Mary Kay O’Connor Process Safety Center Practical Risk Reduction in the Petroleum Industry May 2006 Mary Kay O’Connor Process Safety Center Artie McFerrin Department of Chemical Engineering Texas Engineering Experiment Station Texas A&M University System 3122 TAMU College Station, TX 77843-3122 (979) 845-3489 http://process-safety.tamu.edu Practical Risk Reduction in the Petroleum Industry The research presented in this report was conducted by the Mary Kay O’Connor Process Safety Center at Texas A&M University. The opinions and analysis expressed in this report are solely the responsibility of the Mary Kay O’Connor Process Safety Center. Partial funding provided by the American Petroleum Institute is appreciated. © Copyright 2006. Mary Kay O’Connor Process Safety Center. All rights reserved. College Station, Texas, USA, May 2006 2 Table of Contents Introduction & Scope......................................................................................................................................3 Practical Risk Management in the Petroleum Industry...................................................................................3 Widely-Used Methods for Process Hazard and Safety Analysis .............................................................5 Safety Audit/Checklist Analysis....................................................................................................6 What-If Analysis ...........................................................................................................................6 Dow Fire and Explosion Index (F&EI).........................................................................................6 Mond Fire and Explosion and Toxicity Index...............................................................................7 Failure Mode and Effects Analysis (FMEA).................................................................................7 Hazard and Operability Study (HAZOP) ......................................................................................7 Quantitative Risk Assessment (QRA) and Layer of Protection Analysis (LOPA) ........................8 Fault Tree Analysis (FTA).............................................................................................................9 Hazard Identification and Risk Assessment Programs in the Petroleum Industry...................................9 API’s Risk Based Inspection (RBI).............................................................................................10 Reliability Centered Maintenance (RCM) ..................................................................................10 Inherent Safety, Health and Environment (ISHE) Review..........................................................11 SHE Non-Process Quality Control (NPQC) ...............................................................................11 Major Accident / Higher Level Risk Assessment........................................................................11 Security and Safeguards Risk Assessment ..................................................................................12 Scenario-Based Operating Area Risk Assessment ......................................................................12 Fire Protection Survey.................................................................................................................12 Marine Terminal Survey..............................................................................................................13 Safety Relief Valve and Flare Header Review ............................................................................13 Facility Siting/Building Study.....................................................................................................13 Exposure Assessment Strategy....................................................................................................14 Security & Safeguards Qualitative Risk Assessment (SSQRA)..................................................14 Hazards Analysis for Machinery Safety (HAZAMS) .................................................................14 Other Lesser-Known Methods for Process Hazard and Safety Analysis ...............................................15 Risk Management Program...........................................................................................................................16 Risk Acceptance and Risk Criteria ...............................................................................................................18 Inherent Safety Principles .............................................................................................................................23 Intensification ........................................................................................................................................24 Substitution............................................................................................................................................26 Attenuation ............................................................................................................................................27 Simplification ........................................................................................................................................29 Summary.......................................................................................................................................................30 Appendix.......................................................................................................................................................31 Concepts of Risk and Associated Terms .......................................................................................................31 References.....................................................................................................................................................34 1 Figures & Tables Figure 1. Risk Management Program Elements ......................................................................16 Figure 2. Level of Risks and ALARP ......................................................................................20 Figure 3. An Example of Risk Acceptance Criteria Based on Risk Matrix.............................21 Figure 4. Two Designs for Liquefied Petroleum Gas Separation Unit ....................................25 Figure 5. LNG storage tank .....................................................................................................28 Figure 6. Pumped Acid Reactor Technology ...........................................................................29 Figure 7. Gravity Flow Reactor Technology ...........................................................................30 