Process Safety Management of Highly Hazardous & Explosive ... · PDF fileProcess Safety...

Process Safety Management of Highly Hazardous & Explosive Chemicals

Process Safety Management of Highly Hazardous & Explosive Chemicals

Operating ProceduresOperating Procedures

Now that the PHA’s Are Competed or Underway…Now that the PHA’s Are

Competed or Underway… Operating Procedures

& Safety Programs Must Be Developed

PHA Information Can Be Used

Operating Procedures & Safety Programs Must Be Developed

PHA Information Can Be Used

Operating ProceduresOperating Procedures1910.119(f)

The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall

address at least the following elements.

1910.119(f)The employer shall develop and

implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall

address at least the following elements.

Operating Procedures & Safety Programs Must Consider:

Operating Procedures & Safety Programs Must Consider:

Initial start-up Normal operations Temporary operations Emergency shutdown Emergency operations Normal shutdown Start-up following turnaround Consequences of deviation Steps required to correct or avoid deviation

Initial start-up Normal operations Temporary operations Emergency shutdown Emergency operations Normal shutdown Start-up following turnaround Consequences of deviation Steps required to correct or avoid deviation

Operating Procedures or Standard Operating Procedures

(SOP’s)

Operating Procedures or Standard Operating Procedures

(SOP’s) Where Did This Methodology Come From?

Answer: The Military

Definition: A standard operating procedure is a set of instructions having the force of a directive, covering those features of operations that lend themselves to a definite or standardized procedure without loss of effectiveness. Standard Operating Policies and Procedures can be effective catalysts to drive performance improvement and improving organizational results. Every good quality system is based on its standard operating procedures (SOPs).

Where Did This Methodology Come From?

Answer: The Military

Definition: A standard operating procedure is a set of instructions having the force of a directive, covering those features of operations that lend themselves to a definite or standardized procedure without loss of effectiveness. Standard Operating Policies and Procedures can be effective catalysts to drive performance improvement and improving organizational results. Every good quality system is based on its standard operating procedures (SOPs).

*Must be Readily accessible to employees

Operating ProceduresOperating Procedures Develop and implement written operating procedures*

consistent with the process safety information and addresses at least the following elements:

Initial start-up, normal and temporary operations

Normal and emergency shut-down procedures

Operating limits and consequences of deviation

Hazards presented by the process


The operating procedures addressing operating parameters will contain operating instructions about: pressure limits temperature ranges flow rates…and what to do when an upset condition occurs what alarms and instruments are pertinent if an upset

condition occurs, and other subjects.

The operating procedures addressing operating parameters will contain operating instructions about: pressure limits temperature ranges flow rates…and what to do when an upset condition occurs what alarms and instruments are pertinent if an upset

condition occurs, and other subjects.

Operating ProceduresMany Covered Processes are Operated by Automated &

Manual Procedures

Operating ProceduresMany Covered Processes are Operated by Automated &

Manual Procedures

Operating ProceduresOperators Must be Trained in Software UseOperating Procedures

Operators Must be Trained in Software Use


Must Provide Procedures for Controlling the Process


Compliance Directive Asks: Do written operating procedures exist for each

covered process? Do the procedures provide clear instructions for conducting activities safely?

Do the operating instructions address, as a minimum, step for each operating phase?

Compliance Directive Asks: Do written operating procedures exist for each

covered process? Do the procedures provide clear instructions for conducting activities safely?

Do the operating instructions address, as a minimum, step for each operating phase?


Compliance Directive Asks: Do the operating procedures include

operating limits that outline consequences of process deviation and steps required to correct or avoid deviations?

Compliance Directive Asks: Do the operating procedures include

operating limits that outline consequences of process deviation and steps required to correct or avoid deviations?

Operating ProceduresOperating Procedures Compliance Directive Asks:

Have safety and health considerations been included in the operating procedures?

Properties of, and hazards presented by, chemicals used in the process?

Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment?

