HAZARD IDENTIFICATION Injection Point and Process Mixing Point Hazards Purpose and Use: The Process Safety Hazard Identification documents serve to help facilities identify potential risks associated with work practices, safety practices, process equipment, and technology. Hazard Identification documents are meant to: Improve process safety awareness with a focus on higher potential risks, Provide information and ready reference guides for potentially overlooked and not widely known process safety hazards, and Share lessons from industry related incidents and near misses. Scope: Category: Piping and Other Equipment Associated with Mixing and Injection in Process or Utility Streams, Engineering and Design Practices, Operating Procedures, Operator Training, Mechanical Integrity Inspection Procedures A process mixing point is where process streams of differing compositions and/or temperatures join together. An injection point is a specific type of process mixing point where there can be a significant potential for degradation of equipment integrity due to operation (or mis-operation) of the injection or change in the process parameters. Some examples of common injection points are; water injection in overhead systems, antifoam injections, corrosion inhibitor injections, neutralizer injections, and catalyst injection into reactant streams. The term ‘injection quill’, as contained in this document, refers to a smaller diameter piece of piping or tubing which is inserted into a larger diameter pipe for the purposes of injecting a material into the stream flowing through the larger pipe. It also includes any flow distribution nozzle (or nozzles) which may be attached to the smaller pipe to obtain the required mixing, contacting, and/or wetting. Injection quills may be retractable or fixed. Example of An Injection Quill Process streams are typically combined or joined together at mixing or injection points to: Mix or blend two separate streams, Cause a chemical or physical reaction by combining components of two process streams, Scrub or extract components from one stream by contact with a second stream, Heat or cool (flash or quench) one process stream by combining with another, and/or Protect the internal surfaces of equipment handling a process stream. Examples of Inherent Process Safety Concerns and/or Hazards include: Loss of primary containment (LOPC) due to internal corrosion and/or erosion resulting from: A. Potential damage mechanisms not identified B. Equipment design deficiencies C. Process changes or creep without management of change (MOC) D. Operation outside of design window E. Inadequate mixing point or injection point equipment condition monitoring Loss of primary containment due to mechanical failure of injection or associated equipment Note: This hazard identification document is a generic, non-comprehensive synthesis of inherent concerns and / or hazards for the related topic. It in no way alters any legal requirements. It is not intended to replace sound engineering analysis or judgment. HAZ002.000 1 HAZARD IDENTIFICATION Injection Point and Process Mixing Point Hazards Mixing and injection points are potential locations for damage mechanisms not present in the feed streams or in the final mixed stream. They may also be susceptible to corrosion, erosion, fatigue, stress corrosion cracking or other damage mechanisms which may be present before the feed streams are homogenously mixed. Each of the following hazard situations could lead to possible LOPC with a broad range of consequences depending on the material released, including injury, toxic exposures, fire/ explosion, damage to equipment and/or the environment and negative community impacts. Potential Concerns 1.0 Design Practices Potential Hazards - UNLESS OTHERWISE SPECIFIED, ALL THE HAZARDS MENTIONED MAY RESULT IN LOPC 1.1 Process mixing points and injection points that are not identified for further evaluation. 1.2 Process mixing points and injection points that are not properly evaluated with such considerations as: 1.2.1 Chemical engineering principles – including the effects of mixing of the components in the process streams (e.g. mixing tables or incompatibility tables), 1.2.2 Mechanical engineering principles, 1.2.3 Materials and corrosion engineering principles, 1.2.4 The process objectives for the mixing or injection point. 1.3 The required process conditions (including operating window) that affect the necessary mixing, contacting, and/or wetting at the mixing point or injection point and immediately downstream are not correctly evaluated and/or specified with such considerations as: 1.3.1 The flow rate and flow regime downstream of the mixing or injection point, 1.3.2 The temperature gradient between two feed streams, 1.3.3 The degree of atomization of the injected stream, 1.3.4 The distribution of the injected stream across the flow area (and, if applicable, downstream flow splits), 1.3.5 The location of the mixing or injection point relative to upstream and downstream equipment could be important considerations in this evaluation and/or specification, 1.3.6 The need for an in-line mixer and the additional damage mechanisms that it would introduce. Note: This hazard identification document is a generic, non-comprehensive synthesis of inherent concerns and / or hazards for the related topic. It in no way alters any legal requirements. It is not intended to replace sound engineering analysis or judgment. HAZ002.000 2 HAZARD IDENTIFICATION 3 Injection Point and Process Mixing Point Hazards Section 1.3 Figure Injected Material Very High Corrosion Rates Could Occur In These Areas 1.4 Adequate materials of construction that are not specified for the process and mechanical operating conditions of the mixing point or injection point (e.g. temperature, vibration, localized corrosion/erosion, etc.) or for the impacted equipment immediately downstream. This includes piping and equipment immediately downstream of a bypass around a heat exchanger that may encounter elevated temperatures during the time in which the exchanger is partially or fully bypassed. Also, special mechanical design considerations may be required for mixing streams with a greater than 250⁰F temperature difference. Section 1.4 Figure Cooler Vapor Stream Saturated with Water Localized Corrosion Where Vapors Condense Warmer Vapor Stream with Halides 1.5 Injection quill/s that are not adequately designed, tested and/or installed for the needed mixing, contacting, and/or wetting. 1.6 Injection point quills and ancillary equipment (e.g., tankage, pumps, instrumentation, strainers, filters, valves, etc.) that are not designed to meet the on-stream specifications of the injection point. 