Table 1. Published Acceptable Values of Risk .........................................................................22 2 Practical Risk Reduction in the Petroleum Industry Introduction & Scope The purpose of this document is to present the fundamental concepts of practical risk management within the U. S. petroleum industry and explore the application of inherently safer design concepts within this context. This document begins with a discussion on the comprehensive risk management programs that are currently being used at many petroleum sites to assist in managing risk. There also is a discussion on hazards, inherently safer design and risk acceptance criteria. This is followed by recommended practices and guidelines for hazard analysis and management that are published by some industrial organizations, e.g., the American Petroleum Institute and the Center for Chemical Process Safety (CCPS). Practical Risk Management in the Petroleum Industry The objective of the risk management process is to ensure that all operating hazards are properly identified and prioritized based on their potential consequences and likelihood of failure. Practical risk management includes the elements of cost and technical feasibility. While it may be desirable to eliminate all hazards and their associated risk from the operating environment, it some cases this ultimate goal may not be practical due to financial and technical limitations. Therefore, an effective risk management process provides management a tool to help identify hazards that present the highest risk to the company, its workers and the surrounding community. With this information, management can effectively allocate resources based on risk and focus efforts to continue operating safely. The risk management process involves identifying, analyzing, and assessing the significance of potential risks, and determining whether cost-effective prevention and mitigation measures are available to reduce their consequences and / or their likelihood of occurrence as low as is practical. Risk management is an ongoing activity with technology, equipment design and 3 operating practices continuously evolving. What may not be practical today may be achievable in the future. This process of risk management has served the industry and its workers well over the course of history. Safety statistics collected by the Government and others shows a history of relatively safe operations, proving that the overall pool of risk can be managed effectively. Risk assessment is the application of policies and practices to identify, assess, and control risk in order to protect human life, the environment, physical assets and company reputation in a cost-effective manner. It is a multi-faceted activity encompassing business strategy, economics, resource allocation and public affairs considerations. Well-defined work processes, trained and qualified personnel, and well balanced, cross functional teams with a wide spectrum of experience including safety, design, operations and maintenance experience are essential for successful risk assessment activities. Decision analysis is another part of risk management, which considers the significance of the risk under study, evaluates the attractiveness of potential risk reduction measures, and decides the course of further action. Once a risk assessment has been conducted and possible risk reduction measures identified, implementation plans are developed considering prioritization of effort and allocation of resources. In some cases, there may be only one practical risk reduction or risk elimination measure. The potential benefits of risk reduction measures must be evaluated against potential implementation risks that are introduced. Considerable judgment is involved in this activity, since the benefits and cost effectiveness of potential risk reduction measures may be difficult to quantify and must be balanced against other operational drivers. To evaluate existing risk and compare risks of potential alternatives, practical risk reduction must assess the processes in terms of the holistic impact to the greater system. includes two elements. Holistic risk First, all major hazards (flammability, toxicity, corrosion resistance, reactivity, transportation and risk migration) must be considered when evaluating the impact 4 of practical risk reduction measures. Second, practical risk reduction must include a lifecycle analysis from a holistic viewpoint that evaluates each stage on criteria such as economy, quality, productivity, energy conservation and pollution prevention (Bollinger, et al., 1996). The petroleum industry uses a variety of risk assessment methods. The applicability and feasibility of a particular method depends on the nature of the process under study as well as a company’s particular preference. a holistic risk analysis. Many processes may require several methods to perform The resultant holistic risk can be qualitative or quantitative depending on the information available and the method employed. Some companies employ enterprise-specific programs that are adapted and tailored for their particular facilities and activities. The existing methodologies can be separated into three classes: widely-used methods, company-tailored specific programs and lesser-known methods and are discussed below. Widely-Used Methods for Process Hazard and Safety Analysis Process hazard identification and risk assessment methods can be categorized into two main categories based on their complexity. The higher the complexity, the more knowledge or experience the team must have and the more data and resources that are needed. Some simple methodologies require only basic process data and include Safety Audit, Checklist Analysis, What-If Analysis, Dow Fire and Explosion Index (F&EI), Mond Index and Failure Mode and Effects Analysis (FMEA). Other methodologies, such as Hazard and Operability Study (HAZOP), Quantitative Risk Analysis (QRA), Layer of Protection Analysis (LOPA) and Fault Tree Analysis (FTA) are considered more complex. These methods are briefly described below in order of increasing complexity. 