How to Optimize Your PSM Program | The 2 RMP Elements: 01 Hazard Assessment | Blog No. 71
- Eli Macha, President
- Apr 22
- 2 min read
[This blog series derives from a technical paper written by Eli Macha, President of Macha PSM]
2 RMP Elements
While the ammonia refrigeration industry widely recognizes the PSM regulation having 14 major program elements, experienced PSM consultants are vastly aware of two other requirements listed in the EPA’s Risk Management Program regulation.
Hazard Assessment
Not to be mistaken for the process hazard analysis, the hazard assessment is a calculation, explanation, and depiction of the worst-case and alternative case release scenarios. The low-hanging fruit for this requirement is to first ensure a hazard assessment is on file. Next, ensure the hazard assessment was completed less than five years prior.
What are some mistakes to avoid with hazard assessments? Unless an individual is well versed in the hazard assessment calculation requirements, the main area to audit here is the accuracy of the scenarios selected. Was the largest vessel chosen for the worst-case release scenario? Oftentimes, the high pressure receiver is the largest vessel, but some systems have a main suction accumulator or recirculator with a bigger capacity. Depending on its location, this might be the better vessel to use for the calculation. The alternate case scenario details should also be reviewed. If the alternate case scenario is that of a pressure relief valve (PRV) lifting, is the PRV the greatest capacity PRV installed on the system? Or, is the PRV no longer installed on the system?
If one is looking to optimize their hazard assessment, there are two options: (1) they can ensure the consultant they hire to prepare the hazard assessment has the necessary expertise or (2) they can dig into the requirements themselves. If one takes the latter route they should read the requirements of Title 40 CFR Part 68 Subpart B in detail. Next, they should read the, “Risk Management Program Guidance for Offsite Consequence Analysis,” document provided by the EPA.[1] It would also behoove careful researchers to review the, “Supplemental Risk Management Program Guidance for Ammonia Refrigeration Facilities,” which offers recommendations for worst-case and alternative case scenario selection.[2] Finally, PSM practitioners also have various courses available to them which provide a more detailed treatment of how to perform the requisite calculations and what tools to use to depict the scenarios. One such course is the Engineering Calculations for PSM and RMP offered by the University of Wisconsin-Madison which devotes a half day to calculations and tools for depicting worst-case and alternative release scenarios.
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