Lectura 4 - Major Hazard Risk Assessment For Existing and New Facilities

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Major Hazard Risk Assessment

for Existing and New Facilities


Katherine (Kate) Filippina and Lachlan Dreherb
a
ModuSpec USA, Inc., Katy, TX 77450; kate.filippin@moduspec.com (for correspondence)
b
ModuSpec Australia Pty Ltd., Melbourne VIC 3000, Australia

Published online 29 November 2004 in Wiley InterScience (www.interscience.wiley.com). DOI 10.1002/prs.10045

This paper outlines a risk assessment methodology prise’s undertakings and thereby constitute critical
that has been developed through work with major haz- input to the enterprise’s overall risk management
ard facilities, including ammonia plants in Australia, strategy. A sound and systematic approach to risk man-
satisfying regulations equivalent to the European agement, based on a coherent and logical risk manage-
Seveso II Directive. The methodology is an approach for ment strategy, facilitates compliance with relevant leg-
ensuring an undertaking of effectively assessing the islation and in-house corporate policy where
risks associated with major hazards that will not only applicable.
satisfy regulations and corporate requirements, but This paper outlines a risk assessment methodology
also, more importantly, provide a framework for sus- developed through work with a range of major hazard
tainable business processes, by enabling the methodol- facilities in Australia. The methodology is an approach
ogy to be integrated into normal business management for ensuring a full understanding of the risks associated
processes. The approach enables existing management with major hazards that will not only assist with meet-
systems to be effectively incorporated into the evalua- ing regulations and corporate requirements but, more
tion processes. Common pitfalls encountered during important, also provide a framework for sustainable
the risk assessment process are also discussed. © 2004 business processes and a safer environment for em-
American Institute of Chemical Engineers Process Saf ployees and the wider community. Common pitfalls
Prog 23: 237–243, 2004 encountered during the risk assessment process are
also discussed.
INTRODUCTION
The concept of managing major hazard facilities is OBJECTIVE
not a new one, but there is a growing regulatory envi- The objective of the methodology is to reduce the
ronment that requires more analysis and better docu- risk from major hazards to as low as reasonably prac-
mentation of how a facility is being managed and, ticable (ALARP) [7] or so far as practicable (SFAP) [4].
specifically, how the risks are being managed. The This is achieved through reducing risk associated with
European Seveso directive, risk assessment regulations the facility’s:
in Norway, COMAH regulations in the United King-
dom, Major Hazard Facility Regulations in Australia, • Identified largest hazards
and U.S. OSHA PSM and the U.S. EPA Risk Manage- • Identified largest potential major incidents
ment Program all require a thorough understanding of A flow diagram of the basic steps in this process is
major hazards and risks for these types of facilities shown in Figure 1. The stages of this process are dis-
[1– 6]. cussed in the following sections.
Operators, as well as other relevant parties (such as
contractors), have a duty to ensure that appropriate risk HAZARD IDENTIFICATION
analyses are carried out for the activities in which they A systematic hazard identification study must iden-
are involved. The aim of these risk assessments is to tify all potential major incidents associated with the
identify hazards that are present, then remove or re- facility operations. This is a critical component of the
duce the occurrence of potential incidents or minimize risk assessment. To ensure a successful risk assessment
their associated consequences. Risk analyses provide outcome, it should demonstrate site participation and
knowledge concerning risks resulting from an enter- involvement.
Employee involvement can have a significant impact
© 2004 American Institute of Chemical Engineers on developing a risk-reduction culture in the organiza-

Process Safety Progress (Vol.23, No.4) December 2004 237


Figure 1. Risk assessment process.