5 Safety Audit/Checklist Analysis Safety Audit or Checklist Analysis is one of the first methods applied for hazard identification and management. It is a list of possible problems and areas to be checked based on the nature of and experience with the system. A checklist is often used for identifying potential hazards during process design or before process operation. What-If Analysis The What-If Analysis is a brainstorming method frequently used by industry at almost every stage of a process. A multidisciplinary team with personnel who are familiar with the process brainstorm questions about possible undesired events due to hazards. There is no inherent structure as with HAZOP or FMEA. Dow Fire and Explosion Index (F&EI) The Dow F&EI was developed by the Dow Chemical Company in 1964 and is one of the most widely-used hazard evaluation indices (AIChE, 1994; Scheffler, 1994; Brasie, 1976). It divides the plant into units and then calculates the hazards of chemical substances in terms of a material factor that is then modified by penalty factors for general and special process hazards and credit factors for loss control measures and devices. Expert knowledge and empirical experience are applied to the penalty and credit factors of this method. Although the Dow F&EI is an easy method to apply, it has some limitations. It may lead to oversimplification when applied mechanically without considering the specific situation of the plant (King, 1999). Specific adjustments are needed according to the characteristics of the plant. For example, Gupta (1997) suggested increasing some penalty factors for plants located in developing countries. Kletz (1980) cautioned that some of the numbers are arbitrary. The values of the weighting factors for combining the sub-indices are subject to controversy as well. 6 Mond Fire and Explosion and Toxicity Index The Mond Fire and Explosion and Toxicity Index was developed by ICI in 1979. It is based on the Dow F&EI, but introduces toxicity as an additional factor. The overall index is calculated by combining indices for general and special process hazards, quantity hazards, layout hazards, acute health hazards, and cost of equipment and pipework (King, 1999; Khan and Abbasi, 1998a; Lewis, 1980). Failure Mode and Effects Analysis (FMEA) The objective of FMEA is to analyze failure modes of each item of equipment and their effects on a system or plant. The failure mode describes how equipment fails (e.g., open, closed, on, off, leaks) and the effects of the failure modes. Human operator errors are usually not included in FMEA, but the effects of an operational mishap are often indicated by an equipment failure mode. The FMEA method requires a system or plant equipment list or knowledge of equipment functions, failure modes and knowledge of system or plant responses to equipment failure. FMEA is not efficient for systems where complex logic exists in the equipment failures. Normally it cannot handle interactions among several components (CCPS, 1992). Hazard and Operability Study (HAZOP) The HAZOP method was developed by ICI in 1963 and published in 1974 by Lawley (Kletz, 1999). It is the most commonly used method to identify and evaluate potential hazards in a process plant and to identify operability problems that could compromise the plant’s ability to achieve design intent (Lees, 1996; Kletz, 1999; CCPS, 1992; Crowl and Louvar, 2002). This systematic analysis technique requires a detailed source of information for the design and operation of a process, such as current process flow diagrams (PFDs), process and instrumentation diagrams (P&IDs), detailed equipment specifications, materials of 7 construction and mass and energy balances. It is most often used during or after the detailed design stage, and it is applied to each individual piece of equipment or system of the unit or plant analyzed. For each assumed deviation based on guide words (e.g., more, less, no) associated with process variables (e.g., flow, temperature, pressure, concentration, pH, viscosity, state), the resultant conditions are assessed in terms of potential negative safety consequences and existing safeguards. Quantitative Risk Assessment (QRA) and Layer of Protection Analysis (LOPA) QRA and LOPA are two other risk assessment methods used by the petroleum industry. The frequency of a release is calculated using a combination of event trees, fault trees or an appropriate adaptation from both methods. QRA is a method that systematically identifies where operations, engineering or management systems can be modified to reduce risk, based on a quantitative estimate of incident frequency and consequence. QRA can help managers evaluate the overall risk of a process (Crowl and Louvar, 2002; CCPS, 2000). LOPA is a semi-quantitative method based on a system of protection layers that includes simplified approaches to characterize the consequences and estimate the frequencies for risk determinations. The protection layers include inherently safer concepts, process control systems, safety instrumented functions, passive and active protection devices and procedural intervention. The combined effects of the protection layers are compared with certain risk tolerance criteria, such as frequencies of fatalities and fires, a maximum frequency for a specific category of consequence, and a required number of independent layers of protection for a specific consequence category (Crowl and Louvar, 2002; CCPS, 2001). Normally LOPA yields more conservative results than QRA because the effectiveness of each protection layer is conservatively estimated. Both QRA and LOPA methods are especially effective for evaluating alternative risk reduction strategies. 8 Fault Tree Analysis (FTA) Fault Tree Analysis (FTA) originated in the aerospace industry and has been used extensively in the nuclear power industry. This method, which was introduced into the chemical industry in the late 1970s by Lapp and Powers, provides a deductive method for determining causes of the focused event (top event). By using Boolean logic gates (AND, OR) to relate equipment failure and human error, a FTA generates system failure logic models. FTA is suited for analyzing highly redundant systems compared to single-failure-oriented techniques (e.g., FMEA, HAZOP). The methodology is powerful and comprehensive, but very demanding because it requires a detailed understanding of how the plant or system functions, detailed process drawings and procedures and knowledge of component failure modes and their effects (CCPS, 1992). It is especially time-consuming to generate the tree of events leading to the top event. Normally only experts who know the methodology and are familiar with the process can perform it. Automatic generation of the tree is still under research (Wang et al., 2001). Moreover, incident probabilities and failure frequencies are used in the FTA. These data are not always available and sometimes must be estimated with significant uncertainty (CCPS, 1993). Hazard Identification and Risk Assessment Programs in the Petroleum Industry The methodologies mentioned above have been adapted in the petroleum industry according to individual needs and applications. The petroleum industry often exceeds the regulatory requirements for OSHA Process Safety Management (PMS) and EPA Risk