Control measures to be taken if physical contact or airborne exposure occurs?

Quality control for raw materials and control of hazardous chemical inventory levels?

Any special or unique hazards?

Compliance Directive Asks: Have safety and health considerations been included

in the operating procedures? Properties of, and hazards presented by, chemicals

used in the process? Precautions necessary to prevent exposure, including

engineering controls, administrative controls, and personal protective equipment?

Control measures to be taken if physical contact or airborne exposure occurs?

Quality control for raw materials and control of hazardous chemical inventory levels?

Any special or unique hazards?


From the OSHA PSM NEP for “Refineries” Information typically listed in EOP and/or ESP

includes, but is not limited to the responsibilities for performing actions during an emergency, required PPE, additional hazards not present during normal operations, consequences of operating outside operating limits, steps to shutdown the involved process in the safest, most direct manner, conditions when operators must invoke the emergency response plan, or scenarios when they themselves must stop and evacuate.

From the OSHA PSM NEP for “Refineries” Information typically listed in EOP and/or ESP

includes, but is not limited to the responsibilities for performing actions during an emergency, required PPE, additional hazards not present during normal operations, consequences of operating outside operating limits, steps to shutdown the involved process in the safest, most direct manner, conditions when operators must invoke the emergency response plan, or scenarios when they themselves must stop and evacuate.


From the OSHA PSM NEP for “Refineries” From interviews with at least three control

board operators in the Selected Unit(s), have these operators received sufficient training, initial and refresher, to be qualified to shutdown the Selected Unit(s) per the requirements of 119(f)(1)(i)(D)?

From the OSHA PSM NEP for “Refineries” From interviews with at least three control

board operators in the Selected Unit(s), have these operators received sufficient training, initial and refresher, to be qualified to shutdown the Selected Unit(s) per the requirements of 119(f)(1)(i)(D)?

Operating Procedures - Start Up…We Must


Describe normal SOP's

Describe start-up SOP's

Describe Shut-down SOP’s

Describe normal SOP's

Describe start-up SOP's

Describe Shut-down SOP’s


Company Must Have a Method for Developing Procedures With Elements Such As: SOP Preparation SOP Review and Approval Frequency of Revisions and Reviews Checklists Document Control SOP Document Tracking and Archival Standardized Format

Company Must Have a Method for Developing Procedures With Elements Such As: SOP Preparation SOP Review and Approval Frequency of Revisions and Reviews Checklists Document Control SOP Document Tracking and Archival Standardized Format

Include Sections such as: Objectives Purpose Concerns Procedures Department Operator Equipment Involved Location Related Documents

Include Sections such as: Objectives Purpose Concerns Procedures Department Operator Equipment Involved Location Related Documents



Operating ProceduresLet’s Look at an Example

Operating ProceduresLet’s Look at an Example

Operating Procedure for NASA E-Complex

1.0 INTRODUCTION1.1 PURPOSE

The purpose of this procedure is to establish a step-by-step detailed method for assuring a safe transfer of liquid hydrogen at the E-1 facility low pressure liquid hydrogen transfer and storage system by purging/inerting and transfer of liquid hydrogen from trucks at the trailer transfer stations to the liquid hydrogen storage sphere.

1.2 SCOPE

This procedure contains only those instructions pertaining directly with control of the systems configuration to perform necessary purging/inerting of the system to assure elimination of oxygen and the transfer of liquid hydrogen. The LH2 will be transferred from trailers to the liquid hydrogen (LH2) storage sphere. The procedure contains instruction for

a. Facility Status/Set Upb. Pre-transfer Purging/Inertingc. Liquid Hydrogen Transferd. Facility Securing/Shutdown

Operating Procedure for NASA E-Complex

1.0 INTRODUCTION1.1 PURPOSE

The purpose of this procedure is to establish a step-by-step detailed method for assuring a safe transfer of liquid hydrogen at the E-1 facility low pressure liquid hydrogen transfer and storage system by purging/inerting and transfer of liquid hydrogen from trucks at the trailer transfer stations to the liquid hydrogen storage sphere.