1.7 Adequate design provisions for monitoring key variables of the design operating window that are not made (e.g., accessibility, instrumentation, sampling points). Note: This hazard identification document is a generic, non-comprehensive synthesis of inherent concerns and / or hazards for the related topic. It in no way alters any legal requirements. It is not intended to replace sound engineering analysis or judgment. HAZ002.000 HAZARD IDENTIFICATION 4 Injection Point and Process Mixing Point Hazards 1.8 Adequate design provisions for future equipment condition monitoring inspections (e.g., removable spools, manways, accessibility, etc.) that are not made. 1.9 Adequate backflow prevention that is not made to keep the main process stream from backing through an injection point during any type of operation to which it will be subjected. This could lead to inadvertent mixing or equipment being subjected to different process conditions than it was designed. 2.0 Unmanaged Process Changes 3.0 Operation Outside of Design Window 4.0 Mechanical Failure 2.1 Process changes outside of the design operating window that are not properly managed with an MOC. This may include unmanaged changes in flowrates, compositions, pressures and/or temperatures of streams involved in process mixing or injection points. 2.2 Physical changes made to piping and/or equipment downstream of the mixing or injection point, or at the mixing or injection point, that are not properly managed with an MOC. This could lead to mechanical integrity issues. 2.3 Temporary injection points installed for startup or shutdown activities that are not managed effectively to ensure they are disconnected when they are no longer required. 3.1 Compositions, flowrates, pressures and/or temperatures of process or chemical injection streams associated with process mixing points or injection points that are not routinely monitored and kept within the design operating window. 3.2 Performance monitoring that is not routinely done to ensure that the mixing point or injection point is achieving any key process objective. 3.3 Injection points that are not commissioned and/or decommissioned at the proper time during associated equipment startup and shutdown. 4.1 Injection quills and the associated nozzles could corrode, erode or plug causing a deficiency of mixing, contacting and/or wetting downstream of the injection point. (Plugging could be a common problem with intermittently used quills which remain in place.) 4.2 Injection quills could blow out of their packing gland during retraction without a blowout prevention device. 4.3 Thermal fatigue due to temperature cycling could cause equipment failures at mixing points and injection points. This cycling could be a function of flowrate and/or temperature differences of the streams being mixed, as well as fluctuations in them. Section 4.3 Figure Hotter Stream Localized temperature swings could result in fatigue failure Cooler Stream 4.4 Pressure cycling and flow induced vibrations at mixing points and injection points (especially those resulting from multi-phase flow regimes or flashing) could cause fatigue and associated equipment failure. Note: This hazard identification document is a generic, non-comprehensive synthesis of inherent concerns and / or hazards for the related topic. It in no way alters any legal requirements. It is not intended to replace sound engineering analysis or judgment. HAZ002.000 HAZARD IDENTIFICATION Injection Point and Process Mixing Point Hazards 4.5 Shutoff valves for intermittently operated injection points could leak through and result in accelerated corrosion. 5.0 Inadequate Equipment Condition Monitoring 5.1 Inspection techniques consistent with the specific damage mechanisms and their probable locations at mixing points and injection points that are not identified and routinely used. 5.2 Equipment deficiency limits that are not set and enforced for the integrity of mixing point or injection point associated equipment. 5.3 The flow pattern/s from the quill/s associated with an injection point that is not verified on a periodic basis. References and Resources: API 570 – Piping Inspection Code; In-service Inspection, Rating, Repair, and Alteration of Piping Systems, Fourth Edition, February 2016 NACE Technical Committee Report 34101 “Refinery Injection and Process Mixing Points” NACE SP0114-2014 “Standard Practice Refinery Injection and Process Mixing Points” Inspectioneering Journal – July/August 2013 “The Many Parts of Injection Points”, Available at https:/inspectioneering.com/ API RP 932-B – Design, Materials, Fabrication, Operations, and Inspection Guidelines for Corrosion Control in Hydroprocessing Reactor Effluent Air Cooler (REAC) Systems. Second Edition, March 2012, Errata, January 2014. Industry Incidents: May 5, 1988 – Incident at Norco, LA, Refinery October 8, 1992 – Incident at Wilmington, CA, Refinery April 16, 2001 – Incident at United Kingdom Refinery November 20, 2008 – Incident at Tyler, TX, Refinery Note: This hazard identification document is a generic, non-comprehensive synthesis of inherent concerns and / or hazards for the related topic. It in no way alters any legal requirements. It is not intended to replace sound engineering analysis or judgment. HAZ002.000 5 HAZARD IDENTIFICATION Injection Point and Process Mixing Point Hazards Appendix Figure 1 Failure of Elbow Downstream of Injection Point on Overhead of De-ethanizer Line United Kingdom Refinery Failure April 2001 Appendix Figure 2 Fire Following Failure of Naphtha Line at a Mix Point Tyler, TX, Refinery Failure November 2008 Note: This hazard identification document is a generic, non-comprehensive synthesis of inherent concerns and / or hazards for the related topic. It in no way alters any legal requirements. It is not intended to replace sound engineering analysis or judgment. HAZ002.000 6 HAZARD IDENTIFICATION Injection Point and Process Mixing Point Hazards Revision Date Summary of Changes 1 11/06/2015 First Draft With Illustrations 2 01/16/2016 Draft with Subgroup Submitted Comments 3 01/25/2016 Draft with Comments from Subgroup Joint Review 4 01/30/2016 Draft with Late Comments from Subgroup 5 03/16/2016 Final with Legal and MI Task Force Comments Note: This hazard identification document is a generic, non-comprehensive synthesis of inherent concerns and / or hazards for the related topic. It in no way alters any legal requirements. It is not intended to replace sound engineering analysis or judgment. HAZ002.000 7