Process Safety Considerations for Onshore Oil & Gas Production Facilities

Jan Kulmann, PE

Manager, Engineering Technical Services Major Projects, DJ Basin

It’s Not PSM, It’s Risk Management

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Different  precursor  events:    Personal  Safety  and  Process  Safety  

Fatality  /  Major  Injury    

Non-­‐injury  accidents  Near  misses    

Unsafe  working  condi<ons    

Minor  injury    

Loss  of  containment  Exceeding  opera<ng  envelope  

Degrada<on  of  opera<ng  procedures    Igni<on  sources  created  

 

Personal  injury  

High  poten<al  incidents    

Major  accident  (Process)  

Fire    Explosion  Fatali<es  

Precursor  

even

ts  

   Unsafe  acts    

It’s Not PSM

 What is PSM?   OSHA regulation 29 CFR 1910.119 Process Safety Management (PSM) of highly

hazardous chemicals became effective on May 26, 1992   The goal of a Process Safety Management (PSM) program is to ensure that process

facilities are operated safely   PSM programs focus on major process-related events such as fires, explosions and

the release of toxic chemicals   Addresses the management of Highly Hazardous Chemicals (HHC)

 What makes my facility PSM?   A process with =>10,000 lbs (4535.9 kg) or more of a flammable liquid or gas on site

in one location, or   A process with a threshold quantity or more of a highly hazardous chemical (HHC).

An examples found in natural gas plants is…   Hydrogen sulfide =>1,500 lbs.

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It’s Not PSM

 PSM Exceptions   Storage of hydrocarbon fuels used only for workplace fuel (such as propane for

comfort heating, gasoline for vehicle refueling), if not a part of a process covered by this standard;

  Storage or transfer of flammable liquids in atmospheric tanks which are kept below their normal boiling point without benefit of chilling or refrigeration.

 Facilities that are not covered under PSM   Retail facilities   Oil or gas well drilling or servicing operations

  Normally unoccupied remote facilities   Oil and gas production facilities   Oil and gas transmission facilities (DOT Regulated)

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It’s Not PSM

But…..  Colorado & Federal Regulations Getting Stronger, not Weaker

  COGCC, CDPHE, API, OSHA

 Colorado Activity Increasing   Public awareness increasing   More complex operations, higher volumes, higher pressures

  It’s all about managing risk

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People Processes Plant

Incident Hazard

Noble’s Response

Process Safety Focus Team  Objective: Define, implement and improve key Process Safety

Standards, Competencies and Practices that will reduce the probability of Process Safety related incidents

 Management Identified Key Areas:   Plant – Facility Design, Construction, Commissioning, Start Up Practices   Processes – Operational Procedures and Practices   People – Competency, Leadership, Culture, Training and Behaviors   Specific Focus Area – Oil Tank Practices, Air Emissions*

*Colorado emissions regulations

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It’s Risk Management

But…  Elements of PSM useful for Production Facilities:

  Process Safety Information   Process Hazard Analysis (PHA)   Operating Procedures   Training

  Mechanical Integrity   Management of Change

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Process Safety Information (PSI)

 Needed Documentation   P&IDs   PFDs   Vendor Equipment Data

  Cause & Effect Diagrams   Electrical Area Classification   Chemical Hazard Information

 Document/Drawing management   Redline management   Storage for future reference

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Process Hazard Analysis (PHA)

 Developed for new designs or changes to current designs   Methods adjustable based on complexity of project

  What-if   Checklist   Hazard and Operability Study (HAZOP)

 Team Review   Includes Operations and Engineers

  Identifies Process Hazards   Identifies ways a hazardous incident can occur

  Evaluates the likelihood and the severity of the hazardous incident   Develops recommendations to eliminate or control the hazard

 Timing of this process is key

 Follow up required

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Operating Procedures & Training

 SOPs unique to each location/process  Pre Safety Startup Review (PSSR)

  Confirms construction and equipment match design   Confirms PHA recommendations implemented   Confirms SOPs in place and training complete

 Training specific to equipment on site   Manual with equipment procedures   Ongoing training and validation

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Mechanical Integrity

 Program development from current practices   Leverage PSM software   Contracted inspections   Document management

 Critical equipment list for maintaining data   Know what needs to be collected & managed

  Make sure inspections actually address any current failures

 Analysis of data for risk management   Baseline data vs. lifetime calculations   Data, data, data!

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Management of Change (MOC)

 Assures change is recognized by all personnel  Assures change is reviewed and evaluated before implemented

  Includes changes in:   Personnel

  Procedures   Equipment   Technology   Chemicals

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Risk Management

 All elements work together

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Process Safety

PSI

PHA

SOPs

Training

MI

MOC

Wrap Up

 Leadership support/commitment is critical for success  Many elements underway but may not be in a “program”

 Continuous improvement lives on

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Questions

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