Process safety and societal risks in India

I was going through a risk assessment report prepared for an organization that was planning to increase production capacity using a toxic chemical as a raw material. This chemical is received through pipelines traversing through public areas. I found one thing startlingly out of place. The report used outdated population data in the vicinity of the pipelines. Unauthorized settlements were everywhere near the pipeline and this was not considered in the report. This is a peculiar problem in India. How can we rely on population statistics when the data itself is dynamic on a day to day basis! One other thing that always perturbs me is that I doubt if the user of the report understands the assumptions made and is really able to understand the report.
Just having a colorful report with a lot of drawings indicating toxic end points and red zones does not really mean you have identified the risks involved.While such reports are mandatory from a regulatory perspective, it is better that the organization revisit these reports periodically based on changes in population density.

Lord Tony Newton,independent chair of the Buncefield Investigation Board says "The system should in future consider the total population at risk – societal risk – at each new development application. We should not continue to allow surrounding populations to increase without considering the consequences". I really do not know how we can implement this in India unless there is strong enforcement by the regulatory agencies.

Process safety and fatigue

It is disturbing to note that fatigue probably played a part in the new US power plant explosion that occurred when lines were being blown with natural gas. It appears that one of the victims who died in the explosion was working 12 hours a day, seven days a week, for six months. If operators are being allowed to work without break even in the US, imagine the plight in India!The pressure of commissioning a plant to meet target deadlines often result in people working overtime. With more and more activities being outsourced, industry must be careful that this problem is tackled to avoid incidents. What is more worrying is that the aviation industry in India is reporting incidents of pilot fatigue due to inadequate rest periods.If it can happen in the aviation industry, it can happen in the chemical industry too!

Process safety -Pressure Relief and Flame out devices - Take care of them!

According to a news release dated 8.3.2010, "The U.S. Department of Labor's Occupational Safety and Health Administration has cited BP North American Inc. and BP-Husky Refining LLC's refinery in Oregon, Ohio, with 42 alleged willful violations, including 39 on a per-instance basis, and 20 alleged serious violations for exposing workers to a variety of hazards including failure to provide adequate pressure relief for process units. Proposed penalties total $3,042,000.Forty-two willful citations with proposed penalties totaling $2,940,000 are proposed as follows:

1. Thirty-eight (38) per-instance, willful citations with penalties totaling $2,660,000 allege as follows:
1. Twenty-six instances allege deficient pressure relief, a violation of 29 CFR parts 1910.119(d)(3) and 1910.119(j)(5), with total penalties of $1,820,000;
2. Three instances allege the lack of flame-out protection on heaters and a furnace, a violation of 29 CFR 1910.119(d)(3), with total penalties of $210,000; and
3. Nine instances allege facility-siting hazards, a violation of 29 CFR 1910.119(e)(5), with total penalties of $630,000.
2. Four willful citations with penalties totaling $280,000, allege as follows:
1. Lack of pressure vessel information, a violation of 29 CFR 1910.119(d)(3), with a penalty of $70,000;
2. Cross-connections between fire-emergency water supplies and process systems, a violation of 29 CFR parts 1910.119(d)(3) and 1910.119(e)(5), with a penalty of $70,000;
3. Failure to conduct thickness measurements at designated test sites and as required at the flare header, a violation of 29 CFR 1910.119(j)(4)(ii), with a penalty of $70,000; and
4. Failure to conduct thickness measurements in accordance with RAGAGEP, a violation of 29 CFR 1910.119(j)(4)(iii), with a penalty of $70,000".
Of particular interest is the twenty six instances of deficient pressure relief and three instances of lack of flame out protection.

Purging of Natural Gas Lines - Adding fuel to the fire?

The CSB had issued urgent recommendations on the natural gas explosion at Con Agra on June 9,2009. The incident occurred when natural gas lines were being purged free of air using natural gas itself.The CSB urgent recommendations include
(a) Purged fuel gases shall be directly vented to a safe location outdoors, away from personnel and ignition sources
(b) If it is not possible to vent purged gases outdoors, purging gas to the inside of a building shall be allowed only upon approval by the authority having jurisdiction of a documented risk evaluation and hazard control plan.The evaluation and plan shall establish that indoor purging is necessary and that adequate safeguards are in place such as:
• Evacuating nonessential personnel from the vicinity of the purging;
• Providing adequate ventilation to maintain the gas concentration at an established safe level, substantially below the lower explosive limit; and
• Controlling or eliminating potential ignition sources
(c) Combustible gas detectors are used to continuously monitor the gas concentration at appropriate locations in the vicinity where purged gases are released
(d) Personnel are trained about the problems of odor fade and odor fatigue and warned against relying on odor alone for detecting releases of fuel gases

It is not safe in the first place to allow purging of an air filled pipeline with natural gas. You can never control or eliminate all potential ignition sources. PERIOD!!
See the CSB recommendations in this link.
See my latest post on this subject

Domino effect and Process Safety

An interesting article on Domino Effects in the developed countries mentions the following "A study of 261 accidents involving domino effect has been carried out. The main features have been analyzed: origin, causes, consequences and most frequent sequences. The analysis has shown that the most frequent causes are external events (31%) and mechanical failure (30%). The storage areas (37%) and process plants (27%) are by far the most common places where domino accidents have occurred. The most common sequence in the event trees resulted to be explosion–fire (21%), followed by release– fire–explosion (15%) and fire–explosion (14%)".
While the study concludes that "The historical analysis has shown that the frequency of domino effect accidents has decreased over the last two decades. Most of these accidents have occurred –as could be expected– in the most industrialized countries (from which, furthermore, more information is available). The most frequent sequences are explosion–fire, release–fire– explosion and fire–explosion. From the analysis of the causes, although the most frequent ones are external events and mechanical failure, a relatively high frequency is found for human error. This would indicate the need to further promote the training of employees, as well as an additional improvement of safety measures, specially in storage areas".