tion. This is a major benefit, as employees through all • Sensitivity of the local environment
levels of the organization gain a greater understanding
of the risk from the operations and how the tasks that Historical Incidents
they are involved in control that risk. The major benefit A review of historical incidents in the industry will
of site participation is a high level of ownership and provide valuable information about the major incidents
acceptance of the outcomes at the conclusion of the that are known to the industry and their causes. These
risk assessment process. This will allow easier imple- should be reviewed for the particular process or type of
mentation of any recommendations, either procedural industry, such as ammonium nitrate plants, ammonia
or design related. plants, urea plants, and ammonia storage facilities.
The facility will also get a better result if the whole Consideration should also be given to other industries
risk assessment process is part of the culture and not that operate similar facilities.
done in isolation. We have had significantly more suc- Facilities that are already operational should also
cess by incorporating the personnel undertaking the review their site incident database. Companies with
risk assessment into the facility’s working process and several sites should also review incident databases
involving a high level of operating personnel. This is from other facilities within the same organization. This
contrasted with minimizing the risk assessors’ involve- should cover any incidents that have occurred as well
ment in the plant and using them only to answer as any near misses. Near misses provide a much greater
specific questions when difficulties with compliance or number of potential incidents to consider, above actual
difficulties with the regulators occur.
incidents. These can provide information about inci-
To ensure that all the potential major incidents are
dents that did not happen, but may need additional
identified, a number of hazard identification techniques
controls to ensure they are not likely to happen in the
should be used. These are outlined in the following
future.
sections. It should also be noted that the selection of
A common mistake made by operators is to disre-
the appropriate hazard assessment technique should
gard or not follow up on near misses. Near misses are
consider a range of issues, including:
a warning and should be used to the advantage of the
• Nature of the potential hazards organization, not left with the potential to reoccur in
• Culture of the facility’s workforce the form of an incident.
• Position of the facility in relation to the surround- If an incident database does not exist, then one
ing community should be set up to record any incidents or near misses.
• Complexity of the process These should be regularly followed up in detail.

238 December 2004 Process Safety Progress (Vol.23, No.4)


Another common oversight involves organizations leases continued for approximately 6 days after the
that are limited to single or few facilities. When con- explosion.
ducting the hazard identification process in these orga- Four people were killed as a direct result of the
nizations, it is common to encounter the attitude that “it explosion, and 18 were injured and required hospital-
hasn’t happened to us, therefore it will not happen.” It ization.
is very important that such organizations take a broad Comments. The investigation team concluded that
view to hazard identification and consider the experi- the explosion resulted from a lack of written, safe
ence of the wider industry and not purely their own operation procedures at the Terra Port Neal ammonium
site. nitrate plant. The lack of safe operating procedures
The review of historical incidents should be under- resulted in conditions in the plant that were necessary
taken early in the risk assessment process. The infor- for the explosion to occur.
mation arising from the review can then be considered Reference. [12]
as part of the remaining hazard identification steps [8]. Review significance. The significance of this incident
is that the documented cause (inadequate safe operat-
ing procedures) is not restricted to the ammonia indus-
Sample of Historical Incidents try. Thus, it is also suggested that wide reading of
Date of incident. 21 September 2001 historical incidents would be advantageous because
Location. AZF (Azote de France) in an industrial the fundamental causes of many accidents are not in-
zone on the outskirts of Toulouse, southwest of France dustry specific. These shortcomings (poor procedures)
Type of facility. Ammonium nitrate fertilizer factory can be addressed by the involvement of employees in
Incident description. The explosion had occurred in the risk assessment process. A greater understanding of
a warehouse in which granular ammonium nitrate was the risks and the importance of various procedures will
stored flat, separated by partitions. The amount was reduce the likelihood of employees making mistakes.
reported to be between 300 to 400 tons of ammonium As with the previous example, training and regular
nitrate, which is used to make fertilizers. A representa- auditing were also required to ensure that management
tive for the Interior Ministry in Paris ruled out a criminal of this issue was fully understood.
attack. He reported that the explosion had been caused
by an accident following an “incident in the handling of Hazop/Hazid
products.” As a result of the incident, 30 people died: The classical “Hazop” technique has been devel-
22 inside the factory and 8 outside. oped over four decades, and is centered on “process
Comments. The theory of an accident remains for flow,” as would be seen in a chemical plant. It is a
the explosion at the AZF factory. One of the theories widely used technique to identify potential hazards and
examined relates to contamination of the ammonium operational difficulties associated with the specific de-
nitrate in the warehouse by chlorine compounds. sign of a process plant [13].
References. [9, 10, 11] Hazops tend to identify lower level hazards and
Review significance. Although the details of the in- risks. This is why the Hazop is only one in a suite of
cident cause were not completely clear at the time of hazard identification tools that should be used. The
writing, one of the lessons to learn from this incident advantage, however, is that the whole process is re-
was to make sure there is clear segregation of chemi- viewed and there is less likelihood of missing a hazard
cals. This information is used in the hazard identifica- that may initially seem insignificant, but with more
tion. study can actually lead to a much larger scenario. The
In one case we studied, this issue was examined in Hazop can capture a significant amount of information
detail to document the reason why the operator did not that can be fed into the later stages of the analysis. For
consider an explosion of the ammonium nitrate storage example, the Hazop can identify potential major inci-
(attributed to contamination) to be a significant risk. dents that can be flagged for later follow-up.
Complete segregation of chemicals from storage was This stage of the analysis is conducted in a work-
only part of the argument for why this hazard was not shop format, with the involvement of a number of site
considered a threat. A detailed management system personnel from each section of the facility. A series of
that recognized the dangers of breaching this system, guidewords are used to determine whether there are
with procedures, training, and regular auditing were possible deviations from expected operation. Hazops
also present to ensure management of this issue was help efficiently identify the steps needed to move the
fully understood. design and safety management process forward, and to
Date of incident. 13 December 1994 formally record and document that safety and opera-
Location. Terra Industries, Inc. Nitrogen Fertilizer bility issues have been addressed. This assists in for-
Facility, Port Neal, IA mally demonstrating that hazards have been identified
Type of facility. Ammonium nitrate plant and avoided or the resulting risks have been reduced to
Incident description. Initially an explosion occurred an acceptable level.
in the plant. The explosion resulted in the release of It is important that there is a thorough examination
approximately 5,700 tons of anhydrous ammonia to the of each specific process deviation and that the com-
air and secondary containment, approximately 25,000 ments made in the meeting are summarized fully. This
gallons of nitric acid to the ground and lined chemical should be done in all cases and not just for those items
ditches and sumps, and liquid ammonium nitrate solu- where deficiencies are found. Shortcuts are often taken
tion into secondary containment. Off-site ammonia re- in this area for the sake of expediency at the time of the

