Title:

Pre-Startup Project Safety Review

Function: Environmental, Health and Safety

Freeport Site
Standard No.: BCF020.025 Page: 1 of 8
Reviewed: 07/16 Effective: 08/16 Supersedes: 05/15
Preparer: Owner: Approver:
Site Safety Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport
Safety

REVISION HISTORY

Revision Revision
Date Number Revision Details
07/16 5 - Added Sect. 2.4, PSSRs upon restoration of temporary MOC to
original configuration.
- Sect. 5.1 modified to require Construction Engineer/Manager for
all capital projects
- Sect. 5.1 specified 3 individuals required for PSM/RMP PSSRs
MOC 0117-EHS-16-1140.
05/15 4 -Att. 8.1 & 8.4 Modified PSSR checklists per incident 0117-UTIL-
15-0074
-5.1 Clarified minimum number of people
-3.1.3 Added exception for personnel protection insulation
-Att. 9 Clarified title
 Title:
Pre-Startup Project Safety Review

Function: Environmental, Health and Safety

Freeport Site
Standard No.: BCF020.025 Page: 2 of 8
Reviewed: 07/16 Effective: 08/16 Supersedes: 05/15
Preparer: Owner: Approver:
Site Safety Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport
Safety

1.0 PURPOSE

This document defines the procedures for preparation and execution of Pre-Startup Safety Reviews
(PSSR).

The purpose of a Pre-Startup Safety Review (also called Step 4 in capital projects) is to:

1.1 Ensure that all safety and environmental issues identified during the previous EHS
reviews (i.e., Step 0, 1, 2, 3, Process Hazard Analyses (PHA), or Management of Change
(MOC)) have been satisfactorily resolved and that the process is safe to start.

1.2 Ensure the design concepts identified in the EHS reviews have been implemented.

1.3 Ensure all applicable operating, safety, emergency and maintenance procedures,
training, and documentation have been completed prior to startup. These procedures
may need to be updated / refined after startup.

1.4 Ensure construction and equipment is in accordance with design specifications and a
punch list of safety and administrative items which need to be completed before startup is
prepared.

1.5 For changes involving the introduction of a highly hazardous chemical, ensure that the
above items have been completed prior to the introduction of highly hazardous
chemicals.

2.0 SCOPE

2.1 PSSRs shall be conducted for new facilities and for modified facilities when the
modification is significant enough to require a change in the process safety information.

2.2 PSSRs shall also be conducted for all capital projects unless they have been exempted
from the step review process per BC032.013.

2.3 For MOCs that do not meet the scope of Section 2.1 or 2.2, the MOC Coordinator should
determine whether or not a PSSR is needed.

2.4 When restoring a temporary change back to the original configuration, conduct another
PSSR if a PSSR was needed for the change to the temporary condition.
 Title:
Pre-Startup Project Safety Review

Function: Environmental, Health and Safety

Freeport Site
Standard No.: BCF020.025 Page: 3 of 8
Reviewed: 07/16 Effective: 08/16 Supersedes: 05/15
Preparer: Owner: Approver:
Site Safety Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport
Safety

3.0 DEFINITIONS

3.1 Mechanical Completion

Mechanical completion occurs when all equipment has been installed, all instruments are
installed, all wires and air lines are connected, all electrical wires are hooked up, covers
installed, conduits sealed, pre-commissioning and commissioning completed and each
system approved by the owner. Specifically this includes:

3.1.1 Rotating Equipment

The correct direction of rotation has been established with the coupling or other
drive disconnected. The necessary piping has been connected and properly
aligned. All couplings, sheaves, sprockets, etc., have been properly aligned to
within manufacturer's tolerances. Couplings, belts, chains, and guards have
been installed.

3.1.2 Pressure Vessels

Hydrostatic tests have been performed in the manufacturer's shop. Flange leak
testing has been completed as part of the pipe testing.

3.1.3 Piping

The total system has been checked with regard to conformity to the drawings
and checked that the correct interconnection between the units has been made.
The system has been successfully pressure tested. The insulation for personnel
protection has been installed except for flanges left bare for testing or locations
where it prevents an effective PSSR. Flange guards as required by the Pipe
Service Index should be in place.

3.1.4 Safety Features

Safety features are fully functional. These include, but are not limited to safety
interlocks, sprinkler systems, fall arrest systems, etc.

3.1.5 Environmental

The installations for environmental protection are complete and environmental

permits/closures are complete.
 Title:
Pre-Startup Project Safety Review

Function: Environmental, Health and Safety

Freeport Site
Standard No.: BCF020.025 Page: 4 of 8
Reviewed: 07/16 Effective: 08/16 Supersedes: 05/15
Preparer: Owner: Approver:
Site Safety Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport
Safety

3.1.6 Electrical

The installation has been checked regarding correct connections for wiring and
function.

