procedure for waivers

PSM/02/10 Revision: 0

Page 2 of 11 Date Prepared: Aug 1, 2006 Date Revised:

GUIDELINE FOR SAFETY / RELIABILITY SYSTEM WAIVERS

SCOPE: This Document describes the Waiver requirement for the Safety / Reliability Systems covered in EAPCL PSM Nos. 3, 4, 8, 10, & 13. The document contains: Table of Contents: Section Description Page No 01 Basis 02 02 Safety and Reliability System 03 03 Responsibilities of Cross Functions 05 04 Guidelines for Recommendation 07 05 Waiver Requirements 08 06 Waiver Process & Close Out 09 Attachments: SOC Waiver Form



SECTION 1 BASIS Process Safety Management Systems provide a well-defined system to ensure that the Site has managed the Risks to an acceptable level. To manage risk, safety / reliability system are clearly defined in PSM 3, 4, 8, 10, 13. Key systems are mentioned below:

Safety Critical System Integrity of the Process Containment Audit & Recommendations follow up system Safety Systems to Prevent Recurrence.

To ensure the integrity of these systems, guidelines have been developed to manage any deviation from standards. Some of the area which have been addressed in this document are:

1) Responsibilities of all the functions defined to ensure that interfaces work smoothly for compliance of Safety / Reliability System.

2) Different categories of recommendations defined and completion timeline for each type

assigned. Waiver/deletion requirements for dropping non-workable recommendation given.

3) Waiver requirements for different systems defined. Responsibility for preparation and

approval assigned.

4) Waiver tracking & record keeping requirements clearly defined.



SECTION 2: SAFETY & RELIABILITY SYSTEMS: Safety & Reliability Systems exist to reduce the risk associated with any Process Plant. Objective is to ensure that the risks are always in a manageable zone. Major systems which ensures this condition are mentioned below: 1) Safety Critical Devices Systems: (Ref. PSM - 7 & 7a):

Safety Critical Systems must be reliable to control the hazards which are likely to lead to a major accident with a potential for injury, fire or loss of containment. The programs to ensure the reliability of these equipment should be adhered to and in case this is not done, it is important that the associated risk are understood, properly documented and a waiver taken. These programs are: Safety Critical Instrument & Electrical Devices Reliability. PSV Calibration.

2) Mechanical Integrity Of Process Containment: (Ref. PSM- 11) Mechanical integrity of Process Containment is most important to ensure that these

equipment have the capability for the containment of the process. An inspection program provides the necessary protection against this risk. It ensures the mechanical integrity of these equipment, however at times some equipment is not inspected as per specified frequency. It is most important to understand the associated risk, properly document and a waiver taken. These programs are:

Pressure Vessel Inspection. Temporary Repair Inspection & Removal. Critical Piping Inspection. Equipment / Structure Fire Proofing Inspection.

3) Audit & Recommendations: (Ref. PSM- 4)

A Safety Review & Audit Plan provides the management with an assessment of the effectiveness of the Safety & Reliability Systems. These audits also pick the deficiencies in the system, resulting in generation of recommendations. All the recommendation should be agreed with the interface and approved by the relevant Departmental Manager, after which it is mandatory to comply with them to reduce the associated risk. Therefore it is most important that these audit and review are carried out as per SOC approved frequency and the recommendations are worked on at a high priority. However at times some audits or recommendations might not be carried out. It is most important to understand the risk, properly document and a waiver taken.



These audit and reviews are:

Process Safety Management Systems(PSMs). PHA/HAZOP. PSOI,MSOI, LSOI, E&I SOIs. Safety Critical Devices System. VCM Sphere Audit. Pre Commissioning Safety Audit. (PSSRs) Hazardous Substance Storage Survey. Quarterly emergency drills. Fire Water System Performance Test.

4) Safety System To Prevent Recurrence (IRR, Ref. PSM- 3, 10)

Safety Incidents provide valuable opportunity to learn about the break down or deficiencies in our Safety Management System. All incidents highlight the safety risks present in the system. Proper analysis generates recommendation, it is most important to complete the recommendations as these provide opportunities to rectify deficiencies to prevent recurrence.