Management Program (RMP) by adopting additional safety and management systems. An example is the implementation of structured reliability centered maintenance (RCM) techniques for planning maintenance functions, together with Risk Based Inspection (RBI). In this approach, reductions in operational risk are achieved through optimization of inspection by analyzing 9 those components considered most critical. There are several risk assessment/management programs employed by the petroleum industry including: API’s Risk Based Inspection (RBI) Risk Based Inspection (RBI) is the methodology that factors risk into inspection and maintenance decision-making (Reynolds, 1998). RBI is both a quantitative and qualitative process for systematically combining the failure probabilities and consequences to establish a prioritized list of equipment based on their associated risk. This prioritized list guides the RBI user in the development of an inspection and maintenance program that manages the risk of equipment failures. It also combines engineering knowledge in the area of corrosion mechanisms and integrates it with the inspection program. RBI categorizes analysis outcomes into four basic risks: flammable events, toxic releases, major environmental damages and business interruption losses. It covers only pressurized equipment, such as vessels, columns, heat exchangers, piping, furnace tubes, and tanks and does not cover non-pressurized equipment, such as instrument systems, controllers and electrical gears. Reliability Centered Maintenance (RCM) RCM aims to determine the most cost-effective maintenance strategy with the active support and cooperation of all people involved for each type of failure process. This strategy is accomplished by answering a series of questions about equipment functions, failures, performance standards and impact of failures. From these questions, a predictive maintenance strategy is developed to mitigate the consequences of a failure based on the criticality of the failure mode. Based on the answers to the questions, RCM provides a flow diagram that indicates the type of maintenance to use. 10 Inherent Safety, Health and Environment (ISHE) Review ISHE is a formal and systematic critical review of process and key operation steps, critical process information and raw materials/products distribution used to identify, reduce or eliminate significant safety and health hazards/environmental risks. This program also identifies key hazard controls and provides inputs to develop a strategy for subsequent ISHE reviews. SHE Non-Process Quality Control (NPQC) The NPQC program assesses engineering details of controls for key hazards and exposures of personnel, reviews deviations from approved SHE practices and job specifications and helps to ensure that human factors are incorporated into detailed engineering. Major Accident / Higher Level Risk Assessment This program uses corporate risk matrices to construct and review risk scenarios and in-place risk controls. A baseline risk assessment study is conducted and maintained to manage major accident hazards. The risk assessment is completed on an operating area basis so that a facility can characterize the hazards with the highest potential consequences. Identified hazards are evaluated through a scenario-based risk assessment process. For evaluation of loss of containment hazards, inventories can be risk ranked to determine the higher risk release scenarios. This assessment is not intended, however, to be a substitute for the unit-by-unit, line-by-line HAZOP process. 11 Security and Safeguards Risk Assessment This program assesses the probabilities and severities of undesired security events, when significant changes occur to facility operations and prior to new construction. These security risk assessments are used to identify and develop countermeasure recommendations that mitigate the identified risks in a cost-effective manner. Scenario-Based Operating Area Risk Assessment This assessment focuses on identifying operating events that are not identified through other risk assessments. It includes a focus on operating practices, conditions, tasks and procedures that can result in significant incidents that might include: • Operating practices that may introduce hazards to personnel and facilities • Infrastructure concerns that can result in a loss of containment at process units or in offsite areas including flares, electrical, sewers and/or other utilities • Impacts on site facilities from outside operations (e.g., power outage, release/fire at neighboring site, public services) • Impact of severe weather and natural hazards on site facilities (e.g., hurricane, typhoons, flooding, earthquake) This assessment is conducted on a unit-by-unit basis and includes reviews of process units and off site facilities (e.g., docks, laboratories, mechanical shops). Fire Protection Survey The Fire Protection Survey is a comprehensive review of fire fighting systems at a facility to assess their adequacy of design, system management and operational readiness. The review focuses on active and passive fire fighting systems. It also focuses on related loss prevention systems, such as fire and gas detection, emergency isolation, layout and spacing, drainage and electrical area classification. 12 Marine Terminal Survey The focus of the Marine Terminal Survey is to improve safety, protect the environment and reduce risks at marine terminals. This program assesses how effectively risks that affect personnel safety, plant assets and the community are being managed. It also assesses how well prepared and responsive the terminal is to emergencies, such as oil spills. The Marine Terminal Survey scope includes leadership, commitment and organization, risk assessment, safety, training, pre-arrival screening and communication, port passage, berth approach, maneuvering, berthing/mooring, vessel/shore access, mooring management, ship-shore interface, inert gas and crude oil washing, ship-shore transfer equipment, cargo transfer, pollution prevention and response, fire and explosion, emergency preparedness and response, in-port lightering, maintenance and inspection and single/multi-point mooring. Safety Relief Valve and Flare Header Review This assessment is used to confirm the adequacy of safety relief devices based on credible design contingencies and to validate that the safety relief device design and flare design meet appropriate requirements. This review includes verification of design contingencies for the relief device sizing, inlet piping losses and the downstream piping connections. Flare system analysis is performed using computer modeling. Facility Siting/Building Study The objective of a facility siting study