1.2 SCOPE

This procedure contains only those instructions pertaining directly with control of the systems configuration to perform necessary purging/inerting of the system to assure elimination of oxygen and the transfer of liquid hydrogen. The LH2 will be transferred from trailers to the liquid hydrogen (LH2) storage sphere. The procedure contains instruction for

a. Facility Status/Set Upb. Pre-transfer Purging/Inertingc. Liquid Hydrogen Transferd. Facility Securing/Shutdown

1.0 REFERENCES

2.1 DOCUMENTS SSP-8715-0001 John C. Stennis Space Center Safety and Health Handbook SSTD-8070-0089-FLUIDS SSC Facility Cleanliness Requirements for Propellant,

Gas and Hydraulic Systems SOI-8080-0027 Preparation and Use of Detailed Operating Procedures (DOP) SOI-8080-0030 Contamination Prevention, Field Cleaning and Temporary

Closures STP-8830-0012 John C. Stennis Space Center Technical Procedure Commodity

Receipt and inspection

2.2 DRAWINGS PSK-E1-1001-FAC, Sheet 1 – LH Trailer Unloading Storage and Transfer Piping

and Instrument Diagram PSK-E1-9001-FAC, Sheet 9 – E1 LH2 Storage Area MFP

1.0 REFERENCES

2.1 DOCUMENTS SSP-8715-0001 John C. Stennis Space Center Safety and Health Handbook SSTD-8070-0089-FLUIDS SSC Facility Cleanliness Requirements for Propellant,

Gas and Hydraulic Systems SOI-8080-0027 Preparation and Use of Detailed Operating Procedures (DOP) SOI-8080-0030 Contamination Prevention, Field Cleaning and Temporary

Closures STP-8830-0012 John C. Stennis Space Center Technical Procedure Commodity

Receipt and inspection

2.2 DRAWINGS PSK-E1-1001-FAC, Sheet 1 – LH Trailer Unloading Storage and Transfer Piping

and Instrument Diagram PSK-E1-9001-FAC, Sheet 9 – E1 LH2 Storage Area MFP

3.0 RESPONSIBILITIES

3.1 Personnel

3.1.1 Test Team

The Test Stand Director shall be responsible for the operations as outlined in the procedure and personnel requirements. Personnel must either be certified per the requirements or be approved as trainees. The number of Test Operations personnel required to perform the operating tasks and functions set forth in this procedure is three. The test team shall comprise of the test conductor, two LH2 Storage Area Valve Operators and an LH2 Trailer crew. Any change in the number of personnel must be approved by the Test Stand Director or supervisor.

3.1.2 Sign-Off Instructions

The assigned personnel performing this DOP shall buy off each Step upon completion on the buy off sheet.

3.0 RESPONSIBILITIES

3.1 Personnel

3.1.1 Test Team

The Test Stand Director shall be responsible for the operations as outlined in the procedure and personnel requirements. Personnel must either be certified per the requirements or be approved as trainees. The number of Test Operations personnel required to perform the operating tasks and functions set forth in this procedure is three. The test team shall comprise of the test conductor, two LH2 Storage Area Valve Operators and an LH2 Trailer crew. Any change in the number of personnel must be approved by the Test Stand Director or supervisor.

3.1.2 Sign-Off Instructions

The assigned personnel performing this DOP shall buy off each Step upon completion on the buy off sheet.

3.2 Safety

3.2.1 General Personnel Safety

The test conductor shall be responsible for ensuring compliance with established safety policies and practices by the personnel in the team during the performance of this procedure. Safe working conditions and personnel compliance with applicable safety rules and regulations is the responsibility of safety personnel.

3.2.2 Hazard Control

In the event of system and/or component leaks, malfunctions and/or failures that occur during the performance of this procedure, the test conductor shall ensure that systems are secured per the Lockout/Tagout provisions of the SSC Safety and Health Procedures and Guidelines, and that no residual energy hazards are present prior to inspections or repairs.

