Free Proposed Consent Judgment - District Court of Delaware - Delaware

I 'Case1:05-cv-00443-GI\/IS D0cumént2-0 Filed 06/28/2005 Pag`e10f2
Appendix B

` Case 1 :05-cv-00443-Gl\/|S gg g3 Filed. 06/28/2005 Page 2 of 2 I
FpC_DE I LAYER OF PROTECTION ANALYSIS -Pa 8 1 Of-1 ·
FHIE: X){X_XXXX IIVIPLEMZENTATION PLAN g
HAP Amendment
1.0 Scope:
. l. The purpose of instituting Layer of Protection Analysis (LOPA) is to reduce the
risk of accidental releases.
_ 2. The use ofthe LOPA methodology will enhance the current Process Hazard
Analysis (PSM PHA) activity and the LOPA methodology will be imbedded in
` the existing PSM PHA procedures. . l
_ 3. LOPA is a semi-quantitative risk assessment methodology. It provides a method ` ·
` for evaluating the risk of hazard scenarios and comparing itwith risk tolerance
criteria to decide if existing safeguards are adequate, and if additional safeguards
_ _ are needed. ` _
· 4. LOPA can be viewed as an extension of PHA. Typically, it is applied after a
PHA has been performed. LOPA builds on information developed in the PHA.
_ - 5. With LOPA., safeguards are evaluated for two key characteristics: l) whether the .
. ` safeguard is effective in preventing the scenario from reaching the consequence
and 2) whether the safeguard is independent of the initiating event and the other ‘
Independent Protection Layers (IPLS). -
- - A 2.0 g LOPA Implementation Plan: .. I ... . - . ..-. . . __ - _
l.__ A qualified employee will enroll for LOPA trainingby an accredited training
I - provider such as PrimaTech or Process Improvement Institute. . i A .
_ 2. The employee trained in LOPA methodology will facilitate LOPA analysis of our
‘“ “ ‘ 2 VCM and VAM process areasalong with our PSM PHA procedure. - —
3. LOPA will be included in the SOP for PSM PHA in order to be used with all i .
tbtnre scheduled PHA activities as part of the standard methodology.
· 4. Implementation of the resulting recommendations utilizing the LOPA .
methodology will be completed in accordance with the SOP’s used for - .
I _ implementing PHA recommendations. I -
5. Any new projects will trigger a PHA according to the standard procedures for
new projects and useof the LOPA methodology will be part of the PHA.
I 3.0 Attachments: A ·
l. I Process Hazard Analysis procedure with LOPA revision
l Arraovao BY; rmaacaau Director ‘ P l REWSED DATE 1/20/05 _ -
‘ EFFECTIVE DATE: 1/20/05