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Title:

Pre-Startup Safety Reviews

Individual Unit
Procedure

Function: Health and Safety


No.:
PA-020-0028

Port Arthur, TX.

Reviewed:

Preparer:
EHS Team Member

01/2012 Effective:

Owner:
EHS Team Member

Page:

1 of 16

08/11/15 Supersedes: 04/09/09


(Rev.04)
(Rev.03)
Approver:
EHS Manager

Document Revision Change Table


Revision
Number
01
02
03
04

Revision Description

Revised By

Changed Header and Footer


Added Requirements of Attachment A for all Engineering
Projects (Attachment A Rev 1)
Revised Grounding Check Electrical Portion of Attachment A
(Attachment A Rev 2)
Revised header of Attachment A to remove BASF FINA
Petrochemicals and Sabina Petrochemicals and replaced with
BASF TOTAL Petrochemicals (Attachment A Rev 3)

VB
AHR

Revision
Date
06/08
11/08

AHR

4/09

MD

08/15

***IMPORTANT*** If printed, this is an uncontrolled copy of this document.


The current version can be viewed in the Electronic Document Management System

Title: Pre-Startup Safety Reviews

Individual Unit
Procedure

Function: Health and Safety


No.: PA-020-0028

Port Arthur, TX.

Reviewed: 01/2012

1.

Page: 2 of 16

Effective: 08/11/15 Supersedes:


(Rev.04)

04/09/09
(Rev.03)

PURPOSE
To establish minimum requirements for conducting pre-startup safety reviews (PSSRs)
prior to the startup of a new or modified process.

2.

3.

DEFINITIONS
2.1.

Pre-Startup Safety Review (PSSR)


A review of a new or modified process to confirm that the design and construction
of the new or modified process was completed in accordance with the safety
concept and the work meets all company and governmental standards. It also
confirms that the information concerning the new or modified covered process has
been properly documented and communicated.

2.2.

Process Safety Information (PSI)


Includes the following types of information:
Information pertaining to the hazards of the highly hazardous chemicals used
in the process.
Information pertaining to the technology of the process.
Information pertaining to the equipment in the process.

2.3.

MOC Coordinator
This person is the one responsible for seeing the completion of the Management
of Change (MOC). In some cases, this may be the MOC initiator or the installer.

2.4.

Levels 1, 2, 3, & 4
This is the risk level given after selecting the Risk Level Assessment method and
completing the Risk Assessment. The Risk Assessment is found in Section 3 of
the MOC and filled out by the MOC Coordinator.

SCOPE
This procedure applies to new facilities and to modified facilities when the modification is
significant enough to require a change in the process safety information.

***IMPORTANT*** If printed, this is an uncontrolled copy of this document.


The current version can be viewed in the Electronic Document Management System

Title: Pre-Startup Safety Reviews

Individual Unit
Procedure

Function: Health and Safety


No.: PA-020-0028

Port Arthur, TX.

Reviewed: 01/2012

4.

Page: 3 of 16

Effective: 08/11/15 Supersedes:


(Rev.04)

04/09/09
(Rev.03)

PROCEDURE
4.1.

PSSR Team Development


4.1.1. The PSSR can be categorized by the risk assessment found in Section 3
of the MOC database.
A.

For Level 1 & 2 changes, the team will consist of one


representative from production (exempt), maintenance (exempt or
non-exempt), and operations (non-exempt) for a total of at least 3
members.

B.

For Level 3 & 4 changes, the team will be made up of


representatives from production (exempt), maintenance (exempt or
non-exempt), operations (non-exempt), and safety and any other
applicable departments including engineering, instrument,
electrical, mechanical, and operations management and/or process
technician as designated by the area Operations Manager (OM).

C.

For all engineering projects, the team will be made up of


representatives from production (exempt), maintenance (exempt or
non-exempt), operations (non-exempt), and safety and any other
applicable departments including engineering, instrument,
electrical, mechanical, and operations management and/or process
technician as designated by the area Operations Manager (OM).

4.1.2. The PSSR team will perform a field evaluation of the installation and
complete the applicable checklist. See section 4.3.
4.1.3. If the PSSR is initiated due to an MOC, the MOC Coordinator shall
assemble the PSSR team.
4.1.4. If the PSSR is initiated due to an installation of a new facility, then the
Project Manager/Engineer shall assemble the PSSR team. For Capital
Projects, see the corporate procedure, Corporate Procedure BC032.013
Ecology & Safety Project Reviews, for additional guidance.