The primary hazards associated with this procedure are: a. Bodily exposure to a cryogen b. Bodily exposure to a hydrogen flame

3.2 Safety

3.2.1 General Personnel Safety

The test conductor shall be responsible for ensuring compliance with established safety policies and practices by the personnel in the team during the performance of this procedure. Safe working conditions and personnel compliance with applicable safety rules and regulations is the responsibility of safety personnel.

3.2.2 Hazard Control

In the event of system and/or component leaks, malfunctions and/or failures that occur during the performance of this procedure, the test conductor shall ensure that systems are secured per the Lockout/Tagout provisions of the SSC Safety and Health Procedures and Guidelines, and that no residual energy hazards are present prior to inspections or repairs.

The primary hazards associated with this procedure are: a. Bodily exposure to a cryogen b. Bodily exposure to a hydrogen flame

3.1.1 Personal Protective Equipment Required 3.1.1.1 Cryogenic, flame retardant coveralls 3.1.1.2 Cryogenic gloves 3.1.1.3 Face Shields 3.1.1.4 Ear muffs or ear plugs

4.1 General Requirements

4.1.1 Personnel not directly involved with the transfer operation shall be cleared back from the transfer/storage area during offloading operations.

4.1.2 Hot work activity (i.e., welding, cutting, usage of spark producing equipment, smoking, etc.) shall not be permitted within 100 feet of the transfer system/operation.

4.1.3 Communications between all work stations via standard headset orradio is required.

3.1.1 Personal Protective Equipment Required 3.1.1.1 Cryogenic, flame retardant coveralls 3.1.1.2 Cryogenic gloves 3.1.1.3 Face Shields 3.1.1.4 Ear muffs or ear plugs

4.1 General Requirements

4.1.1 Personnel not directly involved with the transfer operation shall be cleared back from the transfer/storage area during offloading operations.

4.1.2 Hot work activity (i.e., welding, cutting, usage of spark producing equipment, smoking, etc.) shall not be permitted within 100 feet of the transfer system/operation.

4.1.3 Communications between all work stations via standard headset orradio is required.

5.0 PREREQUISITES

5.1 Verify Facility Status _____ An Open Item Review of all work activities at the E-1 facility shall be

accomplished to determine if any constraints exist against the perform of this procedure

_____ Verify LH sphere vacuum system is operational. _____ Verify GN2 system is operational. _____ Verify LH2 Storage Area emergency shower is operational _____ Verify LH2 Storage Area washdown hose is operational _____ Verify LH2 Storage Area Flare System is operational _____ Verify deluge system is operational _____ Verify control system is operational _____ Verify DAS is operational _____ Verify GHe system is operational _____ Verify that LH2 delivery has been scheduled _____ Verify GH system is operational

5.0 PREREQUISITES

5.1 Verify Facility Status _____ An Open Item Review of all work activities at the E-1 facility shall be

accomplished to determine if any constraints exist against the perform of this procedure

_____ Verify LH sphere vacuum system is operational. _____ Verify GN2 system is operational. _____ Verify LH2 Storage Area emergency shower is operational _____ Verify LH2 Storage Area washdown hose is operational _____ Verify LH2 Storage Area Flare System is operational _____ Verify deluge system is operational _____ Verify control system is operational _____ Verify DAS is operational _____ Verify GHe system is operational _____ Verify that LH2 delivery has been scheduled _____ Verify GH system is operational

6.0 FACILITY SETUPS

6.1 Verify Flex Hoses are secured in holders with caps installed. 6.2 Verify Site GN2 at LH2 Storage Area Panel pressure is > 2,000

psig using PI-10H41-GN. 6.3 Verify Site GHE at LH2 Storage Area Panel pressure is > 1,800

psig using PI-10H39-HE. 6.4 Verify Site GH2 at LH2 Storage Area Panel pressure is > 1,500

psig using PI-10H42-GH.

