Good Engineering Practices 1

[BenjaminM]

We have a process line at our facility that uses carbon disulfide. It is a hazardous chemical covered under Risk Management Program.

This past week the EPD visited us to review our RMP. They made a few suggestions, but were very pleased that we had resolved minor issues from their prior visit two years ago.

We were missing some documentation though. First we are to document what standards our system is built too. Second we are suppose to certify our process was built following
"Good Engineering Practices".

When asked to elibrate on what they were looking for, they said they basically said they needed a "one line blanket statement" that said our system was built using "Good Engineering Practices". I could not get a good definiation of GEP from them.

Now I complete grasp the idea of using equipment within their intended tolerances, keeping pressure in a tank under the MAWP, using the proper class of instruments in a Class I, Div 1 area, and doing things that are safe and just make sense! But what the heck are GEP??

I dislike the idea of just writing some BS blanket statement. I want it to have some merit. I currently intend to get ahold of the originial design provided by the CS2 vendor and make sure everything matches up. Is there anything else I should be looking for?

Similary for documenting the standard the system was built too, what should I be looking for? That we used ANSI 150# flanges? That the tank is National board stamped? The schedule of the pipe used? The API standard used for sizing the pressure relief valve?

I really would like this to be meaningful and not set set us up for trouble down the road when the next inspector wants more than just a blanket statement. Any suggestions or could someone point me in the generaly right direction?

Thankyou all for your time and help!!

 

[dcasto]

You must select what you believe are "good engineering practices". If you state that all vessels are National Board stamped, then every vessel better be just that, nothing MORE and nothing Less. If you have a set of tables that you use for piping thickness or schedules, then use it.

It is better to say that we will use vessels with board stamps or other approved designs. Other "approved designs" must be reviewed by the MANGER of engineering or higher. This statement indicates that management of the system to to use "good engineering pratices" is in place. Hence Risk Management Program.

 

[JoeTank]

I guess it is reaaly true... no job is done until the paperwork is complete.

Joe Tank

 

[BenjaminM]

Thankyou dcasto. So basically it's just writing down what you think the correct way of doing things are, then doing them?

JoeTank your more right than you know. During their audit, it was totally a paper audit. At no point did they actually walk outside to see our tanks / reactors. For all they know we could have made it all up. They were strickly concerned with paperwork.

 

[zerosum]

myrdale,

RMP borrowed extensively from PSM to include the term "good engineering practice"

I am cut-and-pasting an extract from PSM regarding good engineering practice, and I think you can find a better description of the government's intent regarding same in the PSM regulations.

Quote:

recognized and generally accepted good engineering practice (RAGAGEP) for covered processes and are explicitly required by OSHA PSM standards such as 1910.119(d)(3)(i)(D);1 and 1910.119(d)(3)(i)(F);2 and 1910.119(j)(6)(ii).3 ther OSHA PSM standards implicitly require the employer to develop and use the original design and design intent, such as 1910.119(d)(3)(i)(A)4 and 1910.119(d)(3)(i)(C);5 1910.119(d)(3)(ii);6 and 1910.119(j)(6)(i).7

Unquote.

This may add to the confusion or not, but I think there is a bunch written about good engineering practice wrt safety and by implication, the RMP requirements for good engineering practice.

 

[dcasto]

what you need to understand is that if the EPA said doing xyz is a good engineering practice and then something happens, then the EPA could be held responsible. Thats why they will not tell you anything and they cannot even comment on your selection.

If you want to adopt some paper written by a third party about a engineering practice, will the author be held responsible if something goes wrong? Most likely. Thats why you see disclaimers by API et al.

 

[BenjaminM]

I actually picked up on the disclaimer at the begining of API 2000.

Thanks Zerosum, I think you've made it abit clearer. I've been though CFR 1910 and PSM, but let me give those sections you listed another go around. I think the "Develop a design and use that original design" is a big part of it. Shows that we put thought into the setup and carried though with what we intended to do.

Another engineer I work with said GEP are one of those nebulus things with out a clear defination. That basically any company can develop it's own standard or can use pre-defined standards such as nation fire code, etc. And that in the very end it's a paper work thing to keep lawers happy if there were ever a problem.

 

[zerosum]

myrdale,

I haven't dealt directly with PSM in a while but I have a recollection that there is a volume of work that PSM inspectors/auditors/consultants use which is maybe called 'interpretations' or FAQ some such. I believe that it is a federal document and might shed some more light on your problem. Your safety or mechanical integrity people should be able to point you to this thick volume that the auditors use, it's probably online somewhere. It could conceivably have a bit on "RAGAGEP"

 

[zerosum]

CCPS of the AiCHE has (had) a reference with a title something like: "Good Process Design Practice"

It talks about hazard reviews, FTA, FMEA, commissioning, other process safety mechanisms and how to integrate into the design process. Might be helpful if you can get a copy.

 

[rbcoulter]

Maybe one way to look at this is from a regulator's viewpoint.
If you have an incident with an applicable process, the regulator/inspector will try to find faults in your program.
They will definitely site you for not abiding by specific codes/regulations that are applicable. What if they cannot find an applicable code? IMO, this is where GEP comes in.
They will check industry practice (supplier's practice, trade group practice, etc.) to see if there is something in your engineering that is different. If something stands out, they will most likely site you for it even though is is not a codified requirement.

 

[dcasto]

i like rbcoulters responce and I've seen it in action. If you do not pick a standard, then the regulators will tell you which standard to use.