PROCESS SAFETY MANAGEMENT - Aiha-rms

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The Use of Process Safety Management Elements on Upstream Oil & Gas Facilities A COMPONENT OF AN OH&S MANAGEMENT SYSTEM

OHS Best Management Practices OHS Management System Standards ANSI Standard for Occupational Health and Safety Management Systems (Z10) ISO Occupational Health & Safety Management System Standard (45001) API RP 75L – Guidance for the Development of a Safety and Environmental Management System for Onshore Oil and Natural Gas Production Operations and Associated Activities Standard key elements Hazard Identification Hazard Control

What Is Process Safety Management Process Safety Management (PSM) is the application of management principles and systems to the identification, understanding, and control of process hazards to protect employees, facility assets and the environment. OSHA Process Safety Management of Highly Hazardous Chemicals (29 CFR 1910.119)

Application of Rule The PSM regulation applies to facilities that have processes meeting one or both of the following criteria. The facility contains or stores: Highly hazardous toxic or reactive chemicals that exceed the established threshold quantities as listed in the regulation. A quantity in excess of 10,000-lb of a flammable liquid or gas.

Application of Rule Currently Exempts Oil and gas well drilling or servicing

Application of Rule Original PSM rule pre-amble stated that oil and gas well drilling or servicing facilities would be exempt from this rule because a separate one would be established, which was never done.

Application of Rule Currently Exempts Flammable liquid stored in atmospheric tanks or transferred, which are kept below their normal boiling point without benefit of chilling or refrigerating and are not connected to a process

Application of Rule Original intent of OSHA to include atmospheric storage tanks in PSM Excluded by a judge’s ruling in 1997.

Application of Rule Currently Exempts Oil and gas production operations

Application of Rule Following concerns raised by API about the absence of an economic analysis of the PSM impact to oil & gas production facilities, OSHA suspended enforcement of PSM Standard on these facilities.

Application of Rule Currently Exempts Normally unoccupied remote facilities (NURF) “Normally unoccupied remote facility” means a facility which is operated, maintained, or serviced by employees who visit the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility. Facilities meeting this definition are not contiguous with, and must be geographically remote from all other buildings, processes, or persons. OSHA Interpretation letter average 14 hours per week

Case for Upstream PSM Current shale plays typically have multiple well production sites Reduces “footprint” in order to lessen environmental impact Results in more complex production facilities EPA methane rules requires 95% emission control efficiency on O&G storage tanks Multiple tanks under minimal pressure ( 16 oz. to 3 lbs.) in order to improve emission collection and destruction Results in elimination of “true” atmospheric storage tanks

What Is Process Safety Management 14 Elements Application Employee Participation Process Safety Information Process Hazard Analysis Operating Procedures Employee Training Contractors Pre-Start up Safety Review Mechanical Integrity Hot Work (Non-routine Work Authorizations) Management of Change Incident Investigation Emergency Planning and Response Compliance Audits

Process Hazard Analysis PHA allows the operator to: Design facilities with safety in mind Determine locations of potential safety problems Identify corrective measures to improve safety Preplan emergency actions to be taken if safety controls fail

Process Hazard Analysis Addresses: The hazards of the process Engineering and administrative controls applicable to the hazards and their interrelationships Consequences of failure of engineering and administrative controls Consequences of failures associated with facility siting or human factors Likelihood of these failures The need to promptly resolve PHA findings and recommendations

Process Hazard Analysis Must be performed that using one of the following methods: What-If; Checklist; What-If/Checklist; Hazard and Operability Study (HAZOP); Failure Mode and Effects Analysis (FMEA); Fault Tree Analysis; or Appropriate equivalent methodology

Process Hazard Analysis PHA must be performed by a team with expertise in engineering and process operations specific to the evaluated process; along with other pertinent personnel One team member must be knowledgeable in the specific PHA methodology implemented at the site

What-If PHA Experienced personnel brainstorming a series of questions that begin, "What if ?” Each question represents a potential failure in the facility The response of the process and/or operators is evaluated to determine if a potential hazard can occur If so, the adequacy of existing safeguards is weighed against the probability and severity of the scenario to determine whether modifications to the system should be recommended

What-If PHA Perhaps the most commonly used method. One of the least structured methods: Can be used in a wide range of circumstances. Success highly dependent on experience of the analysts. Useful at any stage in the facility life cycle. Useful when focusing on change review.