3.1.7 Instrumentation
All installations have been checked regarding correct connections for wiring,
tubing, and function. This includes checking the opening and closing of control
valves. Alarms have been connected and calibrated. Instrument tubing has
been leak-tested including the instrument, and bubble leak-tested.

3.1.8 Site Development/Housekeeping

The site being inspected has been cleaned and all construction debris removed.
All rubbish has been hauled off and the grounds graded and ditches finished.

3.1.9 Water Rinses and Runs

Rinsing new equipment or piping with water is considered part of pre-

commissioning and can be conducted prior to the completion of the PSSR.
Running a process with water shall not be done prior to the completion of the
PSSR.

4. PROCEDURES

4.1 When the project is essentially mechanically complete (>95%), a PSSR may be
conducted.

4.1.1 It should be noted that the project should be periodically reviewed throughout the
construction phase to ensure correct installations are made as one identifies
safety concerns not previously recognized. This is the responsibility of everyone
with assigned responsibilities in the project area, including the safety hub and the
technology team.

4.1.2 Some projects that are large in scope and size, or have multiple phases, may
require a series of Pre-Startup Project Safety Reviews. Also, projects being
implemented during shutdowns may have small items that are not complete but
do not affect the safety or operation of the unit. Decisions on how to handle
these situations must be made on a case by case basis with a Pre-Startup team
and have responsibilities and dates assigned to complete the items.
 Title:
Pre-Startup Project Safety Review

Function: Environmental, Health and Safety

Freeport Site
Standard No.: BCF020.025 Page: 5 of 8
Reviewed: 07/16 Effective: 08/16 Supersedes: 05/15
Preparer: Owner: Approver:
Site Safety Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport
Safety

4.2 PSSR preparation and notification

4.2.1 Capital projects must have the following preparatory documentation submitted to
the PSSR team at least two weeks prior to the scheduled PSSR:
 Step 1 & 2 Meeting Minutes
 Checklist to be used to execute the PSSR if required by Section 6.3
 MOCs if any changes were been made after the conclusion of the step review
processes and not reviewed by the step review team
4.2.2 Non-capital projects must have the following preparatory documentation
submitted to the PSSR team prior to the scheduled PSSR:
 MOC
 Checklist to be used to execute the PSSR if required by Section 6.3

4.2.3 If the required preparatory documents are contained within an MOC, the
requirement for submission of the preparatory documents can be met by
ensuring the PSSR team members are aware of the location of the MOC.

4.3 Volatile Organic Compounds (VOC) Equipment Change

Any change (addition, deletion, or replacement) in piping, valves, pumps, compressors or

connectors in VOC service must be communicated to the Fugitive Emissions Contractor
Field Supervisor (email #FreeportLDAR) prior to the PSSR at a minimum .

4.2.3 In VOC, service is defined as a piece of equipment or piping in contact with a

stream containing 10% volatile organic compounds.

4.2.4 If a stream VOC specification changes to 10% or greater, or if a stream that is

10% VOC is reduced to less than 10%, contact the Fugitive Emissions
Contractor Field Supervisor.

4.2.5 Communicate to the Fugitive Emissions Contractor Field Supervisor changes in

operating pressures if a piece of equipment that was operating at 0.725 psi
below ambient pressure begins to operate at a higher pressure, or if a piece of
equipment begins to operate at 0.725 psi below ambient pressure that previously
was running at a higher pressure.
 Title:
Pre-Startup Project Safety Review

Function: Environmental, Health and Safety

Freeport Site
Standard No.: BCF020.025 Page: 6 of 8
Reviewed: 07/16 Effective: 08/16 Supersedes: 05/15
Preparer: Owner: Approver:
Site Safety Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport
Safety

5. ATTENDEES

5.1 Required Attendees

 Production/Manufacturing Representative
 Change Requestor or designee
 Maintenance Representative for PSM/RMP covered scope
 DOT Member for PSM/RMP covered scope
 Project Engineer / Manager for capital projects
 Construction Engineer/Manager for capital projects
 EHS Hub for capital projects <=$5M, EHS CoEs for capital projects >$5M
 Production Execution Manager for capital projects >$5M
 Construction Engineer/Manager for capital projects

One person can serve multiple roles, however

o PSM/RMP covered PSSRs must have 3 separate individuals representing the
Production/Manufacturing Representative, Maintenance Representative, and DOT
Member roles.
o Non-PSM/RMP covered PSSRs must have at least 2 separate individuals
participating.