is to facilitate the management of toxic and flammable hazards within the manufacturing sites through optimization of the location and design of hazards, equipment, ignition sources and plant buildings. Facility siting includes two components: spacing requirements and the proximity of processes to concentration centers of 13 workers. The focus is on worker protection, through isolation from toxic chemicals, fires and explosions, and maintaining the functional integrity of the control center so emergencies can be mitigated quickly even when the environment at the facility is too hazardous for people to enter. Exposure Assessment Strategy The primary objective of an exposure assessment program is to minimize potential exposures to health hazards and to prevent occupational illnesses and injuries. The Exposure Assessment Strategy (EAS) ensures the systematic identification, assessment and documentation of potential exposure hazards and controls in an operating site. Security & Safeguards Qualitative Risk Assessment (SSQRA) The objective of this program is to mitigate the actions of threats by reducing the probability of event occurrence, reducing impacts of undesirable events or transferring risk in terms of recovery planning or insurance. Vulnerabilities are identified that suggest the possibility of undesired events, their possible causes and effects and safeguards identified, so that credible scenarios can be developed to describe how "most likely worst-case" events might occur and make qualitative estimates of the consequence and probability of each scenario. The scope of this review is established by the owner/operator using qualitative risk assessment through risk scenario analysis. The review can be applied to address levels of protection for operations, special activities, sensitive information, and changes in threat levels and to evaluate security following major security incidents. Hazards Analysis for Machinery Safety (HAZAMS) The objective of HAZAMS is to reduce the frequency and consequence severity of human/machinery incidents by recognizing and mitigating hazards. HAZAMS program is a 14 systematic approach to identify, evaluate and control hazards involved in the human/machinery interface. This methodology may be applied to any human/machine interface where direct contact with machinery is far more frequent than in the typical petrochemical process unit. HAZAMS is designed especially for applications in polymers and film finishing operations. Other Lesser-Known Methods for Process Hazard and Safety Analysis A large number of other methods have been published in the open literature but have not been widely used in the petroleum industry. Tixier et al. (2002) reviewed 62 methods and classified them based on the type of input and output, data required, type of method (deterministic, probabilistic, qualitative, quantitative), relation between input and output data and risk hierarchy. Some examples are listed below: • Quantitative multi-attribute approach for risk analysis (Christen et al., 1994) • Generalized model of hazard systems (Marshall and Ruhemann, 1997) • Hazard Identification and Ranking (HIRA) (Khan and Abbasi, 1998b) • Computer-based Hazard Identification (HAZID) (McCoy et al., 2000) • Optimum risk analysis (Khan and Abbasi, 2001) • Safety Weighted Hazard Index (SWeHI) (Khan et al., 2002) • Hybrid Hazard identification (Viswanathan et al., 2002) • Tool for Rapid Risk Assessment in Petroleum Refinery and Petrochemical Industries (TORAP) (Khan & Abassi, 1999) • Risk-Based Corrective Action (RBCA) for chemical releases (Chen, Wu, Kao, Yang, 2004) • North Carolina Risk Analysis Framework (Chen, Wu, Kao, Yang, 2004) • Illinois Tiered Approach to Correction Objectives (TACO) (Chen, Wu, Kao, Yang, 2004) • Exposure and Risk Assessment Decision Support System (Chen, Wu, Kao, Yang, 2004) 15 Risk Management Program Risk management is the identification of risks, the implementation of measures aimed at reducing the likelihood of those risks, and decision making to implement risk reduction measures. Risk management must cover the entire lifecycle of a project and all activities at a facility. Key elements in a risk management program are shown in Figure 1 and include hazard and risk identification; consequence analysis; control or treatment responses (management); procedures, training; emergency planning; incident investigation and audits (Greenberg & Cramer, 1991). Figure 1. Risk Management Program Elements (Greenberg and Cramer, 1991) In the United States, comprehensive risk management programs have been promulgated by relevant regulatory agencies such as the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA). In addition, the American Petroleum Institute (API) publishes recommended practices on many topics including safety, risk management and other engineering practices. Similarly, the Center for Chemical 16 Process Safety (CCPS) of the American Institute of Chemical Engineers (AIChE) publishes Guidelines on safe processing and operations. Risk management practices in the petroleum industry cover the wide spectrum of programs and activities included in these regulations, recommended practices and Guidelines. In response to industry needs, API published Recommended Practices 750, “Management of Process Hazards.” This API document provided recommended practices for the management of process hazards during design, construction, start-up, operation, inspection, maintenance and modification of facilities in eleven specific managerial areas. These areas include process safety information, process hazards analysis, management of change, operating procedures, safe work practices, training, assurance of the quality and mechanical integrity of critical equipment, pre start-up review, emergency response and control, investigation of process-related incidents, and audit of process hazards management systems. The petroleum industry started implementing the recommended practices embodied in API RP-750 prior to the promulgation of the OSHA PSM regulation. It should be noted that all the practices recommended in API RP-750 are included in the OSHA PSM regulation. As a result, the petroleum industry has mature programs in place that ensure the implementation of all elements of the PSM regulation. Other publications, programs and services from API for the petroleum industry cover the exploration and production, petroleum measurement, marine transportation, marketing, pipeline, refining, safety and fire protection, storage tanks, valves, industry training, health and environmental issues, and policy and economic studies. In particular, API with other petroleum industry practitioners has developed Risk Based Inspection (RBI) as one of the