***IMPORTANT*** If printed, this is an uncontrolled copy of this document.


The current version can be viewed in the Electronic Document Management System

Title: Pre-Startup Safety Reviews

Individual Unit
Procedure

Function: Health and Safety


No.: PA-020-0028

Port Arthur, TX.

Reviewed: 01/2012

4.

Page: 4 of 16

Effective: 08/11/15 Supersedes:


(Rev.04)

04/09/09
(Rev.03)

PROCEDURE contd
4.2.

PSSR Checklist
4.2.1. The PSSR checklist will fall into one of three categories, similar to the
PSSR team.
A.

For Level 1 & 2 changes, the PSSR team shall use the PSSR
checklist found in Section 4 of the MOC database.

B.

For Level 3 & 4 changes, the PSSR team shall use the PSSR
checklist found in Section 4 of the MOC database and the Port
Arthur Site PSSR checklist found in Attachment 1.

C.

For Engineering Project changes, the Risk Level Assessment will


be performed. The team shall use the PSSR checklist found in
Section 4 of the MOC database and the Port Arthur site PSSR
checklist found in Attachment A. A copy of the completed
Attachment A will be copied into the MOC.

4.2.2. The MOC Coordinator shall ensure that the MOC/PSSR checklist is
completed. The Project Manager/Engineer will assist the MOC Coordinator
with the MOC/PSSR checklist for capital projects.
4.3.

PSSR Team Duties


The PSSR Team, using the applicable PSSR checklist, shall confirm prior to
startup or introduction of PSM/RMP regulated chemicals that:
All requirements under MOC have been met (if applicable).
A Process Hazard Analysis (PHA) has been performed (if required) and
recommendations have been resolved or implemented before startup.
Construction and equipment are in accordance with design specifications.
Safety, operating, maintenance and emergency procedures are in place and
are adequate.
Training of each employee involved in operating and/or maintaining the
process has been completed.

4.4.

PSSR Action Item Tracking


4.4.1. Incorrect or Incomplete Items
If, during the PSSR process, incorrect or incomplete items are found by the
PSSR team, they may be divided into two groups:

***IMPORTANT*** If printed, this is an uncontrolled copy of this document.


The current version can be viewed in the Electronic Document Management System

Title: Pre-Startup Safety Reviews

Individual Unit
Procedure

Function: Health and Safety


No.: PA-020-0028

Port Arthur, TX.

Reviewed: 01/2012

4.4

Page: 5 of 16

Effective: 08/11/15 Supersedes:


(Rev.04)

04/09/09
(Rev.03)

PSSR Action Item Tracking contd


4.4.1

4.5.

Incorrect or Incomplete Items contd

Items that must be completed or corrected before the process can


safely startup.

Items that may be completed after the process starts up.


The completion dates in both cases must be denoted on the checklist.

Startup
4.5.1. Upon completion of all before startup items, the MOC form is forwarded
to the Operating Manager of the area for approval to implement and
startup the change.

4.6.

After Startup
4.6.1

4.7.

The Project Manager or MOC Coordinator, as appropriate, shall ensure


that the after startup items are completed by the target date.

PSSR Closeout
4.7.1. The PSSR will be closed when all before and after items are completed.
4.7.2. The location of any associated supporting documentation applicable to the
items in the PSSR checklist shall be noted on the PSSR checklist or
attached to the completed PSSR.
4.7.3. The completed PSSR checklist shall be maintained with the matching
MOC for seven years.

5.

RESPONSIBILITIES
5.1.

Port Arthur Management Team


Has primary responsibility for implementation of this procedure.

5.2.

EHS Manager
Has primary responsibility for the initiation, re-issuance, administration, and/or
interpretation of this procedure.

***IMPORTANT*** If printed, this is an uncontrolled copy of this document.


The current version can be viewed in the Electronic Document Management System

Title: Pre-Startup Safety Reviews

Individual Unit
Procedure

Function: Health and Safety


No.: PA-020-0028

Port Arthur, TX.

Reviewed: 01/2012

5.

6.

