledgeable in the process.

EHS Audit Leader/ Sr. Production Manager/Director

Same as above Unit Participation

3 A report of the findings of the audit shall be developed.

EHS Audit Leader/ Sr. Production Manager/Director

Same as above The Sr. Production Manager/Director is responsible to see that EHS Audit Leader returns report.

4 The employer shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.


Same as above

5 Employers shall retain the two most recent compliance audit reports.


Same as above


Requirements for Compliance Audits under RMP are the same as PSM See above See above


PSM ELEMENT #14 -TRADE SECRETS UNIT: ___________________ DATE: ___________________ Reference OSHA 1910.119(p)

Site Program

Accountable for

Requirement

Type/Location of Documentation

References/Comments

1 Employers shall make all information necessary to comply with the section available to those persons responsible for compiling the process safety information (required by paragraph (d) of this section), those responsible for developing the operating procedures (required by paragraph (f) of this section), and those involved in incident investigations (required by paragraph (m) of this section), emergency planning and response (paragraph (n) of this section) and compliance audits (paragraph (o) of this section ) without regard to possible trade secret status of such information.


N/A See each of the proceeding sections and associated programs.

2 Nothing in this paragraph shall preclude the employer from requiring the persons to whom the information is made available under paragraph (p)(1) of this section to enter into confidentiality agreements not to disclose the information as set forth in 29 CFR 1910.1200.


N/A Documentation is provided.

3 Subject to the rules and procedures set forth in 29 CFR 1910.1200 (i)(1) through 1910.1200(i)(12), employees and their designated representatives shall have access to trade secret information contained within the process hazard analysis and other documents required to be developed by this standard.


N/A Documentation is provided.


PSM ELEMENT #14 -TRADE SECRETS UNIT: ___________________ DATE: ___________________ Reference OSHA 1910.119(p)


Site Program

Accountable for

Requirement

Type/Location of Documentation

References/Comments

1 A written Risk Management (RM) program that meets requirements of 40 CFR 68.

EHS Manager Freeport EHS Web Page - LCM: BCF020.033 (this document) and Freeport Environmental website

2 Submit a RM Plan for each covered process prior to June 21, 1999 and submit updates every 5 years or sooner according to requirements under Management of Change above or 40 CFR part 68.36 and 68.190. This includes all requirements under Subpart G which includes, a) Submission b) Executive Summary c) Registration d) Offsite Consequence analysis e) Five-year accident history f) Prevention Program/program 3 g) Emergency response program h) Certification i) Updates And Subpart H which includes a) Record keeping b) Availability of information to the public c) Permit content and air permitting authority requirements d) Audits

EHS Manager

Freeport EHS web page – Environmental

3 Develop and implement a management system that: a) That ensures the implementation and continuance of an RM program b) Assign a qualified person for overall responsibility for the RM

program c) When responsibility for implementing individual requirements are

assigned to persons other than the person in (b) above list the names or positions and define the line of authority.

EHS Manager Freeport EHS web page - LCM: BCF020.033: Process Safety Management and Risk Management Plan (this document)


G-R-PRS-040 ELEMENT EMPLOYEE PARTICIPATION UNIT: ___________________ DATE: ___________________ Reference G-R-PRS-040

Requirement Responsible for Requirement


N/A G-R-PRS-040 ELEMENT PROCESS SAFETY INFORMATION Reference G-R-PRS-040, Section 6.1.1 – 6.1.4



1. Process Safety documentation must be available to the Production, Maintenance and Emergency Response personnel at all times.

See this document

2. An index of the documentation shall be provided. See this document 3. Plant documentation listed under G-P-PRS-040, Section 6.1 shall be

‘As-Built’ following installation of a capital project or plant modification (MOC).

See this document

4. The documents shall be maintained in an up-to-date status and kept for the lifetime of the unit.

See this document

5. The following information shall be provided for all raw materials, products, intermediates and wastes: Material Safety Data Sheet (MSDS) for all materials that are or can be isolated.

See PSM/RMP PSI Site Requirement #2

6. Thermal Stability information, unless thermal hazard is negligible )If needed, determination of Thermal Stability / Reactivity significance

should be made together with Regional or Global Process Safety and/or BASF Safety Testing(.

See PSM/RMP PSI Unit Requirement #2f

7. Material Compatibility Information or Matrix See PSM/RMP PSI Unit Requirement #2g

8. Other relevant safety data that is not included on MSDS, e.g. ST (Staub=dust) class or Minimum ignition energy for solids

9. Process Description, including process chemistry See PSM/RMP PSI Unit Requirement #3b

10. Process Flow Diagrams (Material Flow and Energy Balance) – as applicable

See PSM/RMP PSI Unit Requirement 3a & 4g

11. Business Unit Process Safety Concept (if existing) 12. Piping and Instrumentation Diagrams (P&IDs) with equipment design

information See PSM/RMP PSI Unit

Requirement #4b. Details


of the minimum information to be included on P&IDs is provided in G-P-PRS-040, Section 6.2.