methodologies that are widely used in industrial practice. The Clean Air Act Amendments of 1990 contained specific mandates requiring OSHA and EPA to establish regulations to protect workplace employees, the public and the environment. OSHA fulfilled its mandate in 1992 by promulgating the Process Safety Management (PSM) regulation. EPA, on the other hand, promulgated the Risk Management Program (RMP) 17 regulation in 1996. The Clear Air Act Amendments of 1990 also established the Chemical Safety and Hazard Investigation Board. The objective of OSHA’s PSM regulation is to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. PSM defines fourteen elements of a comprehensive safety management system integrating technologies, procedures and management practices. As discussed earlier, the petroleum industry had already started implementation of most of the practices required under the PSM regulation because of API Recommended Practices 750. EPA’s RMP regulation requires regulated facilities to develop and implement appropriate risk management programs to minimize the frequency and severity of chemical plant incidents. It aims at protecting the public and the environment. Regulated facilities are required to register with the EPA and to develop and implement a program that has three elements: hazard assessment, a prevention program and an emergency response plan. Information about the risk management program must be submitted to the EPA in a document known as the Risk Management Plan. EPA shares the information in the Risk Management Plan with federal, state, local authorities and the community. The Center for Chemical Process Safety (CCPS) of the American Institute of Chemical Engineers (AIChE) presented a comprehensive risk management program with twelve elements (Greenberg and Cramer, 1991). Risk Acceptance and Risk Criteria As the statement “one can only manage what one measures” illustrates, to manage the risk of an industrial installation, one must first identify, estimate, rank and compare the risk with generally accepted risk criteria. A risk assessment or evaluation result must be judged against a “level of goodness,” which is an evaluation criterion or an acceptable level of risk. 18 This section provides an overview of risk acceptance and risk criteria. First of all, there are no general risk criteria applicable to each and every technology under any regulatory program. Criteria are relative and involve consideration of various factors. Considerations in these judgments may include the uncertainty and severity of the risk, the reversibility of the health effect, the knowledge or familiarity with the risk, whether the risk is voluntarily accepted or involuntarily imposed, whether individuals are compensated for their exposure to the risk, advantages of the risk activity, and the risks and advantages for alternatives (Baruch, 1988). Some general guidelines for developing risk criteria are (Fischhoff, 1988): • Acceptance criteria must be based on measures of total risks that express the probabilities and consequences of the incidents. The criteria must also account for regulatory requirements, accepted norms and the company’s own experiences and value system. • The result of risk evaluation must be assessed in relation to the risk acceptance criteria. Also, the risk evaluation results and the risk acceptance criteria must express the risk on the same scale of measurement. • The scale of measurement must be in ordinal type or higher since the decision could be in terms of “better than/worse than” criteria. • The risk analysis must be sensitive to differences in the risks among alternative designs and solutions. The ALARP (as low as reasonably practicable) technique is one method used in the establishment of risk criteria. The general framework for this technique is represented by the three-tier system in Figure 2 (Wells, 1996). The risk level boundaries vary along with the number of people at risk. The values vary depending on the industry sector, safety philosophy implemented by the industry and the practicality of applying risk reduction techniques. 19 Figure 2. Level of Risks and ALARP (Adapted from Wells, 1996, Source: Health and Safety Executive, 1992, the tolerability of risk from nuclear power stations) The ALARP principle is applied to the intermediate region between the unacceptable and acceptable bounds where further individual and societal risk reductions are required to achieve a level considered “as low as reasonably practicable”. The ALARP techniques can be converted into a risk matrix as a guide to decision-making, as shown in Figure 3. 20 Unacceptable risk ALARP region Acceptable risk Figure 3. An Example of Risk Acceptance Criteria Based on Risk Matrix (Adapted from Kjellen & Sklet, 1995) The boundary values for the ALARP are case-specific and depend on compliance requirements and company policy. These values usually depend on risk-benefit analysis. Examples of acceptable values of risk available in the public domain are compiled in Table 3. 21 Table 1. Published Acceptable Values of Risk Risk Criteria (death/year) Canvey Island report, UK (1978) (Wells, 1996) 35 x 10-6 / y Netherland (Wells, 1996) 1 x 10-5 /y unacceptable N = 10 1 x 10-7 /y acceptable Netherland (Wells, 1996) 1 x 10-7 /y unacceptable N = 100 1 x 10-9 /y acceptable Health and Safety Executive, Royal Society, UK 1 x 10-5 /y upper limit (1983)* (Wells, 1996) 1 x 10-6 /y acceptable 1 x 10-7 /y for sensitive population Du Pont (Wells, 1996) 1 x 10-5 / y BNFL (Thorp reprocessing plant, UK) (Wells, 1996) 1 x 10-5 / y UK Central Electricity Generating Board, Nuclear 1 x 10-5 / y upper limit Power (Wells, 1996) Sizewall B, UK (1987) (Wells, 1996) 1 x 10-5 /y design 1 x 10-5 /y normal Russia (Yelokhin & Tshovrebov, 2004) > 10-4 /y inadmissible level 10-4 to 10-5 /y risk control < 10-5 / y acceptable Russia (Societal risk) (Yelokhin & Tshovrebov, 2004) 10-4 /y unacceptable for 25 or more adults exposed to fatal danger 10-5 deaths/y unacceptable for 25 or more children, old men, patients to build hospital, pre-school and children’s establishment. Norwegian Petroleum Directorate (Hobbs, 1999) 10-4 /y for each accident type * Adopted by USA’s National Census of Fatal Occupational Injuries (Hobbs, 1999) 22 Inherent Safety Principles The basic concepts of inherent safety were formalized by Kletz (1984, 1991) and include intensification, substitution, attenuation and simplification. Application of inherently safer design (ISD) concepts is more efficient and cost effective for new design and construction; however, the challenges for existing facilities are quite different. Most importantly, however, for new as well as existing plants, the application of inherently safer