6.5 Verify/Set E1 LH2 Storage Area MFP as follows: _____ Station 1 to 1,500 ｱ 50 psig _____ Station 2 to 1,500 ｱ 50 psig _____ Station 3 to 225 ｱ 10 psig _____ Station 4 to 20 ｱ 10 psig _____ Station 5 to 50 ｱ 10 psig _____ Station 6 to 50 ｱ 10 psig _____ Station 7 to 80 ｱ 5 psig _____ Station 8 to 300 ｱ 50 psig _____ Station 9 to 50 ｱ 10 psig _____ Station 10 to 60 ｱ 10 psig _____ Station 11 to 50 ｱ 10 psig

6.0 FACILITY SETUPS

6.1 Verify Flex Hoses are secured in holders with caps installed. 6.2 Verify Site GN2 at LH2 Storage Area Panel pressure is > 2,000

psig using PI-10H41-GN. 6.3 Verify Site GHE at LH2 Storage Area Panel pressure is > 1,800

psig using PI-10H39-HE. 6.4 Verify Site GH2 at LH2 Storage Area Panel pressure is > 1,500

psig using PI-10H42-GH.

6.5 Verify/Set E1 LH2 Storage Area MFP as follows: _____ Station 1 to 1,500 ｱ 50 psig _____ Station 2 to 1,500 ｱ 50 psig _____ Station 3 to 225 ｱ 10 psig _____ Station 4 to 20 ｱ 10 psig _____ Station 5 to 50 ｱ 10 psig _____ Station 6 to 50 ｱ 10 psig _____ Station 7 to 80 ｱ 5 psig _____ Station 8 to 300 ｱ 50 psig _____ Station 9 to 50 ｱ 10 psig _____ Station 10 to 60 ｱ 10 psig _____ Station 11 to 50 ｱ 10 psig

7.0 PRETRANSFER PURGING/INERTING

7.1 Purging and connection of trailer unloading station flex hoses

7.1.1 Make the following announcement. Attension E-1 personnel. LH will be transferred from LH trailers to the E-1 LH storage tank. All non-essential personnel maintain a clearance of 100 feet from the liquid hydrogen storage tank and trailer unloading area.� Repeat.

7.1.2 Set the area warning light(s) to Flashing Amber.

7.1.3 Verify Deluge Water System is in Standby.

7.1.4 Verify LH2 Storage Area Deluge Water Isolation Valve VA-10G32-DW is Open on East Side of Sphere.

7.1.5 Verify the LH2 transfer crew is ready to proceed. Position trailer and the unloading station and note which unloading station(s) are used.

7.0 PRETRANSFER PURGING/INERTING

7.1 Purging and connection of trailer unloading station flex hoses

7.1.1 Make the following announcement. Attension E-1 personnel. LH will be transferred from LH trailers to the E-1 LH storage tank. All non-essential personnel maintain a clearance of 100 feet from the liquid hydrogen storage tank and trailer unloading area.� Repeat.

7.1.2 Set the area warning light(s) to Flashing Amber.

7.1.3 Verify Deluge Water System is in Standby.

7.1.4 Verify LH2 Storage Area Deluge Water Isolation Valve VA-10G32-DW is Open on East Side of Sphere.

7.1.5 Verify the LH2 transfer crew is ready to proceed. Position trailer and the unloading station and note which unloading station(s) are used.

Perform Steps 7.1.6 – 7.1.24 if there is a trailer at the Trailer Unloading Station No. 1. Else DNA.

