Background - hdbk11010021

DOE-HDBK-1101-96

many or all PSM elements. However, the minimum requirements for the PSM Rule must be met if

the SAR is to be the source of PSM documentation for a covered process.

1.2 Background

Historically, chemical process hazards within the DOE complex have been considered relatively

minor compared to nuclear hazards. Prior to the promulgation of the PSM Rule, HHCs were

generally viewed as standard industrial hazards unless they could potentially affect the nuclear

inventory of a facility. Thus, consideration of chemical releases in safety analysis documents is a

relatively recent practice within DOE. DOE policies and Orders have not provided an integrated

approach to chemical process safety management. While some PSM elements were in place within

DOE, they were designed for nuclear rather than chemical process safety.

The PSM Rule, which was issued February 24, 1992, addresses chemical process hazards by

redefining the minimum management program requirements for quantities of certain HHCs that

equal or exceed specified threshold quantities (TQs). DOE O 440.1, WORKER PROTECTION

MANAGEMENT FOR DOE FEDERAL AND CONTRACTOR EMPLOYEES, requires that

covered chemical processes within DOE comply with the PSM Rule. Where DOE contractors have

many complex processes covered by the PSM Rule, the PSI and PrHA elements may be phased in

over 5 years (no later than May 26, 1997). Refresher training and compliance audits must be com-

pleted at least every three years, with initial refresher training and audits completed by May 26,

1995. All other elements were required to be fully implemented by May 26, 1992. New

construction of covered processes shall implement the applicable elements of the PSM Rule as the

life cycle progresses.

DOE contractors that are not in compliance with the PSM Rule should have implementation plans in

place to outline their "good faith" efforts to come into compliance as soon as possible. In addition,

contractors should be able to show consistent progress toward meeting their implementation plans.

1.3 Application

The PSM Rule applies to "processes" rather than to "plants" [Q1, Q2, Q3]. The definition of pro-

cess given in the glossary indicates that chemical quantities in distinct and separate processes may

be compared individually, rather than collectively, to the threshold quantity (TQ) [Q4, glossary

definition of process]. The PSM Rule applies to any process that meets the following criteria.

The process contains the specified TQ or more, by weight, of any of the 137 listed HHCs

[Q5, Q6, Q7]. (OSHA's toxic and reactive HHCs and their respective TQs are provided in

Appendix A.)

The process contains 10,000 pounds or more of a flammable HHC (liquid or gas, or mixture

of flammable liquids or gases) [Q8, Q9], in one location, with the following exceptions.

1) When a hydrocarbon fuel is used exclusively onsite, the PSM Rule does not apply so long

as the fuel is not a part of a process containing another highly hazardous material covered by

the Rule [Q10].

2) The PSM Rule also does not apply to flammable liquids that are stored in atmospheric

tanks [Q11, Q12, Q13, Q14, Q15] or transferred through associated piping when those