Process Safety Progress (Vol.23, No.4) December 2004 239


Hazop, but this has a significant downside later. Re- provides the supporting information to demonstrate
cording the reasons why a hazard is not likely to occur control of risk to an ALARP condition at a facility.
is just as important as documenting why it is likely to One of the mistakes often made is to keep a record
occur. Full documentation of the Hazop is invaluable in of just the controls recommended for implementation.
ensuring that the design intent of a facility is captured. Without details of additional controls that have been
When future modifications are made, the designers can considered and the reasons for their rejection (such as
revisit the original process purposes and design limita- cost, impracticality, etc.), a facility cannot truly demon-
tions to ensure that any proposed modifications do not strate that their risks are controlled to ALARP.
introduce any unforeseen hazards. This stage of the
assessment can significantly reduce the amount of Layer of Protection Analysis (LOPA)
work later, if the documentation is thorough. LOPA [14] can be considered as an extension of the
hazard identification process. It is a simplified fault and
Checklists event tree technique used to identify and assess what
A checklist can be incorporated into a Hazop or safeguards are in place to prevent a hazard from oc-
hazard identification workshop. Checklists provide a curring.
systematic means of checking that potential scenarios The concept of a LOPA is to list the sequence of
have been analyzed. The checklist should incorporate events associated with the manifestation of a hazard in
the generic known failures that could occur in the time order. This provides various insights into what
process. It should also incorporate the lessons learned could or could not happen. The concept relies on the
from the historical review. For example, a checklist for notion that injury, damage, and ill-health are the result
an ammonium nitrate facility would include contami- of the loss of control of damaging energies.
nation as a result of the previous example of historical A fault tree is effectively a statement of what matters
incidents. The checklist is another systematic tool to have to conspire together to bring about an undesired
provide guidance for the workgroup and ensure that event. This shows the sequence of events giving the
the analysis covers the full range of possible scenarios. loss of control of energy.
An example checklist is shown below. An event tree is a similar device except that it an-
swers the questions associated with a particular event
Checklist Example occurring with several possible outcomes. It shows the
outcome after the loss of control of energy.
Equipment Type/Area Initiating Event When combined, these provide a cause– conse-
quence picture (also known as a bow-tie diagram).
Pressure vessels Overfills and spills When the safeguards in place are added to the
Vessel shell failure picture, they are shown as layers of protection. These
External event layers of protection show whether sufficient safeguards
PSV release have been provided for the hazard.
Pumps Mechanical seal failure It is possible to incorporate a qualitative assessment
Coupling failure/fracture to evaluate the adequacy of the controls for a particular
Casing failure incident. Otherwise, the information can be fed into a
External event quantitative assessment for further evaluation. The
Tank (Refrigerated) Material embrittlement LOPA can also be used to identify the critical controls
Overfills and spills for an incident. This information can then be used to
External event—Dropped ensure that appropriate systems are in place for that
objects control to be effective.
Ammonium nitrate Contamination with
storage • chlorides Case Study
• copper An example of the basic information in a LOPA
• zinc analysis is shown in the following example.
• chromate Hazardous scenario progression
Contamination by
• hydrocarbon fuel • Incorrect metal alloy used for storage tank pipe-
• organic substances line joint
Sources of heat • Change in storage conditions favorable to em-
brittlement
• Rupture of pipeline joint and release of ammonia
CONTROL IDENTIFICATION AND RISK EVALUATION The layers of protection identified are
The control identification and risk evaluation will
provide the basis for ensuring that the risk is reduced to • Standards used for material selection during de-
as low as reasonably practicable. sign
The proposed methodology provides an advantage • Management of change procedure for changing
in that the details of all risk controls considered and materials
discussed are recorded for future reference. The rea- • Management of change procedure for change in
sons for choosing an alternative control, or the reason process conditions
for rejecting a specific control, are documented. This • Temperature/pressure alarms on tank for change