7.1.1 Open VA-10J34-HE, Unloading Station No. 1 GHe purge block valve.

7.1.2 Open VA-10B01-GH, Unloading Station No. 1 Fill Line Bleed. Purge line for 2 minutes.

7.1.3 Close VA-10B01-GH, Unloading Station No. 1 Fill Line Bleed.

7.1.4 Close VA-10J34-HE, Unloading Station No. 1 GHe purge block valve.

7.1.5 Verify/connect grounding cable to the trailer at Trailer Unloading Station No. 1.

7.1.6 Open VA-10J34-HE, Unloading Station No. 1 LH2 Transfer Line GHe purge block valve, partially to cause a slight helium flow out of the flex hose during connection. Sniff the connection with an LEL meter prior to disconnection for presence of hydrogen ( > 20% LEL unacceptable) in the line. MIP

7.1.7 Request the Truck Driver to disconnect the liquid transfer flex hose from the holder and connect to the trailer at Trailer Unloading Station No. 1. Maintain clean to Level 2. MIP

Perform Steps 7.1.6 – 7.1.24 if there is a trailer at the Trailer Unloading Station No. 1. Else DNA.

7.1.1 Open VA-10J34-HE, Unloading Station No. 1 GHe purge block valve.

7.1.2 Open VA-10B01-GH, Unloading Station No. 1 Fill Line Bleed. Purge line for 2 minutes.

7.1.3 Close VA-10B01-GH, Unloading Station No. 1 Fill Line Bleed.

7.1.4 Close VA-10J34-HE, Unloading Station No. 1 GHe purge block valve.

7.1.5 Verify/connect grounding cable to the trailer at Trailer Unloading Station No. 1.

7.1.6 Open VA-10J34-HE, Unloading Station No. 1 LH2 Transfer Line GHe purge block valve, partially to cause a slight helium flow out of the flex hose during connection. Sniff the connection with an LEL meter prior to disconnection for presence of hydrogen ( > 20% LEL unacceptable) in the line. MIP

7.1.7 Request the Truck Driver to disconnect the liquid transfer flex hose from the holder and connect to the trailer at Trailer Unloading Station No. 1. Maintain clean to Level 2. MIP


Operating Procedures May be a Combination of Written Instructions

and

Graphic Illustrations

Operating Procedures May be a Combination of Written Instructions

and

Graphic Illustrations

Operating ProceduresRefinery Operation Flow Chart

Operating ProceduresRefinery Operation Flow Chart


Must be Developed for Each Equipment Operation in the Covered Process

Refer to Block Diagrams Refer to P&ID Must Cover Normal Operating Conditions,

Normal Operating Parameters, i.e.. Pressure/Flow/Current/ etc.

Must be Developed for Each Equipment Operation in the Covered Process

Refer to Block Diagrams Refer to P&ID Must Cover Normal Operating Conditions,

Normal Operating Parameters, i.e.. Pressure/Flow/Current/ etc.


Must Follow Procedures & Recommendations in PHA’s

Must Follow Form

Remember the 3rd Grade Rule“Write Clear Enough that a 3rd Grader

Could Follow the Procedure”

Must Follow Procedures & Recommendations in PHA’s

Must Follow Form

Remember the 3rd Grade Rule“Write Clear Enough that a 3rd Grader

Could Follow the Procedure”

Operating Procedures Operating Procedures

For Shut-down Procedures…Remember: Most operations must be shut down in a

specific order! Failure to follow these shut down procedures

could results in a catastrophic release or system failure

For Shut-down Procedures…Remember: Most operations must be shut down in a

specific order! Failure to follow these shut down procedures

could results in a catastrophic release or system failure

Ammonia Plant Explosion Caused by Improper Shut-down of Engine Room

Operating Procedures Operating Procedures

Operating Limits Operating Limits Must

be Understood Pressures Flows Electrical Potential Tolerances

Operating Limits Operating Limits Must

be Understood Pressures Flows Electrical Potential Tolerances


Team Exercise Will be Performed in the Next Session with Safe Work Practices

Team Exercise Will be Performed in the Next Session with Safe Work Practices

Now That We’ve Completed the Operating Procedures

Now That We’ve Completed the Operating Procedures

We Must Develop Safety Work Practices, Programs & Procedures for Covered

Processes

We Must Develop Safety Work Practices, Programs & Procedures for Covered

Processes

What’s Next?

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