Fossil Generation & the Process Safety Management Standard
Transcript of Fossil Generation & the Process Safety Management Standard
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Fossil Generation & the Fossil Generation & the Process Safety Management Process Safety Management
StandardStandardEEI Occupational Safety & Health
Committee ConferenceDavid A. Hurban, PEDavid A. Hurban, PE
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The Goal of Process Safety
To provide a comprehensive management system that instills the discipline of containing and controlling chemicals from delivery to final disposition resulting in the protection of personnel, the public, and the environment.
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Keeping it Simple
A Management System to Protect People from the Hazards of the Process.
Process Safety
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What Initiated Process Safety?
• Flixborough, England 1974– Cyclohexane VCE; 28 Fatalities
• Seveso, Italy 1976– Dioxin Release; 2000 Treated
• Bohpal, India 1984– MIC Release; 3,800 Fatalities
• Pasadena, Texas 1989– Flammable Gas VCE; 23 Fatalities
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How Did The Standard Evolve?
• 55 FR 29150 Proposed Standard– Issued July 17, 1990
• Comment and Hearing Period– Ended June 5, 1991– 175 Comments, 4000 Pages Testimony
• Final Rule 29 CFR 1910.119– Issued February 24, 1994
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Potential Covered Processes for Fossil Generation
• Chlorine for Water Treatment.– TQ 1500 lbs
• Anhydrous Ammonia for ESP & Flue Gas Treatment– TQ 10,000 lbs (29CFR1910.111)
• >44% Ammonium Hydroxide for SCR NOx Reduction– TQ 15,000 lbs
• Hydrogen for Generator Cooling– TQ 10,000 lbs (29CFR1910.103)
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Implementation in Electric Industry
• Denial by maintaining inventories below threshold quantities.
• Avoidance through concentrations less than those regulated.
• Afterthought implemented by chemists and industrial hygienists.
• These approaches do not make the process safer.
Denial
Avoidance
Afterthought
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Why the Reluctance
• Hard to do• Complicated• Small Part of the Overall Plant• Make Electricity not Chemicals• Experience and Expertise• Costs $$ Money $$
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Can This Happen in Your Plant?
• An accident on January 30, 2007, at the Little General Store in Ghent, WV killedfour people and injured six others when propane gas was suddenly released through a liquid withdrawal valve during a changeover between two propane tanks. A volunteer firefighter and an EMT who responded to reports of the leak were among those killed when the propane cloud ignited, destroying the store.
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Think About Coal Dust
• On February 7, 2008, a huge explosion and fire occurred at the Imperial Sugar refinery northwest of Savannah, Georgia, causing 14 deaths and injuring 38 others, including 14 with serious and life-threatening burns. The explosion was fueled by massive accumulations of combustible sugar dustthroughout the packaging building.
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Do you Have Ammonia on Demand?
• On June 11, 2008, one worker was killed and approximately seven others were injured, during a maintenance operation on a heat exchanger. Ammonia over pressured inside the exchanger, causing it to rupture.
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Is this a Potential Hazard in our Waste Water Systems?
• On July 29, 2008, three workers died and a fourth was injured when an explosion occurred inside an 80-foot-tall storage tank at the Packaging Corporation of America (PCA) corrugated cardboard mill in Tomahawk, Wisconsin. The workers were on a catwalk above the tank and performing hot work (welding) at the time of the explosion. The storage tank held a mixture of recycled paper pulp and water.
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Elements of Process Safety
• Employee Participation
• Process Safety Information
• Process Hazards Analysis
• Operating Procedures• Training• Contractors• Pre-startup Safety
Review
• Mechanical Integrity
• Hot Work Permit
• Management of Change
• Incident Investigation• Emergency Planning• Compliance Audit• Trade Secrets
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Key Elements of Process Safety
• Employee Participation• Process Safety Information• Process Hazards Analysis• Operating Procedures• Training• Pre-startup Safety Review• Mechanical Integrity• Management of Change• Incident Investigation
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Element of ISO 9000 Quality Management Systems (QMS)
• Management Responsibility • Quality System • Order Entry • Design Control • Document and Data Control • Purchasing • Control of Customer Supplied
Products • Process Control• Product Identification and
Tractability
• Control of Nonconforming Products
• Inspection and Test Status • Control of Quality Records • Training• Corrective and Preventive Action • Servicing • Handling, Storage, Packaging,
and Delivery • Internal Quality Audits • Statistical Techniques• Inspection and Testing Control of
Inspection, Measuring, and Test Equipment
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Key Elements of a QMS
• Management Responsibility • Design Control • Document and Data Control • Purchasing • Process Control• Product Identification and Tractability• Control of Nonconforming Products • Training• Corrective and Preventive Action • Inspection and Testing Control of Inspection,
Measuring, and Test Equipment
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How These Compare
• Employee Participation• Process Safety
Information• Process Hazards Analysis• Operating Procedures• Training• Pre-startup Safety Review• Mechanical Integrity• Management of Change• Incident Investigation
• Management Responsibility • Design Control • Document and Data Control • Purchasing • Process Control• Product Identification and
Tractability• Control of Nonconforming
Products • Training• Corrective and Preventive Action • Inspection and Testing Control of
Inspection, Measuring, and Test Equipment
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Take Home Message
• Occupational Safety Protects People from Hazards in the Workplace
• Quality Management Protects the Customers from Defects and Manufacturers from Rework
• Process Safety Protects People from the Process
• They Share the Same Fundamental Building Blocks
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Protect Your People From These Processes
• High Pressure High Temperature Steam• Explosive & Flammable Hydrogen• Toxic Ammonia & Chlorine Vapors• Reactive & Corrosive Acids & Caustics• Combustible Fuel Oil• Large Volumes of Natural Gas• Hot Sulfur• Coal Dust