Page: 6 of 16

Effective: 08/11/15 Supersedes:


(Rev.04)

04/09/09
(Rev.03)

RESPONSIBLITIES contd
5.3.

Port Arthur Employees


Have primary responsibility for adherence to procedure including identifying
deficiencies in the procedure, and identifying, reporting and correcting activities
not in compliance with the procedure.

5.4.

PSSR Team Members


Have primary responsibility for conducting a PSSR as required in accordance with
this procedure.

RELATED DOCUMENTS
6.1.

PA-020-0028_Attachment A_PSSR1-checklist

6.2.

Management of Change Procedure

6.3.

BC032.013 Ecology and Safety Project Reviews Procedure

***IMPORTANT*** If printed, this is an uncontrolled copy of this document.


The current version can be viewed in the Electronic Document Management System

PA-020-0028
BASF TOTAL Petrochemicals LLC

Attachment A

Pre-Startup Safety Review (PSSR) Checklist


ATTACHMENT A (PA-020-0028) Revision 3
Description of New or Modified Facility:

Project Title/MOC#:

Date:

Complete the PSSR Checklist after mechanical completion and prior to startup of facility.
Action Items should be entered in ACTION TRACKER database under appropriate section (Prior to or After Start-Up)
A.

Pressure/Vacuum Consideration

Item

N/A

PS

AS

Action Needed

Resp.
Target
Person Date

1. Has protection been provided against overpressure and


vacuum and is the correct size and setting relief device been
installed?
2. Is relief device discharge piping adequately braced
against reaction forces and directed away from personnel?
3. Have weep holes or drains been provided in the discharge
piping of pressure relief devices?
4. Have block valves been installed in relief device piping? If
YES are they full port valves and are they locked open?
5. Have new safety valves and rupture discs been tagged
and entered into the routine maintenance program?
6. Have provisions for cleaning relief device piping been
provided?
7. Have pressure relief device calculations been properly
documented and incorporated into the master relief device
records?
8. Have pressure relief devices been captured on safety
valve lock list?

Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up
Effective: 08/11/15

Page 7 of 16
Approved By: EHS Manager

PA-020-0028
BASF TOTAL Petrochemicals LLC

Attachment A

Pre-Startup Safety Review (PSSR) Checklist


ATTACHMENT A (PA-020-0028) Revision 3
B.

Temperature/Reaction Considerations

Item

Y N N/A

PS

AS

Action Needed

Resp.
Target
Person Date

Y N N/A

PS

AS

Action Needed

Resp.
Target
Person Date

1. Have personnel been adequately protected from contact


with hot surfaces?
2. Has potential for instrument failure (including computer
shutdown) and loss of utilities been adequately
addressed?
3. Has potential for leaks into or out of the process been
adequately addressed?
4. Has potential for improper valve set-up or operating error
been adequately addressed?
C.

Valve, Piping, and Vessel Considerations

Item
1. Have cross-tied lines (pump headers, utility lines, etc.)
been avoided where contamination, pressure, or
temperature problems are likely?
2. Has a line by line review been conducted to assure that
valves, piping, and vessels are installed as specified?
3. Are vents and drains located such that they do not
create a personnel hazard?
4. Are sample points installed and properly configured for
safe sampling?
5. Can valves and equipment be safely accessed for
operation and maintenance? Do adequate provisions
exist for cleanup and can all valves can be locked,
blinded or disconnected?
6. Are hoses and fittings the proper type and have bleedoffs been provided at hose connection points? Have
hoses been fitted with current inspection tags? Were
brittle pipe failure issues addressed?

Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up
Effective: 08/11/15

Page 8 of 16
Approved By: EHS Manager

PA-020-0028
BASF TOTAL Petrochemicals LLC

Attachment A

Pre-Startup Safety Review (PSSR) Checklist


ATTACHMENT A (PA-020-0028) Revision 3
7. Has adequate back-flow prevention been provided and
installed properly?
8. Has appropriate testing been completed to ensure
integrity of new or revised piping systems and is the
piping system adequately supported or braced?
9. Are process sight glasses, flow indicators, gauges, etc.
properly armored?
10. Have lines and vessels been clearly labeled, including
flow arrows and hazard identification symbols?
11. Has material of construction been verified to assure
correct material was received and installed as per
specifications? Were brittle pipe failure issues
addressed?
12. Has the testing fluid been properly flushed from the
piping or vessel and all test blanks and blinds been
removed?
13. Have drawings been revised to show as installed
condition?
14. Have equipment and piping been registered in the
inspection program with new inspection due dates
included? Has baseline Mechanical Integrity Inspection
been performed and documented?
15. Have valve, piping, and equipment been pressure
checked?
16. Have stress relieving requirements been met?
17. Has Risk Based Inspection evaluation and grouping
been performed as required by N-G-MC-105?

Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up
Effective: 08/11/15

Page 9 of 16
Approved By: EHS Manager

PA-020-0028
BASF TOTAL Petrochemicals LLC

Attachment A

Pre-Startup Safety Review (PSSR) Checklist


ATTACHMENT A (PA-020-0028) Revision 3

D.

Rotating and Mechanical Equipment Considerations

Item

Y N N/A

PS

AS

Action Needed

Resp.
Target
Person Date

1. Have adequate equipment guards been installed and


adequate provisions exist for clean-up, isolation, and
lock-out of equipment to perform maintenance?
2. Have deadhead pressure and seal leakage been
considered for pumps?
3. Has the rotation of equipment been checked to assure it
is correct and the lubricants and seal fluids been
properly charged?
4. Is equipment adequately labeled?
5. Are capacities of lifting equipment, floors, and hoists
clearly displayed and visible to the operator?
6. Are mechanical interlocks operating properly?
7. Has stress on machinery due to piping or nozzle loading
been addressed?
8. Has the Reliability Group been notified n order to
establish baseline vibration data or to add equipment to
oil analysis monitoring?
9. Have flex hoses or hoists been installed that must be
added to proper inspection programs?

Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up
Effective: 08/11/15

Page 10 of 16
Approved By: EHS Manager

PA-020-0028
BASF TOTAL Petrochemicals LLC

Attachment A

Pre-Startup Safety Review (PSSR) Checklist


ATTACHMENT A (PA-020-0028) Revision 3

E.

Control Systems Considerations

Item

Y N N/A

PS

AS

Action Needed

Resp.
Target
Person Date

1. Are instruments and alarms provided where necessary


and unnecessary alarms avoided?
2. Has the fail safe function of valves been properly
installed and tested and the actuator air supplies been
valved in?
3. Has the potential for interaction with existing controls
been reviewed?
4. Has the operation of interlocks, alarms, and control
loops been verified? Have Z-devices been locked and
tested?
5. Can automatic valves be properly isolated and cleaned
for servicing or removal?
6. Have provisions been made for routine maintenance?
7. Have instrument loop drawings, cause and effects
documents, and specification sheets been updated?
8. Have Z-devices been included on the lock list for
review?
9. Have analyzers been included in the PM program?
10. Have SIL calculations been performed on Z devices as
required by PA-P-EI-100?
11. Have new Gas Chromatographs or other process
stream analyzers been installed in the process that will
require scheduled calibration or inspection?

Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up
Effective: 08/11/15

Page 11 of 16
Approved By: EHS Manager

PA-020-0028
BASF TOTAL Petrochemicals LLC

Attachment A

Pre-Startup Safety Review (PSSR) Checklist


ATTACHMENT A (PA-020-0028) Revision 3
F.

Electrical System Considerations

Item

Y N N/A

PS

AS

Action Needed

Resp.
Target
Person Date

1. Have the correct electrical classification rules been


observed?
2. Have start/stop switches and electrical switchgear been
properly labeled and can electrical equipment be
isolated safely by lock-out provisions for repair work?
3. Have conduit fitting covers been installed, conduit seals
poured, and electrical equipment been adequately
protected from weather and corrosion?
4. Have electrical protective relays and safety devices been
checked for proper calibration?
5. Have electrical guards been installed and indicator lights
operating properly?
6. Has ground installation been verified against
construction drawings and tested per plant standard?
7. Are ground wires available for tank trucks, rail cars, and
drums (as required)?
8. Has electrical heat tracing been properly installed and
labeled?
9. Is critical spare equipment fed from a separate power
source?
10. Have electrical drawings been revised to reflect as
installed condition?
11. Where needed are guards provided to prevent
accidental tripping of switches?

Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up
Effective: 08/11/15

Page 12 of 16
Approved By: EHS Manager

PA-020-0028
BASF TOTAL Petrochemicals LLC

Attachment A

Pre-Startup Safety Review (PSSR) Checklist


ATTACHMENT A (PA-020-0028) Revision 3
G.

Safety/Environmental Protection

Item

Y N N/A

PS

AS

Action Needed

Resp.
Target
Person Date

1. Have inert blankets, purges, sprinklers, and fire proofing


been installed where specified?
2. Has the installation created the need for relocating or
adding fire extinguishers, fire monitors, safety showers,
eye baths, or air packs?
3. Is the lighting adequate?
4. Have tripping hazards or head knockers been avoided?
5. Do walkways and ladders provide safe access at all
levels and are walking or working surfaces level,
properly secured, and do they provide proper traction?
Are safety gates properly installed?
6. Does equipment layout provide safe access for
operation and maintenance?
7. Have elevated work requirements been met?
8. Is the work area adequately ventilated where needed?
9. Are adequate provisions made for drum and cylinder
handling?
10. Has the HAZCOM program been updated to reflect
changes in chemicals? Are MSDSs available?
11. Do signs adequately identify work area hazards and
provide proper instruction?
12. Are exit and egress routes clearly identified?
13. Have any new noise areas been created or existing
areas been made worse?
14. Has the system been reviewed to assure minimal
personnel exposure to toxic chemicals during operation
and maintenance?

Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up
Effective: 08/11/15

Page 13 of 16
Approved By: EHS Manager

PA-020-0028
BASF TOTAL Petrochemicals LLC

Attachment A

Pre-Startup Safety Review (PSSR) Checklist


ATTACHMENT A (PA-020-0028) Revision 3
15. Can hazardous materials from spills or maintenance
preparation be safely handled? Have adequate
provisions been made for disposal of all wastes? Have
waste lines been routed to appropriate sewers?
16. Will run-off water be adequately contained if it becomes
contaminated? Have all containment issues been
adequately addressed?
17. Have all environmental permits been obtained?
18. VOC Equipment List update needed (Inform LDAR)?
19. If expansion joints are being installed, have they been
added to the inspection program required by PA-P-MC103?
H.

Other Considerations

Item

Y N N/A

PS

AS

Action Needed

Resp.
Target
Person Date

1. Have all Management of Change items been completed


as required by the MOC Form?
2. Does the facility comply with all applicable engineering
standards and design specifications?
3. Were any safety problems created during construction
package?
4. Have operating procedures been written and operating
parameters established and has operator training been
conducted?
5. Have the safety and emergency procedures been
updated?
6. Has the potential impact of the change on unchanged
facilities been adequately addressed?
7. Has spare critical equipment been provided and set up in
the warehouse inventory?
8. Have maintenance procedures been updated?
9. Have all equipment files been updated?
10. Have instrument/analyzer procedures been updated?

Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up
Effective: 08/11/15

Page 14 of 16
Approved By: EHS Manager

PA-020-0028
BASF TOTAL Petrochemicals LLC

Attachment A

Pre-Startup Safety Review (PSSR) Checklist


ATTACHMENT A (PA-020-0028) Revision 3
11. Have specialty items been documented and included in
the PM program?
12. Does any new equipment installed make existing spare
parts obsolete from the storeroom or other staged
areas?
13. Has Equipment Registration along with creation of
Functional Location, spare parts, and preventive
maintenance been completed as required by PA-P-ME101?

Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up
Effective: 08/11/15

Page 15 of 16
Approved By: EHS Manager

PA-020-0028
BASF TOTAL Petrochemicals LLC

Attachment A

Pre-Startup Safety Review (PSSR) Checklist


ATTACHMENT A (PA-020-0028) Revision 3

I.

Additional Considerations

Item
1.

Y N N/A

PS

AS

Resp.
Target
Person Date

Action Needed

2.
3.
4.

The Pre-Startup Safety Review is complete and this facility/modification is ready for startup upon completion of
all PS type deficiencies.
Inspection /PSSR Team: We agree that all PSSR questions and inspections were performed to the best of our ability.
MOC Coordinator:______________________________________________
Print Name

Signature

Date of Review:_________________________

Expertise (Eng., Maint, Ops, etc.)

Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up
Effective: 08/11/15

Date

Page 16 of 16
Approved By: EHS Manager