PHA Example – What If PHA was generated by use of compressed produced gas to enhance well production. New equipment and tie-in points were divided into nodes and potential safety issues in each node were identified using the parameter/guideword combinations defined in the What If methodology.

PHA Example – What If From compressor to wellhead From wellhead to compressor inlet

PHA Example – What If What If Hazard Consequences Recommendations High pressure, manual isolation valves closed or valves closed on wellhead tree Overpressure piping Injury, environmental release, fire Consider adding isolation valves. Lock open isolation valves. Consider adding high pressure shutdown. Low temperature of injection gas into wellhead Downhole equipment failure Equipment damage, back side pressure, operability issues Consider adding line heater as needed. Consider adding low temp alarm. High pressure due to overheating by line heater Overpressure piping Injury, environmental release, fire Consider adding high temperature shutdown of line heater. Consider adding high pressure shutdown.

HAZOP PHA HAZard and OPerability analysis The HAZOP analysis shall address the following: The hazards associated with the process areas; Identification of any consequences of operating parameter deviations that have a potential for catastrophic consequences; Engineering and administrative controls applicable to the hazards and their interrelationships; Consequences of failure of engineering and administrative controls; Facility siting; Human Factors; Qualitative evaluation of the range of possible safety and health effects if there is a failure of controls; and A Risk Ranking of the identified hazards.

HAZOP PHA PROS: Creative, open-ended; Complete – identifies all process hazards; Rigorous, structured, yet versatile; Can identify safety and operability issues. CONS: Can be time-consuming (e.g., includes operability); Relies on having right people in the room; Does not distinguish between low probability, high consequence events (and vice versa).

PHA Example HAZOP PHA was generated by an addition of new water filtering equipment to an existing water storage and disposal facility. New equipment and tie-in points were divided into nodes and potential safety issues in each node were identified using the parameter/guideword combinations defined in the HAZOP methodology. Additionally, checklist questions were used to identify potential hazards associated with facility siting and human factors.

PHA Example #1 - HAZOP NODE #!: Flow into Filters from Pumps and flow from Filters, to Settling Tank Causes Consequences Safeguards Adequate? Recommendation Filter Plug High upstream discharge pressure, potential overpressure, release, spill. Pumps cannot exceed maximum intended pressure. No Ensure pumps have correct controls (PAHH, PALL) and that the set points for the PAHH/PALL are adequate to protect the filters, piping and tanks. Pumps not running when intended Potential upstream high liquid level, off spec product – Operational. Manual operation. Yes Potential overpressure, loss of containment, fire or explosion, personnel injury. Tank and filter vessel PSVs, Fire detection, LEL detection in filter building, Cameras with remote observation. Yes No or Less Flow High Temperature External Fire

PHA Example - HAZOP Plot Plan / Siting Checklist Question Adequate? Comment Does equipment spacing comply with company, industry, or insurance requirements? Yes Per guidelines. Are atmospheric vents for flammable or toxic material routed to a safe location (i.e., away from personnel and ignition sources)? Yes Routed to a safe location. Discuss the potential for flammable, heavier than air, vapor cloud formation: Location and height of PSV and vent discharges, tank breathing, open sumps and drains, location of ignition sources, etc. Yes LEL monitoring in sump.

PHA Example - HAZOP Human Factors Checklist Question Adequate? Comment Are there potentially hazardous conditions inside the facility such as: Inadequate lighting; trip or overhead hazards? Yes Tripping hazards to be evaluated during install, lighting will be upgraded, Hoist will be overhead hazard, to be evaluated with procedures during PSSR. Are there any concerns with emergency response such as: Inadequate number or location of ESD buttons? Yes ESD locations are adequate. Are there concerns with procedures such as: Procedures are vague, confusing, or incomplete? No Ensure Procedures are adequate for operation of the facility.

Pre-Start up Safety Review Check, double check, and review any changes, modifications, additions made in a PSM covered area – before you flip the switch: Construction and equipment is in accordance with design specifications; Safety, operating, maintenance, and emergency procedures are in place and are adequate; Recommendations from PSSR should be implemented recommendations before startup.