240 December 2004 Process Safety Progress (Vol.23, No.4)


in process conditions outside designed operating A variety of processes including risk assessments,
envelope training exercises, consultation with external authori-
• Ammonia gas detectors and alarms in storage ties, field tests, and site inspections are used to assess
plant the emergency response requirements and capability of
• Concrete bund/dike surrounding storage tank a facility and develop appropriate plans.
• Foam monitors surrounding storage area to knock At least two different levels of response plans should
down ammonia vapors be developed.
This information must be examined to evaluate the 1. Generic response plans that detail characteristic ap-
frequency with which the scenario is likely to occur proaches for the first response to a number of gen-
and the protection that each of the controls provides to eral categories of incidents.
reduce the frequency of occurrence. 2. Specific major incident plans, based on specific sce-
narios and provide response for those events.
Quantitative or Qualitative Risk Assessment
The development process should involve opera-
Quantitative risk assessment (QRA) describes a tech-
tions/plant personnel, internal and external emergency
nique that is used systematically to calculate the cumu-
response groups, and validation of the scenario at the
lative likelihood of the consequences of all possible
incident site. The generic plans will provide informa-
hazards associated with a plant or facility [15]. The
tion about:
primary focus of a QRA in this context is the assessment
of events that have the potential to cause injury or • The hazards and possible escalation paths
death to people either inside or outside the facility • The systems and procedures in place for mitigat-
boundary. ing the event at different stages of escalation
The risk assessment process incorporates the use of • The procedures for mobilizing emergency ser-
a QRA, particularly when the location of the facility is in vices and for evacuation
a populated area and when risk acceptance criteria or • The chain of command and control and the ac-
guidelines must be satisfied for individual risk and/or tions required of people in specific response roles
societal risk [16]. The QRA can be used to determine • Integration of emergency response capabilities/
whether the risk is managed at a level considered plans
acceptable. By examining the major contributors to the
risk, and applying mitigation measures to reduce the The specific major incident plans provide informa-
risk from these contributors, the overall risk from the tion on a specific incident. Although it may not be
facility can be reduced. possible to develop a plan for every major incident at a
In the case of a facility located in a remote area or an facility, the selections that are prepared should be se-
unpopulated area, a qualitative assessment can be lected to provide the most information possible about a
used. This is a more coarse approach and will not major incident in an area of the plant. These specific
provide the same level of detail as the QRA. The qual- plans should be used for training in response to an
itative assessment uses a risk matrix to determine the incident. Training can also provide a feedback loop to
level of risk associated with different hazards. The implement continuing improvements in the plans, such
matrix will have regions of acceptability for assessing as testing their actual effectiveness.
the hazards. The advantage to using a specific plan for training is
that the training can use information from the risk
Case Study assessment, particularly the LOPA, and be developed
A QRA was undertaken for an ammonium nitrate around an incident occurring at the initial stages. This
plant. The individual risk guidelines included the fol- will provide awareness of the type of early warning
lowing: signals or alarms that might be seen, which can be
acted on to prevent the incident from developing.
• Residential developments and places of continu-
ous occupancy, such as hotels and tourist resorts, RISK ACCEPTABILITY
should not be exposed to individual fatality risk Determining the acceptability of risk is often the
levels in excess of 1 ⫻ 10⫺6 per year. most challenging aspect of a risk assessment.
Some regulators provide guidelines or criteria for
To demonstrate that the risk was reduced to meet the use with QRA. These can be used to interpret whether
criteria, the individual risk contour for a risk of 1 ⫻ a facility’s risk is considered acceptable for these crite-
10⫺6 per year was determined. The nearest residential ria [17]. There may also be international or national
area was approximately 1 km from the site. This area standards that have been published for a particular
did not fall within the contour for a risk of 1 ⫻ 10⫺6 per process or type of plant.
year and therefore was not affected by this risk level. For example, in the state of Queensland, Australia,
This was used to show that the risk was acceptable for the “Guidelines for Major Hazard Facilities” prepared
this criterion. by the CHEM Unit in association with the Queensland
Government present the following individual risk ac-
Emergency Response Assessment ceptance criteria [18]:
The emergency response assessment is undertaken
to ensure a comprehensive framework has been set up • Hospitals, schools, child-care facilities, and old
to ensure effective response to an emergency. age housing development should not be exposed

