Process Safety Management of Highly Hazardous & Explosive Chemicals. Operating Procedures

Transcription

1 Process Safety Management of Highly Hazardous & Explosive Chemicals Operating Procedures

2 Now that the PHA s Are Competed or Underway Operating Procedures & Safety Programs Must Be Developed PHA Information Can Be Used

3 Operating Procedures (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.

4 & 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

5 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).

6 Operating 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 *Must be Readily accessible to employees

7 Operating Procedures 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.

8 Many Covered Processes are Operated by Automated & Manual Procedures

9 Operators Must be Trained in Software Use

10 Operating Procedures Must Provide Procedures for Controlling the Process

11 Operating Procedures 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?

12 Operating Procedures Compliance Directive Asks: Do the operating procedures include operating limits that outline consequences of process deviation and steps required to correct or avoid deviations?

13 Operating 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?

14 Operating Procedures 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.

15 Operating Procedures 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)?

16 - Start Up We Must Describe normal SOP's Describe start-up SOP's Describe Shut-down SOP s

17 Operating Procedures 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

18 - Start Up We Must Include Sections such as: Objectives Purpose Concerns Procedures Department Operator Equipment Involved Location Related Documents

19 Let s Look at an Example

20 Operating Procedure for NASA E-Complex 1.0 INTRODUCTION 1.1 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 Up b. Pre-transfer Purging/Inerting c. Liquid Hydrogen Transfer d. Facility Securing/Shutdown

21 1.0 REFERENCES 2.1 DOCUMENTS SSP John C. Stennis Space Center Safety and Health Handbook SSTD FLUIDS SSC Facility Cleanliness Requirements for Propellant, Gas and Hydraulic Systems SOI Preparation and Use of Detailed Operating Procedures (DOP) SOI Contamination Prevention, Field Cleaning and Temporary Closures STP John C. Stennis Space Center Technical Procedure Commodity Receipt and inspection 2.2 DRAWINGS PSK-E FAC, Sheet 1 LH Trailer Unloading Storage and Transfer Piping and Instrument Diagram PSK-E FAC, Sheet 9 E1 LH2 Storage Area MFP

22 3.0 RESPONSIBILITIES 3.1 Personnel 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 Sign-Off Instructions The assigned personnel performing this DOP shall buy off each Step upon completion on the buy off sheet.

23 3.2 Safety 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 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

24 3.1.1 Personal Protective Equipment Required Cryogenic, flame retardant coveralls Cryogenic gloves Face Shields Ear muffs or ear plugs 4.1 General Requirements Personnel not directly involved with the transfer operation shall be cleared back from the transfer/storage area during offloading operations 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 Communications between all work stations via standard headset or radio is required.

25 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

26 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

27 7.0 PRETRANSFER PURGING/INERTING 7.1 Purging and connection of trailer unloading station flex hoses Make the following announcement. Attension E-1 personnel. LH will be transferred from LH trailers to the E-1 LH storage tank. All nonessential personnel maintain a clearance of 100 feet from the liquid hydrogen storage tank and trailer unloading area. area. Repeat Set the area warning light(s) to Flashing Amber Verify Deluge Water System is in Standby Verify LH2 Storage Area Deluge Water Isolation Valve VA- 10G32-DW is Open on East Side of Sphere Verify the LH2 transfer crew is ready to proceed. Position trailer and the unloading station and note which unloading station(s) are used.

28 Perform Steps if there is a trailer at the Trailer Unloading Station No. 1. Else DNA Open VA-10J34-HE, Unloading Station No. 1 GHe purge block valve Open VA-10B01-GH, Unloading Station No. 1 Fill Line Bleed. Purge line for 2 minutes Close VA-10B01-GH, Unloading Station No. 1 Fill Line Bleed Close VA-10J34-HE, Unloading Station No. 1 GHe purge block valve Verify/connect grounding cable to the trailer at Trailer Unloading Station No 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 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

29 Operating Procedures Operating Procedures May be a Combination of Written Instructions and Graphic Illustrations

30 Refinery Operation Flow Chart

31 Operating Procedures 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.

32 Operating Procedures 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

33 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

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

35 Operating Procedures Operating Limits Operating Limits Must be Understood Pressures Flows Electrical Potential Tolerances

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

37 What s Next? Now That We ve Completed the Operating Procedures We Must Develop Safety Work Practices, Programs & Procedures for Covered Processes