design concepts must be considered with a holistic assessment of risk. Finally, unintended consequences such as risk migration/transfer, risk accumulation and overall risk must also be addressed during the consideration of inherently safer design concepts. Modern petroleum/petrochemical plants usually have multiple layers of protection. The layers of protection for loss prevention are classified into four categories in a decreasing order of reliability: inherent, passive, active and procedural (Bollinger et al., 1996). Inherent protection eliminates or reduces a hazard by using materials and process conditions that are non-hazardous or less hazardous. Passive protection minimizes a hazard by process and equipment design features that reduce either frequency or consequence of the hazard without the active intervention of any person or device. Active protection refers to engineering controls used to detect and correct process deviations, such as process controls, safety interlocks and emergency shutdown systems. Procedural protection refers to administrative controls to minimize the effects of an incident, such as operating procedures, administrative checks and emergency response. Inherent safety has actually been embedded into process hazard identification and analysis in existing regulatory programs and recommended practices. The petroleum industry routinely explores and considers opportunities for inherently safer design in material and equipment selection, process development and design, plant layout and management of change. However, as discussed earlier, in considering inherently safer options, appropriate consideration must also be given to other issues such as available resources, unique aspects of 23 the process, configuration of equipment and piping, local laws and regulations and the entire lifecycle of the process. Intensification Intensification attempts to reduce the amount of hazardous material inventory and this principle is applied to many processes in the petroleum industry. For example, hazardous conditions in a distillation column can be reduced by minimizing the size of reflux accumulators and reboilers; using internal reflux condensers and reboilers where practical; using column internals that minimize hold-up without sacrificing the operating performance; reducing the amount of material in the column base by reducing the diameter of the column base; and preventing the toxic, corrosive or otherwise hazardous material from spreading as early as possible in the distillation sequence. An example of the intensification implementation into well-known technology without the necessity of new technology is shown in Figure 4, which displays two designs for a distillation unit to separate liquefied petroleum gases (LPG). In the alternative design (b) in Figure 4, the applied intensification actions include: • The reflux drum is removed, and hence the reflux pump takes the liquid directly from the condenser. The design of the condenser is reversed so that the LPG is in the shell side while the refrigerant enters the tube side. • The buffer storage for the product is eliminated and the flow proceeds directly to the storage areas from a small surge drum. • A low-hold-up packing is used in the column and is reduced to a 2-minute residence time by narrowing the base while maintaining the liquid head. 24 Storage Steam ORIGINAL DESIGN (a) Surge drum Low inventory packing Steam Narrow section to provide head but reduced inventory MODIFIED DESIGN (b) Figure 4. Two Designs for Liquefied Petroleum Gas Separation Unit (Adapted from Kletz, 1991) 25 Substitution The substitution principle attempts to use less hazardous materials and/or alternative processes. Some alternative chemicals may on the surface seem less acutely hazardous while introducing or increasing other forms of hazards. When the substitution principle is applied, hazards associated with the substituted materials must be considered and explored completely. Risk migration/transfer might occur when regulation precedes science as in the substitution of Tetra Ethyl Lead (TEL) with Methyl Tertiary-Butyl Ether (MTBE) as an additive for fuel to increase the octane number. The octane rating is one of the most important characteristics of gasoline and other fuels used in spark-ignition internal combustion engines and are a measure of how resistant the fuel is to premature detonation (knocking). Higher octane ratings correlate with less likelihood that a given compression ratio will cause knocking. Typical "octane booster" additives include TEL and toluene. TEL consists of a lead atom bonded to a tetrahedral arrangement of an ethyl group with a weak carbon-lead bond. At a certain temperature in an internal combustion engine, TEL decomposes into lead and ethyl radicals and helps to propagate the combustion. Studies have shown some problems associated with using TEL as a fuel additive to increase the octane number. Exposure to even low levels of lead can cause permanent brain damage, yet, a catalytic converter that helps remove environmentally unfriendly gases such as CO and NOx cannot be used on leaded gasoline because the lead 'poisons' the catalyst. To avoid such problems caused by TEL, the Clean Air Act banned the use of leaded fuel in 1996. Another methodology to improve gasoline octane rating is Oxygenate Blending. Toxic gases such as CO and NOx are produced by incomplete combustion, and MTBE is a chemical compound that is mandated by EPA as a fuel additive in gasoline to provide extra oxygen for 26 complete combustion. The resulting fuel is known as reformulated gasoline (RFG) or oxygenated gasoline. Refiners have added MTBE to gasoline to meet the Clean Air Act (CAA) requirements. While the use of MTBE as a fuel additive in gasoline has helped to reduce harmful air emissions, it has also caused concern relating to the nation's drinking water supplies. A valuable lesson that must be learned is that substitution or seemingly safer options are not always as simple as they might appear on the surface. Unlike other components of gasoline, MTBE dissolves and spreads readily in groundwater underlying a spill site, resists biodegradation and is difficult and costly to remove from groundwater. Low levels of MTBE can render drinking water supplies non-potable due to its offensive taste and odor. At higher levels, MTBE may also pose a health hazard. The United States Geological Survey has found that the existence of MTBE in groundwater is strongly related to its use as a fuel additive with detection of MTBE in 21% of ambient groundwater in areas using RFG compared with 2% of ambient groundwater in areas using conventional gasoline. EPA has issued an advance notice of its intent to initiate a