Similarly Emergency Response Simulations give us an opportunity to identify gaps in

this crucial area and develop recommendations to improve our emergency handling capability. Therefore it is important that the recommendations are worked on at high priority. However at times understand the risk, properly document and a waiver taken.



SECTION 3: RESPONSIBILITIES OF CROSS FUNCTIONS All the Safety and Reliability System are part of the Sites Risk Management Program. The objective is to ensure that these systems are working smoothly to provide the necessary risk coverage. To ensure success on any system it is important that all the Cross Functions are clear about their responsibilities. Each system would have an owner & facilitator. Further stewardship of how the system is working would have to be done by the owner. Responsibilities of each function is given below: OWNERSHIP: All the systems should have clear ownership of a function. It would be the owners responsibility to ensure that the necessary work process are in-place for smooth running of the safety or reliability system. The ownership of a system is based on the requirements of the PSMs. FACILITATION: An important role is played by the facilitation functions for smooth working of any system. If the facilitation role is not carried out properly the whole system can fall apart. To ensure that this role is clearly understood Site would have this role clearly defined for all the system. If a system is not working properly due to failure of a facilitation function then it would be highlighted in the SOC and work on improving the work process would have to be undertaken. STEWARDSHIP: To check the health of these systems they should be stewarded in the SOC on at least half yearly basis. It would be the responsibility of the owner to steward it and get the waivers from the SOC Chairman in case of non-compliance. Note: Refer, to the attachment on the next page for the Ownership, Facilitation & Stewardship of different systems. These have been clearly spelled out to avoid any future controversies.



RESPONSIBILITIES OF CROSS FUNCTIONS

The Safety / Reliability System functional responsibilities are given below:

OWNERSHIP

FACILITATION STEWARDSHIP

SAFETY CRITICAL - PSV/PRV Calibration Operations Inspection / I&E SOC -Turbine Over Speed Trip checking Machinery group. Operations/Machinery SOC

- Safety Critical Instrument & Electrical Devices Reliability

Operations

I&E

SOC

INTEGRITY OF CONTAINMENT

- Pressure Vessel Inspection Inspection Operations/Maintenance SOC -Temporary Repairs Inspection & Removal

Inspection

Operations/Maintenance

SOC

- Critical Piping Inspection Inspection Operations/Maintenance SOC - Equipment & Structure Fire Proofing Inspection

Inspection

Operations/Maintenance

SOC

AUDITS & RECOMMENDATIONS - PSM SET All SOC - PHA/HAZOP Operations/Safety* All SOC - PSOI Operations Safety SOC - MSOI Maintenance Safety SOC - LSOI Laboratory Safety SOC - Safety Critical System Defeat Audit Operations I & E / Safety SOC - Hazardous Substance Storage Survey Warehouse/SET Inspection SOC -VE-1106 Safety Audit Operations/Safety* All SOC - Pre Commissioning Safety Audit Operations/Safety* Project Engr. SOC - Emergency Simulation (Level- I & II) Safety All SOC - Fire Water System Performance Test Process Engg SET/Maint. / Opns. SOC - SAFETY SYSTEMS TO PREVENT RECURRENCE

-Safety Incident Recommendations (IRRs)

Safety Respected Area Engineers

SOC

- Emergency Response Simulation Recommendations

Safety

ALL

SOC

Production to have lead in conducting the PHA/PSSRs. Safety to ensure that frequencies of cyclic PHA are complied and also tracks the recommendations.



SECTION 4: GUIDELINE FOR RECOMMENDATIONS Completion Date Different Surveys, Audits, PHA/HAZOP, Safety Incidents etc, result in generation of recommendations. To comply with the approved recommendation is mandatory. To ensure that all recommendations are properly & timely closed. Four broad categories have been developed. The objective is to set a timeline standard for the completion of different categories of recommendations. The definitions of each category is given below: 1) Procedural

All the safe guards which can be achieved by providing an approved procedure, standing order or instruction fall under this category.

2) Simple Jobs

Any recommendation which can be complied with by doing routine maintenance or a minor job which does not require engineering fall under this category.

3) Turnaround Jobs All the jobs which can not be handled on a running plant and can only be worked on during Shutdown or Turnaround are covered in this category.