5.2 Optional Attendees

 Maintenance Representative for non-PSM/RMP covered scope

 DOT Member for non-PSM/RMP covered scope
 Production Execution Manager for capital projects <=$5M or non-capital projects
 EHS Hub or CoE for non-capital projects
 Industrial Hygiene
 Instrument Tech or Engineer
 Technical Expertise (Chemist, etc.)

The Project Engineer or MOC Coordinator should invite the appropriate personnel from
the list of Optional Attendees above based on the scope of the change, even if personnel
are not required to attend.

6. AGENDA ITEMS

6.1 For capital projects, the Project Engineer is the chairperson and should give a brief
review of the project scope, an overview of the safety concepts resulting from the Step 1
and 2 (Step 3 if applicable) safety reviews and how these concepts have been
 Title:
Pre-Startup Project Safety Review

Function: Environmental, Health and Safety

Freeport Site
Standard No.: BCF020.025 Page: 7 of 8
Reviewed: 07/16 Effective: 08/16 Supersedes: 05/15
Preparer: Owner: Approver:
Site Safety Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport
Safety

incorporated into the project design, construction and equipment. Special emphasis
should be placed on items in the SR5/Step Review Meeting Minutes and Safety and
Loss Prevention Form F-3749.

6.2 For non-capital projects, the MOC Coordinator or delegate is the chairperson and should
give a brief review of the project scope, an overview of the safety concepts resulting from
the safety reviews and how these concepts have been incorporated into the project
design, construction and equipment. Special emphasis should be placed on items on
the MOC Tab 3 Risk.

6.3 For new facilities or complex modifications to an existing facility, a PSSR Checklist (Long
Form) shall be used. The complexity of a modification is determined by the project
engineer for capital projects or the MOC Coordinator for non-capital projects. It is best
practice to make this determination early such as during the ORBE review (typically
projects with ORBE 6 or 10 ratings are considered complex), the Step 2 review, or
during the MOC risk evaluation. Examples of PSSR Checklists (Long Forms) are in
Section 8.
6.4 For new or relocated portable buildings, containers, and tents, BCF020.036 Attachment
D Portable Building, Container, and Test checklist shall be used.

6.5 An item by item review of the MOC Checklist (Tab 4) shall be made by the review team.

6.6 The entire review team conducts a walkthrough of the project construction site to look for
equipment and construction is in accordance with design specifications, head knockers,
sharp edges and pinch points, shotgun valves, trip hazards, conduit covers in place,
insulation bands cut and tucked, shaft guards in place, housekeeping, labeling, warning
signs, etc.

6.7 Upon completion of the walkthrough, all of the review team reassembles to make sure all
deficiencies identified are incorporated into a punch list. In addition, identify any items
listed that must be completed prior to startup.

7. DOCUMENTATION

7.1 The project engineer for capital projects and the MOC Coordinator for non-capital projects
shall document the PSSR punch list, the PSSR Checklist (Long Form) if used, the PSSR
date, and the PSSR participants in the MOC.

7.2 Punch list items designated as after startup may be completed after the change is made,
but should be completed within two months unless there are extenuating circumstances.
 Title:
Pre-Startup Project Safety Review

Function: Environmental, Health and Safety

Freeport Site
Standard No.: BCF020.025 Page: 8 of 8
Reviewed: 07/16 Effective: 08/16 Supersedes: 05/15
Preparer: Owner: Approver:
Site Safety Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport
Safety

It is the responsibility of the Project Manager and Manufacturing Representative to

complete the punch list in a timely manner.

8. PSSR CHECKLIST (LONG FORM) EXAMPLES

8.1 Loss Control Checklist Example – BCF020.025 Attachment 1

8.2 PSM/RMP Guide Examples – BCF020.025 Attachment 2

8.2.1 Select Pre-Startup Safety Reviews

8.2.2 Examples 3, 4, and 5

8.3 Wyandotte Long Form Example – BCF020.025 Attachment 3

8.4 Geismar Long Form Example – BCF020.025 Attachment 4

9. OPTIONAL SHORT FORM CHECKLIST AND ATTENDEES (PSSR APPROVAL SHEET) –

BCF020.025 Attachment 5

10. FLOWCHARTS FOR DETERMINING SCOPE AND DOCUMENTATION REQUIREMENTS –

BCF020.025 Attachment 6

11. RELATED DOCUMENTS

OSHA PSM 1910.119(i)
EPA RMP 68.77
BASF PSM/RMP Guide, Pre-Startup Safety Review Section
BC032.013 Ecology & Safety Project Reviews
BCF020.036 Management of Change
BASF Process Safety Minimum Requirements
RCMS Document BWP-001 Management of Change