rulemaking to eliminate or limit the use of MTBE as a fuel additive. Clearly the well-intentioned effort to eliminate the hazardous effects of TEL resulted in the unintended consequences and adverse impacts from MTBE use. Attenuation Attenuation is to operate, store and transport materials under less hazardous conditions or forms. An attenuation practice in the petroleum industry is the refrigeration system for LNG (liquefied natural gas) storage. Refrigeration can reduce hazards by reducing the storage pressure and therefore the immediate vaporization and liquid aerosol formation upon leaking. In Figure 5, applied attenuation actions include: • Atmospheric pressure Storage at atmospheric pressure reduces the driving force (pressure difference) for a 27 leak to the outside environment, thus reducing the immediate vaporization of leaking LNG. • Cryogenic temperature, below –260oF A flammable material should be stored below its boiling point whenever possible, especially where the rate of liquid leak flow depends only on liquid head or pressure with insignificant contribution from vapor pressure. Natural gas has an atmospheric boiling point of -260oF. The flow through any hole on the vapor space will be limited below this temperature. • Liquid phase Natural gas in the form of liquid has 600 times less volume as in the form of gas. Natural gas in the form of gas is very hard to handle in the event of leaks (forms plume or puff vapor dispersion) and is easier to combust. Figure 5. LNG storage tank (Source: Center for Liquefied Natural Gas) 28 Simplification The simplification principle applies in process design to minimization of components vulnerable to failure or leak (e.g., welded pipe is preferable to flanged piping, threaded piping should be avoided for flammable and toxic materials, and sight glasses and flexible connectors, such as hoses and bellows should be eliminated wherever possible). A liquid transfer system that uses gravity, pressure or vacuum is usually preferable because it does not require moving parts or seals that can lead to potential leaks and failures. An example of simplification is the pumped acid reactor and gravity flow reactor designs for hydrofluoric acid alkylation in Figure 6 and Figure 7. However, it must be noted that depending on the circumstances, one or the other design may be more appropriate depending on the unique aspects of the process, configuration of equipment and piping, and local laws and regulations. Cooling Water Effluent to Isostripper Reactor Feed and Recycle Isobutane Pump for pumping the acid from the reactor Figure 6. Pumped Acid Reactor Technology (Chang, 1993) 29 Figure 7. Gravity Flow Reactor Technology (Chang, 1993) Summary Lessons learned have shown that effective risk management is of fundamental importance, not only for the lifecycle of the facilities but also for sustainable development. This document discusses the petroleum industry in general, hazards present in this industry and risk management programs to prevent incidents from occurring and to minimize the consequences of incidents that do occur. Comprehensive risk management programs mandated under regulations and guidelines and practices recommended by industry organizations are discussed as well. Applications of inherently safer design principles are presented with examples from the petroleum industry. However, to avoid unintended consequences such as risk migration, risk accumulation and potential increase of risk, inherently safer design options should be implemented only after a holistic risk analysis. To manage risk, we must learn to identify and measure risk. With the acceptance of this objective, hazard identification and risk assessment methodologies applied in the petroleum industry are described including general risk assessment methods and specific risk assessment programs tailored to meet the special needs of the petroleum industry. 30 Appendix Concepts of Risk and Associated Terms It is important to establish an understanding of some terms associated with these concepts. The following the terms used in Risk Risk is the product of the measured or estimated magnitude of the consequence of a failure multiplied by the measured or estimated likelihood of an impact on the target (i.e., risk = frequency × consequence severity or magnitude). Risk Analysis The development of a qualitative (textual) or quantitative (numerical) estimate of risk based on engineering evaluation and mathematical techniques for combining estimates of incident consequence and frequency. Failure The inability of a system or system component to perform a required function within a specified time or performance limits. Hazard An inherent chemical or physical characteristic that has the potential to cause an incident. Hazardous Material Any substance or mixture of substances with the capability of producing adverse effects on the health or safety of human beings or the environment. Individual Risk The frequency at which an individual may be expected to sustain a given level of harm from 31 the realization of specified hazards. Inherent Safety Where upon the occurrence of non-acceptable deviations from normal operating ranges, a system maintains or moves to a non-hazardous status. Inherently Safer Option Process design that seeks to eliminate or reduce hazards at the source. Practical Risk Reduction Measures Methods to reduce the risk of an incident event by evaluating hazards and risks of a process, evaluating the source(s) of the hazard(s), and acting on those sources in a preventive or protective way based on the results of the hazard/risk evaluation. Residual Risk The remaining risk after all practicable improvements to a facility under study have been made. Probability A number that expresses the likelihood of occurrence of a possible state of an uncertainty. By definition, a probability must be a number between 0 and 1, and the sum of probabilities for all possible states of an uncertainty must be 1 (CCPS, 1995b). Frequency The number of occurrences per unit time at which an observed event occurs or is predicted to occur (CCPS, 1992). 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Journal of Risk Research, 7, 6, 609-612 Zwetsloot, G., Askounes-Ashford, N., 1999, Towards inherently safer production, A feasibility study on implementation of an inherent safety opportunity audit and technology options analysis in European firms, TNO Report R990341, The Netherlands (June) http://www.osha.gov/dts/osta/otm/otm_iv/otm_iv_2.html http://www.netl.doe.gov 39 Contact: Dr. M. Sam Mannan Mary Kay O’Connor Process Safety Center Texas A&M University 3122 TAMU College Station, TX 77843-3122 Phone: 979/845-3489 Fax: 979/458-1493 http://process-safety.tamu.edu 40