Process Safety Progress (Vol.23, No.4) December 2004 241


to individual fatality risk levels in excess of 0.5 ⫻ operation. This will vary depending on the hazards and
10⫺6 per year. controls identified in the process.
• Residential developments and places of continu-
ous occupancy, such as hotels and tourist resorts, RISK DATABASE
should not be exposed to individual fatality risk In our experience, a risk database or risk register is
levels in excess of 1 ⫻ 10⫺6 per year. a valuable tool for a site to use to manage their risks
• Commercial developments, including offices, re- effectively. Such a database can be set up to record
tail centers, warehouses and showrooms, restau- details of all the risks identified at the beginning and
rants, and entertainment centers, should not be during the life of the plant. Each hazardous scenario
exposed to individual fatality risk levels in excess can be recorded, along with pertinent information such
of 5 ⫻ 10⫺6 per year. as:
• Sporting complexes and active open space areas • a unique identifier for each risk
should not be exposed to individual fatality risk • a description of each risk
levels in excess of 10 ⫻ 10⫺6 per year. • an assessment of the likelihood it will occur
• Individual fatality risk levels for industrial sites at • an assessment of the consequences of the risk
levels of 50 ⫻ 10⫺6 per year should, as a target, be being realized
contained within the boundaries of the site where • a ranking of each risk according to a risk matrix
applicable. • who is responsible for managing the risk
The results of a QRA can be examined against these • an outline of the existing controls in place to
criteria and risk mitigation controls can be imple- manage the hazard (preventative and contin-
mented to reduce the risk if necessary. gency)
However, meeting any prescribed criteria is only • an outline of proposed mitigation actions (pre-
one part of showing acceptability of risk. The other ventative and contingency)
aspects that need to be demonstrated are: • costs for each mitigation strategy
• information about contingency plans that should
• Adequacy of control measures be invoked if an incident does occur
• Understanding of operations and hazards and
demonstrated plan to reduce risks The database can be set up to provide reporting func-
• Adequacy of safety management system tionality, which can include such things as:

A clear picture of the hazards identified and the control • Graphical risk profiles
measures in place to protect against them occurring will • Ranking of site risks
show whether an appropriate number of control mea- • Process operations key risks and risk manage-
sures have been put in place. Having these set out in a ment plans
database (as discussed in the next section) will allow easy • Summary reports for specific process areas or
assessment of this scenario. Each of the controls must be sitewide
shown to be managed to ensure their operability. This • Critical equipment risk ranking
may be as part of the safety management system, or • Recommended risk controls and further analysis
performance standards. For example, one of the controls The risk register is a record that may be used for audit
for a high-temperature excursion in a storage tank might purposes to demonstrate that a risk assessment has
be a high-temperature monitor and alarm. The perfor- taken place and that risk management is ongoing. To
mance measure for this might be to have only one alarm be of maximum benefit, the risk register must be main-
over a prescribed period of time. tained and updated. It is then an important tool used to
The criticality of controls and their required perfor- demonstrate rigorously the systematic way that hazards
mance are then used as an input into determining the are managed at a facility.
maintenance intervals, such as trip testing.
Another aspect of showing risk acceptability is to FOLLOW-UP AND AUDITING
show that the existing controls are adequate and that The risk assessment process should be ongoing
the alternatives have been considered. If the alterna- throughout the life of the facility. To achieve this, there
tives can be shown to have been examined and con- must be follow-up and feedback to improve the pro-
sidered and the reasons for not choosing them are cess.
documented; this will assist others in understanding An important element of the follow-up process is
why the existing system is adequate. periodic auditing of hazards and their controls. Audit-
An understanding of operations and hazards will be ing is a sampling technique aimed at gaining an overall
shown once the steps of the risk assessment have been impression of the acceptability of the risk assessment
undertaken. A follow-up plan as to how the outcomes process. It is a significant component in demonstrating
are being managed will help to show that the risks are the ongoing acceptability of the risk. Audits provide
being reduced to acceptable levels. assurance that the assessed hazards continue to be
The safety management system is the primary means managed to a high level of competence. Feedback from
of ensuring the safe operation of a facility with respect audits allows improvements to the process. It is avail-
to major hazards. No one standard system can be used able to confirm that the controls identified are opera-
for all facilities; rather, individual facilities must imple- tional and maintainable to achieve the required risk
ment a workable system appropriate to their particular reduction [19].

242 December 2004 Process Safety Progress (Vol.23, No.4)


CONCLUSION management programs under Clean Air Act Section
There are a number of important issues to address 112(r)(7), 40 CFR Part 68, US EPA, Washington, DC,
when undertaking a site risk assessment to address 1999.
major incidents. 7. The Health and Safety Executive (HSE), Reducing
Hazard identification is one of the most important risks, protecting people—HSE’s decision-making
elements of the assessment. This needs to be thorough, process, HSE Books, London, UK, 2001.
involve experienced personnel, and be well recorded for 8. The Health and Safety Executive (HSE), Major in-
future reference. Using more than one technique for iden- cident investigation report—BP Grangemouth
tifying hazards will increase the effectiveness of the pro- Scotland 29th May–10th June 2000, HSE, London,
cess. UK, August 2003.
The assessment of the hazards identified is the key to 9. United Nations Environment Programme (UNEP),
demonstrating that the risk is as low as reasonably prac- Production and Consumption Branch, APELL,
ticable (ALARP). For maximum effectiveness, multiple 2001, UNEP, Geneva, Switzerland; http://www.
techniques also need to be used. Some techniques pro- unepie.org/pc/apell/disasters/toulouse/
vide a better analysis of preventative controls, whereas home.html (Accessed November 2002).
others provide a better analysis of mitigative controls. 10. Autofina Corporate Press Release, Grande Paroisse
Regardless of the techniques used, thorough documenta- Toulouse: Reaction following the publication of the
tion is essential, including employee involvement. experts’ interim report, Autofina, June 2002; http://
Throughout the entire risk assessment process, one www.atofina.com/groupe/gb/actucomm/d_detail.
factor that is consistently important at all stages of the risk cfm?IdComm⫽7322 (Accessed November 2002).
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11. Ammonium nitrate explosion at AZF Toulouse,
vital that the full details of the basis for various design and
http://www.sci.fi/⬃ility/PREn (Accessed Novem-
risk control decisions are recorded. The main reason for
ber 2002).
this is to provide traceability. This will save time when the
12. U.S. Environmental Protection Agency (US EPA)
risk assessment is updated (usually required periodically
Terra Chemical Accident Investigation Team,
by regulators) because the assessment will be under-
Chemical accident investigation report—Terra In-
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Process Safety Progress (Vol.23, No.4) December 2004 243

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