4) Engineering Jobs Recommendations requiring engineering would fall under this category and would have

to go through the control of change protocol. Timeline Of Different Catagories CATEGORY OF JOB MAXIMUM TIME Procedural 02 months Simple Job 04 months Turnaround Job Next Turnaround / FAO Engineering Job 01 Year



SECTION 5: WAIVER REQUIREMENTS Safety & Reliability Management Program requires a well-defined system to ensure that the Site has managed the Risks to and acceptable level. To implement this philosophy, at any instance when one of the key elements is not followed as per prescribed frequency a waiver has to be initiated for approval from the SOC Chairman. Similarly, at times some recommendation might be found not workable and dropped. This change should be documented, associated risk understood & a waiver taken from SOC Chairman. Recommendations extending beyond the maximum time for a category would also require a waiver, which should be taken from the authorized persons upfront, however with a reasonable justification. Spirit of the system would be truly fulfilled if:

1. All the waivers are properly reviewed. 2. Necessary checks and evaluations done which ensure that the waiver till the

revised date will not compromise the site safety. 3. In case of any concerns, adequate measures are taken to ensure site safety.

The elements of the system for which waiver will have to be initiated as follows:

SAFETY & RELIABILITY SYSTEM OVERDUE

OWNERSHIP

SOC WAIVER INITIATION

SAFETY CRITICAL - PSV Calibration Operations Inspection - Safety Critical devices Operations I/E INTEGRITY OF CONTAINMENT

- Pressure Vessel Inspection Inspection -Temporary Repairs Removal Inspection Inspection - Critical Piping Inspection Inspection - Equipment & Structure Fire Proofing Inspection Inspection AUDITS & RECOMMENDATIONS - PSM Audit SOC SET - PHA/HAZOP Process Operations/Safety - PSOI Operations Operations - MSOI Maintenance Maintenance - E&I SOI Maint Maint. - LSOI Laboratory Laboratory - Safety Critical System Defeat audit Production Operations. -VE-1106/VE-1105 Safety Audit Production SET

- Hazardous Substance Storage Survey Safety WH - Pre-Startup Safety Review Safety Operations - Fire Water System Performance Test Process Engg Process Engg - SAFETY SYSTEMS TO PREVENT RECURRENCE - Safety Incident Recommendations SET SET - Emergency Response Sim. Recc. SET SET



SECTION 6: WAIVER PROCESS & CLOSE OUT Waivers to be initiated by the System Owner. Facilitation interfaces to give reason for non compliance to the frequency. Waiver for each item to be taken separately, the following data to be provided on the waiver document.

Last Calibrations / Testing / Inspection / Audit date. Frequency. Why it could not be done. Provide the maximum non-checking healthy life. Logic for the waiver date. Technical evaluation to be attached with the form, if required.

Final waiver document to be presented in the SOC meeting by the Owner. However, with the permission of the SOC Chairman. Waiver document can be reviewed and approved outside the formal meeting. TRACKING & CLOSE OUT: Tracking system should be in-place to monitor the status of all the waivers taken, this would ensure that the waivers are under special focus and are timely closed out. Status of the waiver should be regularly stewarded in the SOC. All waivers should be closed out with in the waiver validity date. Record of all the waivers should be kept with the safety section and the owner.



SAFETY CRITICAL SYSTEMS / INSPECTION Distribution : Original to Safety & Environment Advisor/Copy to concerned owner.

Dated: _______________ Tick mark the relevant parameter: If others, please give detail: ___________________________________________________________________ Device/Equipment Tag No:________________________ Area/Plant:____________ Recommendation/Plan :____________________________________________________________________ Frequency:_________ Last Checked Inspected/Audit date/ or Orig. Due Date:__________________ Reason for deviation from the date/frequency

__________________ _____________________ Initiated by: (Owner) Reviewed by Resp. Deptt./Unit Manager Name:________________________ Name:_______________________ Date:_________________________ Date:________________________ Waiver validity date:____________________ Logic for the waiver date:______________________________________________________________________ ___________________________________________________________________________________________ ___________________________________________________________________________________________ Therefore it is requested to waiver its Checking / Calibration / Testing / Inspection / Removal

__________________________ Approved by SOC Chairman Date: ________________

SCD T-REPINSPIRR SOC OTHERSPHA SOI

SOC WAIVER FORM

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