Pre-Start up Safety Review Question Responsible Person Does all wellhead equipment meet design specifications for pressure and temperature expected? Equipment has been constructed and installed in accordance with design. Process Safety Information is complete and in place. Engineering A Process Hazard Analysis has been completed and recommendations have been addressed and implemented. Written operating procedures are in place. (SOPs). HSE/Operations Training of affected personnel has been completed (operations, maintenance, safety, environmental, emergency responses, etc.). Commissioning activities have been completed. HSE/Operations Operations Safety and Health items have been addressed. HSE Regulatory items have been addressed. HSE Piping and instrumentation Diagram redlined. Operations All process controls calibrated and loop checked with documentation. I&E Construction Foreman/Foreman HSE/Operations HSE/Operations Yes/No/ Initials / Date NA

Pre-Start up Safety Review Question Responsible Person Are all screens, orifices, filter elements, catalyst and vessel internals in place? Have all flanges been checked for proper gaskets and torque specification? Have all construction blinds been removed? Construction Foreman/Foreman Are all PSV isolation valves locked or car-sealed open? Operations Are all PSV properly braced and vented to safe location? Construction Foreman/Foreman Have all bolts with special torque specifications been checked? Is all necessary personal protective equipment available? Construction Foreman/Foreman Is all firefighting equipment in place and operational? HSE Is all necessary first aid equipment available on site? HSE Has emergency response plan been updated or developed and training complete? HSE Construction Foreman/Foreman Construction Foreman/Foreman HSE Yes/No/ NA Initials / Date

Mechanical Integrity Develop and maintain a master list of all equipment that is important to safety of the process. Establish and implement written procedures to maintain the on-going integrity of process equipment. Establish an evaluation guidance for the equipment. Train each employee in an overview of the process, its hazards, and in the maintenance procedures to ensure employees can safely perform assigned tasks. Deficiencies in equipment that are outside acceptable limits must be corrected to assure safe operation.

Mechanical Integrity Example Pressure Relief Valve Evaluation Risk Factors Does the vessel, piping or equipment that the PRV is protecting contain water, brine, hydrogen sulfide or carbon dioxide? Is the normal operating temperature of the vessel, equipment or piping that the PRV is protecting less than -20F? Has the PRV been in service for 10 or more years? Have any Recordable Events occurred with the PRV in the last 5 years? Are there more than 1 PRV protecting the Vessel, piping or equipment that this PRV is protecting? Is the Normal Operating Pressure of the vessel, piping or equipment that the PRV is protecting less than 15 psig? Yes No N/A

Management of Change Formalized system to review and approve all changes to process areas that might affect the safety of the process. Implement written procedures to manage changes (except for "replacements in kind"). Train and provide information about the change to employees and contractors involved in operating or maintaining the changed process. Update previously documented information, operating procedures, or practices if affected by the change.

Management of Change Replacement-In-Kind (RIK) for Changes in Facilities is the exchange or replacement of one piece of equipment or component by another of similar specifications and performance characteristics (size, pressure rating, temperature rating, flow rating, metallurgy, etc.)

Management of Change Formalized review is typically done using a standardized form or software. The following considerations shall be addressed prior to placing any change in service: The technical basis for the proposed change; Impact of change on safety and health; Modifications to operating procedures; Necessary time period for the change; and, Authorization requirements for the proposed change.

Management of Change Questions Describe change and basis for change. Potential hazards or impacts to facility or environment. Is a PHA required? Has PSI been revised? P&IDs PFDs Opperating Procedures MI procedures MSDS Additional training needs? Completed? Review team and sign-offs

Summary Elements of Process Safety Management allow for a systematic means to identify and analyze potential hazards, identify existing controls, and allow for recommendations for additional controls in order to minimize or eliminate health & safety impacts. Additionally, the use of PSM elements fit very well into the requirements of the various OHS Management System Standards

What Is Process Safety Management Process Safety Management (PSM) is the application of management principles and systems to the identification, understanding, and control of process hazards to protect employees, facility assets and the environment. OSHA Process Safety Management of Highly Hazardous Chemicals (29 CFR 1910.119)

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