Q.

Will this new mitigation system really work?

A.

Your responsibility as a good corporate citizen does not include throwing your company's money into an expensive and ultimately worthless piece of hardware. Yet without hard data comparing your mitigation options, you may have no basis for making an informed decision.

Your company has made a commitment to improve the safety of your processes and reduce the risk that your operation poses to your employees and the public. You are in charge, and you're determined to get the best possible reduction in risk with the funding you have available. Here's the catch: How do you compare one mitigation option with the next? You can't afford to perform an expensive experimental trial, but you don't completely trust the manufacturer's claims, either. What do you do?

ABS Consulting can perform a study that will independently compare the effectiveness of each of your mitigation systems. This study can be simple, detailed, or anywhere in between:

Simple. In the simplest case, we would work with you to develop a representative accidental release scenario and then compare the effectiveness of each of your mitigation options using a simple modeling tool. This type of study may only involve a few staff-hours, depending on the complexity of the mitigation systems you want to evaluate. Although the results from this study may not be the most accurate, it should give you an idea of the relative effectiveness of each option.

Detailed. In the most complex case, we would identify a set of hypothetical release scenarios and compare the mitigation effectiveness for each option using sophisticated modeling tools. Such a study might involve an analysis of different meteorological conditions, an evaluation of the probability of different types of release events (mitigation systems typically perform better under certain types of release events), and/or the reliability and expected availability of each mitigation option.

Whatever level of detail is right for you, it will almost certainly be more cost effective than making your decision in the dark.

Q.

My emergency response plan didn't work when I really needed it. Where did I go wrong?

A.

The emergency response plan is not a paper exercise. It is the last line of defense against public and worker exposure to accidental hazardous material releases.

Because of the myriad regulations requiring emergency response activities, the emergency response plan too often becomes a paper behemoth that no one understands. But in an unfortunate instant it may become the most important document at your facility. Is your plan up to the challenge? The fact is, you have probably never experienced a major catastrophe at your facility. Your plan seems to work well during drills, but you just can't simulate the chaos or anticipate the actions that your employees may take in an emergency. Can you?

Perhaps not completely, but ABS Consulting can help you anticipate flaws in your emergency response plan by helping you choose several representative release scenarios and overlaying the resulting consequence analysis "footprint" on your facility's plot plan. (A "footprint" is a graphical representation of the area affected by an postulated accidental release.) This type of result can help you evaluate the safety of proposed evacuation routes and perhaps outline escape paths that are less likely to lead to injury.

And consider this for your next emergency response drill: randomly pick one of the release scenarios that ABS Consulting has analyzed, and, based on the information provided, designate anyone in the "red zone" at that time to be "incapacitated." The challenge for your employees is to safely evacuate the facility avoiding the "red zone" while your emergency responders don protective gear and help your "incapacitated" employees to safety.

Now that's a drill!

Q.

After performing all of the PHAs required by OSHA and EPA, I ended up with hundreds of oustanding recommendations. How can I possibly deal with so many?

A.

Just because the PHA team decided that a consequence is severe doesn't make it true. It is an unfortunate fact that PHA teams are often not well equipped to judge the potential consequences of postulated accidental releases.

Why? Because severe accidents rarely occur, and the PHA teams have no base of experience from which to draw. For that matter, neither do you. As a result, many companies are saddled with hundreds of outstanding PHA recommendations designed to mitigate the risks of release scenarios with grossly overstated severity.

But better safe than sorry, right? Not necessarily.

By entertaining so many low-risk improvements, the truly deserving recommendations are too often delayed indefinitely. You may be inadvertently increasing the likelihood of a severe accident by focusing your attention on recommendations that offer little, or no, risk reduction.

ABS Consulting can help. First, we can help you perform a risk reduction evaluation of your outstanding PHA recommendations. By combining your process expertise and our experience with consequence modeling, we can rank each outstanding recommendation based on its potential for risk reduction. We can then perform a more complete consequence analysis on a well-chosen sample of potential release events to better quantify the true potential severity of such events. In this way, we can help you judge the effectiveness of your recommendations. And the final report will provide you with a basis for rejecting recommendations that do not improve safety.

But that will only fix the symptoms. To ensure that you don't end up in the same position during the next revalidation cycle, we will prepare a series of charts and tables that will help calibrate future PHA teams toward the true potential severity of postulated events. In this way, you can ensure that the team doesn't become overly conservative in their severity evaluations. Furthermore, you may be able to use the information to develop severity categories that are more understandable to the teams. For example, rather than asking the team to judge whether or not a potential release could reach offsite, you could simply ask them to assess the size and duration of the potential release.

Q.

OSHA cited us for inadequately considering facility siting in our PHAs. What was I supposed to do?

A.

So far, OSHA's criteria for adequate facility siting has been "I know it when I see it." The question you have to ask yourself is "Can a release or explosion at my facility endanger my control rooms, administrative buildings, or other locations that house employees?"

To answer this question you need to know (1) where the potential release or explosion centers are, (2) how severe the release or explosion could be, (3) where the population and control centers are with respect to the release or explosion centers, and (4) how well the buildings and control rooms can withstand the overpressures or toxic clouds generated by the release.

Many facilities have chosen to perform a checklist analysis at the end of their PHA to handle this requirement, and OSHA has audited this approach without citation. But what if the checklist answer is "I don't know?" After all, do you have the expertise in house to know how severe an explosion might be if one occurred or whether or not your control room could withstand a 1-psi overpressure? Could you even determine how severe the overpressure would be at the control room?

There is only one generally acknowledged engineering standard for facility siting: the American Petroleum Institute's Recommended Practice API-RP-752. ABS Consulting can perform an RP-752 analysis that can answer all of these questions. The beauty of this approach is that it does not necessarily require an in-depth consequence analysis! It starts with a simple checklist, and if you can answer all of the checklist questions in the affirmative, then there is no need to go further. If not, then a simple screening analysis may resolve the outstanding issues satisfactorily. A full-blown consequence analysis is only necessary if there are open questions that can't be resolved any other way.

Because a facility siting study is usually performed in three stages, you have complete control over the timing and cost of the project. The initial checklist analysis may only require a few staff-days of effort, and, if further analysis is necessary, you can control the remaining stages by specifying the scope and schedule.

Q.

I just found out that we are going to be covered by EPA's RMP rule. What is this "hazard assessment" requirement?

A.

The hazard assessment that you provide to EPA will outline the worst possible event that could happen at your facility. And it will be made public.

Therefore, it must be right the first time. The hazard assessment required by the RMP rule doesn't just require you to go out and perform an analysis. It tells you what scenario you must choose, which meteorological conditions to find, how to perform the modeling, and what endpoint to apply. In short, the rule give you ample opportunity to screw it up!

The analysts at ABS Consulting have helped numerous companies of all sizes achieve compliance with the RMP rule. We offer services ranging from a quick, third-party review of your hazard assessment to actually visiting your site, helping you choose appropriate scenarios, and then modeling your worst-case and alternative release scenarios.

Now that your have an idea of what consequence analysis can do . . .