10.0PURPOSEThe purpose of Management of Change (MOC) is to detect and manage changes to the facility either in technology, design, operation, new materials, equipment or maintenance. These changes have the potential to introduce hazards into the facility. The MOC process detects the change, evaluates the hazards, manages the mitigation of the hazards, and controls the integration of the change into the facility. The purpose of this element is to manage all changes, other than Replacement in Kind prior to implementation of the change.This Management of Change policy is in compliance with the OSHA Process Safety Management (PSM), 29CFR 1910-119(l) and the EPA Process Safety Management, 40CFR 68 Section 112r requirements. 10.1DEFINITION OF CHANGEA “Change” is anything that is not a “Replacement in Kind”. “Replacement in Kind” for purposes of this policy is defined as the replacement with identical or same metallurgy, design and normal operating conditions, operating and maintenance procedures. Changes fall into the following five categories:A.TechnologyB.FacilityC.EquipmentD.ProcedureE.Raw MaterialA.CHANGES IN TECHNOLOGYChanges in technology arise whenever the technical basis for design and operation of the plant (e.g., the design/actual capacities, process chemistry, mechanical design, process control hardware/software, and instrumentation) is altered. Examples of these types of changes are:1.Non-routine changes to instrumentation, control loops, or computer programs, such as changing the range of transmitters or control valve failure position;2.Any change in safety alarm settings, interlocks, and process trips. These can include changes in alarms, instrumentation and control schemes;3.Projects to increase facility throughput or accommodate different feedstocks or products;4.Changes in operating conditions including pressures, temperatures, flow rates, equipment operating speeds, or process conditions outside of the normal operating maximum/minimum limits set in the operating procedures, Process Safety Information, or mechanical catalogues;5.Introduction of new or different process additives (for example, corrosion control agents, antifoulants, antifoam agents, new raw materials, etc.);6. Changes made in the process or mechanical design that result from a PHA; and7.Changes in resin manufacturing formulations and procedures. It is anticipated that each plant will have a list of design criteria and maximum/minimum limits (set in the operating procedures or process safety information) for each process. Each proposed change will be evaluated against this list to determine if an MOC is required. As a guideline, if the proposed change falls within the maximum/minimum limits, an MOC is not required. A proposed change can never exceed any design or normal operating range criteria without a MOC review.B.CHANGES IN FACILITIESChanges in facilities occur whenever mechanical changes are made that would not necessarily appear on a Process and Instrumentation Diagram (P&ID). These could be changes to equipment configuration, changes in material of construction, or installation of temporary facilities. Specifically, these can include the following:1.Structural changes to the unit or facility;2. Changes or modifications to fire protection and emergency response systems;3. All temporary facilities and connections including temporary utility connections; and4. Changes to utilities either in capacity, demand introduced by additions or changes in quality of performance e.g. change in operating temperature of a cooling tower or a change in load capacity beyond the capacity of the unit.C.CHANGES IN EQUIPMENTChanges in equipment arise whenever the equipment and piping involved in plant processes is altered. Some examples of this category are as follows:1.Bypass connections around equipment that is normally in service. Temporarily bypassing or disabling equipment outside of those specified in operating procedures manual, including electrical jumpers or operating an automatic control valve manually;2.Equipment changes, including the addition of new equipment and modifications of existing equipment including process equipment piping or electrical and control systems which operate outside of the design and normal operating parameters of the existing equipment;3.Changes or modifications to pressure relief devices, such as valve settings or relieving capacity, modifications of the process or equipment that cause changes in the facilitys relief requirements. These can include increased process throughput, operation at higher temperatures or pressures, increase in the size of equipment, or the addition of equipment that might contribute to greater relief requirements;4.Any replacement of equipment or components, piping, or electrical components that is not a Replacement in Kind (Replacement in Kind means with an identical part). It is