As more and more chemical industries are coming up in India, it becomes very important to study facility siting issues.Incidents like the Jaipur fire clearly indicate the need for a stronger implementation of facility siting rules.
Read the whole article in this link.

Dangers of melting contents of drums

A chemical manufacturer in India has been asked to pay to pay $8.37 million for a fire that destroyed a Houston-based pesticides maker's warehouse and offices in Pasadena six years ago.
The fire apparently took place when Chloropyrifos drums were placed were placed in a “hot box” in the Houston company's Pasadena warehouse for melting, based on procedures provided by the manufacturer. However, during the melting process, the contaminated chemicals exploded and caught fire.It appears that the drums contained chloropyrifos contaminated with solvent.
It is quite common in pesticide manufacturing to put a drum in a steam bath or a hot box to melt the drum contents. But as this incident shows, you must understand the dangers before doing it.....
See this article for more details.

Process Safety in India -PCPIR's

To promote investment in the chemical sector and make the country an important hub for both domestic and international markets, the government is in the process of setting up Petroleum, Chemicals & Petrochemical Investment Regions (PCPIRs). As per the PCPIR policy ,this is to "attract major investment, both domestic and foreign, by providing a transparent and investment friendly policy and facility regime.These PCPIRs would reap the benefits of co-siting, networking and greater efficiency through the use of common infrastructure and support services. They would have high-class infrastructure, and provide a competitive environment conducive for setting up businesses. They would thus result in a boost to manufacturing, augmentation of exports and generation of employment".
Isn't the setting up of these PCPIR's a good opportunity for the Government to implement mandatory process safety norms in these PCPIR's?

The future of Process Safety in India

A recent news item on February 26th indicates that in the immediate future, Oil Industry Safety Directorate (OISD) is likely to be announced as the single window agency to ensure safety in the oil & gas sector and is also expected to be vested with all necessary statutory powers to fulfill its responsibilities. Several other regulatory changes and announcements that are in the pipeline and expected to be unveiled over the next few months.
What is the future of process safety in India? Do not be surprised if a Chemical Safety Board, similar to the US is set up. Do not be surprised if investigation reports of incidents are put up on the web. But for this to happen, I feel there has to be a strong impetus to the Government to bring in such changes. I am only hoping that another Bhopal is not the impetus!
While on the subject, let us visit the subject of awards and incidents. In my experience, many companies have won many safety awards but then there is a fatal accident. An award for process safety performance cannot be judged by visiting the unit for a few days. It requires commitment day in and day out from top management to really achieve top class process safety performance. I feel that an organization would be better off if it sits back and takes a good look at its performance in process safety periodically.

Natural Gas Blowing of pipelines causes accident

The CSB has released a statement that mentions that the explosion at the Kleen energy plant in the US occurred during the blowing of new pipelines with natural gas to clear them of debris. There were a number of possible ignition sources.It appears that this is a "common" practice in power plants. I wonder if people are forgetting the basics: flammable gas + air + ignition source = Fire or explosion!
It is very dangerous to assume that ignition sources will not be present!

Monitor your Pressure Safety valves for fugitive emissions

An incident in the US highlights the need to ensure that operational checks are conducted to detect any fugitive emissions from PSV’s. It was reported that about 1.5 tonne of a toxic chemical had leaked from the PSV over a period of two weeks. The leak was finally detected when mass balances did not match. If you have PSV’s discharging to the atmosphere that are mounted on top of vessels tanks and other equipment, ensure that you implement a fugitive emission monitoring program to detect any leak from the safety valve. Many large atmospheric ammonia storage tanks have their PSV’s located on the tank top and any leakage from these valves cannot be detected from the ground level. With more and more habitation coming up near maximum accident hazard units, it becomes imperative that you implement a proactive monitoring PSV leak monitoring program.

Process safety - Do not forget the human being in your design!

Some experts predict that in the future, there will not be any control rooms, but operators and managers individually wearing hi tech equipment like personalized visual displays and control units that will be networked and will be used to control plants. Whatever the future, one thing is sure - the human is going to be around! And continue to commit the same mistakes!! Some examples of design "googlies" are given below:
1. If you install an orifice plate to restrict flow as part of your design, be sure one day it will be removed.
2. If you install an instrument on top of a vessel or equipment and expect the operator to note down the reading, be sure that the reading one day will be noted without the operator going to the top.
3. If you design a tank for full pressure and not for vacuum, when there is a chance of vacuum formation, be sure that the tank will collapse one day due to vacuum.

If you forget to think like an operator, be sure your design will fail one day!!
This also raises another point. In the future is it possible to operate a plant that does not depend on human beings? Ultimately, there will have to be a human being who is looking after that technology and he can also make mistakes!

Advanced instrumentation at Refinery

Please read this article

The Worlds Largest Foundation Fieldbus Project
Reliance Petroleum Limited Needed Foundation Fieldbus to Manage the Most Complex Refinery in the World

A picture of the control room is also given in the article.The article also mentions that over 200 of the commissioning staff were given troubleshooting training.