13. Site Map / Plot Plan Utilities/XA Asset Manager

Site Master Planning Files

14. Plant layout drawings 15. Equipment layout / arrangement drawings 16. Underground drawings (Piping, Electrical, Civil) 17. Operating permits issued by the Authorities 18. Calculations and drawings for fixed sprinkler and deluge systems 19. Location of underground firewater piping, hydrants, and monitors

G-R-PRS-040 PROCESS HAZARD ANALYSIS Reference G-R-PRS-040



1. Plant SHE Protection Concept for all parts of the plant including related auxillary and infrastructure features.

a. SHE Step Review documentation (Steps 0, 1, 2, 3 (as applicable), and 4 = Pre-Start up Safety Review),

b. Hazard Assessments. All copies, including previous, historical versions shall be maintained for the life of the facility.

c. The scope of all High Hazard (Step 3 Review applicable) sections of the plant shall be documented for future reference. This scope shall be designated on the applicable P&IDs.

See PSM/RMP Process Hazard Analysis Requirements

G-R-PRS-040 OPERATING PROCEDURES Reference G-R-PRS-040



1. Operating Procedures for all operating states See PSM/RMP Operating Procedures Unit Requirement 1

G-R-PRS-040 TRAINING


Reference G-R-PRS-040



1. N/A G-R-PRS-040 CONTRACTORS Reference G-R-PRS-040



1. N/A G-R-PRS-040 PRE-STARTUP SAFETY REVIEW Reference G-R-PRS-040



1. N/A G-R-PRS-040 MECHANICAL INTEGRITY Reference G-R-PRS-040



1. Interlock descriptions / logic diagrams / interlock trip limit settings See PSM/RMP Mechanical Integrity Site Requirement 1e & Unit Requirement 37

2. Testing documentation for instrumented devices See PSM/RMP Mechanical Integrity Unit Requirement 34

3. Mechanical Equipment drawings (e.g. vessel drawings) See PSM/RMP Mechanical Integrity Unit Requirement 2

4. Vessel Inventory and technical information See PSM/RMP


Vessel Inspection and Testing records (Mechanical Integrity program) Mechanical Integrity Unit Requirement 1-17

5. Piping systems a. Pipe Service Index b. Technical information, if applicable c. Inspection and testing records (Mechanical Integrity program) d. Temporary leakage treatments (e.g. piping clamps), including monitoring plans and records. (Recommended to document within MOC)

a. See PSM/RMP Mechanical Integrity Unit Requirement 20c b. & c. See PSM/RMP Mechanical Integrity Unit Requirement 18-26 d. See PSM/RMP Management of Change Requirements

6. Relief Device Inventory and technical information a. Relief Device Design Calculations including relief load calculations, PSV back pressure calculations, and documentation of all relevant relief scenarios. b. Documentation of the determination of safe discharge location, including dispersion modeling or other related input c. Relief Device Inspection and Testing Records (Mechanical Integrity program)

See PSM/RMP Mechanical Integrity Unit Requirement 50 & 51 a. See PSM/RMP Mechanical Integrity Unit Requirement 51d c. See PSM/RMP Mechanical Integrity Unit Requirement 52-57

7. Safety Instrumented Systems a. Classification of any Safety Instrumented Function (SIF) according to the requirements of G-P-EI 201M, Sections 5.2 and 6.18 b. Documentation and investigation of all failures of a Safety Instrumented Function, according to G-P-EI 201M, Section 7

a. See PSM/RMP Mechanical Integrity Unit Requirement 29& 37 b. See PSM/RMP Mechanical Integrity Unit Requirement 32

8. Motor Control schematics 9. Grounding and Bonding Diagrams; Lightning Protection concept

a. Testing and inspection of bonding and grounding systems (Mechanical Integrity program)

See PSM/RMP Mechanical Integrity Unit Requirement 36 a. See PSM/RMP Mechanical Integrity Unit Requirement 36

10. Hazardous Area Classification Drawings, Explosion Protection Document, or Ex-Zone Classification Drawings, Electrical Classification Drawings according to G-S-SF 100-4M; including determination of zone classifications both internal and external to process equipment.

See PSM/RMP Mechanical Integrity Unit Requirement 35


G-R-PRS-040 HOT WORK PERMIT Reference G-R-PRS-040



N/A G-R-PRS-040 MANAGEMENT OF CHANGE Reference G-R-PRS-040



1. Documentation of changes using Management of Change (MOC) See PSM/RMP Management of Change

2. Changes (technical and organizational) – G-P-PRS 040. All facilities described shall maintain documentation related to technical and organizational changes

See PSM/RMP Management of Change

G-R-PRS-040 INCIDENT INVESTIGATION Reference G-R-PRS-040



1. Documentation of incident investigations, corrective actions and closure of investigations

See PSM/RMP Incident Investigation

G-R-PRS-040 EMERGENCY PLANNING AND RESPONSE Reference G-R-PRS-040



1. Emergency response plan for each unit / facility See PSM/RMP Emergency Planning and Response


G-R-PRS-040 COMPLIANCE AUDITS Reference G-R-PRS-040



N/A

G-R-PRS-040 TRADE SECRETS Reference G-R-PRS-040



N/A

basf psm and risk management plan

Documents

ehs change manager database

process safety updated

ecology safety standard

freeport hub manager

clarity revised manager

title em msg group manager

management practices

corporate safety procedures