Fossil Generation & the Process Safety Management Standard

Fossil Generation & the Fossil Generation & the Process Safety Management Process Safety Management

StandardStandardEEI Occupational Safety & Health

Committee ConferenceDavid A. Hurban, PEDavid A. Hurban, PE

The Goal of Process Safety

To provide a comprehensive management system that instills the discipline of containing and controlling chemicals from delivery to final disposition resulting in the protection of personnel, the public, and the environment.

Keeping it Simple

A Management System to Protect People from the Hazards of the Process.

Process Safety

What Initiated Process Safety?

• Flixborough, England 1974– Cyclohexane VCE; 28 Fatalities

• Seveso, Italy 1976– Dioxin Release; 2000 Treated

• Bohpal, India 1984– MIC Release; 3,800 Fatalities

• Pasadena, Texas 1989– Flammable Gas VCE; 23 Fatalities

How Did The Standard Evolve?

• 55 FR 29150 Proposed Standard– Issued July 17, 1990

• Comment and Hearing Period– Ended June 5, 1991– 175 Comments, 4000 Pages Testimony

• Final Rule 29 CFR 1910.119– Issued February 24, 1994

Potential Covered Processes for Fossil Generation

• Chlorine for Water Treatment.– TQ 1500 lbs

• Anhydrous Ammonia for ESP & Flue Gas Treatment– TQ 10,000 lbs (29CFR1910.111)

• >44% Ammonium Hydroxide for SCR NOx Reduction– TQ 15,000 lbs

• Hydrogen for Generator Cooling– TQ 10,000 lbs (29CFR1910.103)

Implementation in Electric Industry

• Denial by maintaining inventories below threshold quantities.

• Avoidance through concentrations less than those regulated.

• Afterthought implemented by chemists and industrial hygienists.

• These approaches do not make the process safer.

Denial

Avoidance

Afterthought

Why the Reluctance

• Hard to do• Complicated• Small Part of the Overall Plant• Make Electricity not Chemicals• Experience and Expertise• Costs $$ Money $$

Can This Happen in Your Plant?

• An accident on January 30, 2007, at the Little General Store in Ghent, WV killedfour people and injured six others when propane gas was suddenly released through a liquid withdrawal valve during a changeover between two propane tanks. A volunteer firefighter and an EMT who responded to reports of the leak were among those killed when the propane cloud ignited, destroying the store.

Think About Coal Dust

• On February 7, 2008, a huge explosion and fire occurred at the Imperial Sugar refinery northwest of Savannah, Georgia, causing 14 deaths and injuring 38 others, including 14 with serious and life-threatening burns. The explosion was fueled by massive accumulations of combustible sugar dustthroughout the packaging building.

Do you Have Ammonia on Demand?

• On June 11, 2008, one worker was killed and approximately seven others were injured, during a maintenance operation on a heat exchanger. Ammonia over pressured inside the exchanger, causing it to rupture.

Is this a Potential Hazard in our Waste Water Systems?

• On July 29, 2008, three workers died and a fourth was injured when an explosion occurred inside an 80-foot-tall storage tank at the Packaging Corporation of America (PCA) corrugated cardboard mill in Tomahawk, Wisconsin. The workers were on a catwalk above the tank and performing hot work (welding) at the time of the explosion. The storage tank held a mixture of recycled paper pulp and water.

Elements of Process Safety

• Employee Participation

• Process Safety Information

• Process Hazards Analysis

• Operating Procedures• Training• Contractors• Pre-startup Safety

Review

• Mechanical Integrity

• Hot Work Permit

• Management of Change

• Incident Investigation• Emergency Planning• Compliance Audit• Trade Secrets

Key Elements of Process Safety

• Employee Participation• Process Safety Information• Process Hazards Analysis• Operating Procedures• Training• Pre-startup Safety Review• Mechanical Integrity• Management of Change• Incident Investigation

Element of ISO 9000 Quality Management Systems (QMS)

• Management Responsibility • Quality System • Order Entry • Design Control • Document and Data Control • Purchasing • Control of Customer Supplied

Products • Process Control• Product Identification and

Tractability

• Control of Nonconforming Products

• Inspection and Test Status • Control of Quality Records • Training• Corrective and Preventive Action • Servicing • Handling, Storage, Packaging,

and Delivery • Internal Quality Audits • Statistical Techniques• Inspection and Testing Control of

Inspection, Measuring, and Test Equipment

Key Elements of a QMS

• Management Responsibility • Design Control • Document and Data Control • Purchasing • Process Control• Product Identification and Tractability• Control of Nonconforming Products • Training• Corrective and Preventive Action • Inspection and Testing Control of Inspection,

Measuring, and Test Equipment

How These Compare

• Employee Participation• Process Safety

Information• Process Hazards Analysis• Operating Procedures• Training• Pre-startup Safety Review• Mechanical Integrity• Management of Change• Incident Investigation

• Management Responsibility • Design Control • Document and Data Control • Purchasing • Process Control• Product Identification and

Tractability• Control of Nonconforming

Products • Training• Corrective and Preventive Action • Inspection and Testing Control of

Inspection, Measuring, and Test Equipment

Take Home Message

• Occupational Safety Protects People from Hazards in the Workplace

• Quality Management Protects the Customers from Defects and Manufacturers from Rework

• Process Safety Protects People from the Process

• They Share the Same Fundamental Building Blocks

Protect Your People From These Processes

• High Pressure High Temperature Steam• Explosive & Flammable Hydrogen• Toxic Ammonia & Chlorine Vapors• Reactive & Corrosive Acids & Caustics• Combustible Fuel Oil• Large Volumes of Natural Gas• Hot Sulfur• Coal Dust