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SSE Assignment/Activity 2/Case Study As

Improving Safety of Methanol Storage and Transportation of Methanol by Road

Submitted by:
Mirza Hussain: Roll.no: Sp-2022- MSEM/012
Tassawar Hussain: Roll.no: Sp-2021- MSEM/021
Muhammad Nasir: Roll.no: Sp-2022- MSEM/006

Submitted to:
Dr. Muhammad Umer
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TABLE OF CONTENTS

TITLE PAGE NO.

i. Abstract/Executive summary…………………………………………………….4

ii. Introduction………………………………………………………………………...5

iii. Research Objective……………………………………………………………….8

iv. Research Question ……………………………………………………………….8

v. Research Methodology……………………………………………………………8

vi. Key Facility Review Observations……………………………………………….10

vii. Procedures and Document Review …………………………………………….15

viii. On-Site Observations – Loading/Unloading Facilities at X and Y Unit………….17

ix. On-Site Observations Loading/Unloading Facility at K Terminal……………22

x. Methanol Transport Tanker Issues …………………………………………….24

xi. Recommendation …………………………………………………………………26

xii. References …………………………………………………………………………29

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Definitions

“DPL” is a company having two units “X” & “Y”.

“X” is a DPL factory unit having facility of methanol storage and loading unloading.

“Y” is a DPL factory unit having facility of methanol storage and loading unloading.

“K” is a Bulk Storage Terminal.

“ABC” is a Tanker Transporter which transport the methanol from bulk storage to

factories.
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Research Title:

Improving Safety of Methanol Storage and Transportation of methanol by road

Abstract/ Executive summary:

Methanol also known as methyl or wood alcohol is extremely flammable colorless liquid.
The transport of methanol by road and its storage carries a high risk of accident and every
effort should be made to ensure that such transport and storage is carried out under the
best possible safety conditions.
The research objective was to analyze and identify the main risks associated with the
storage and transport of methanol by road as well as to identify and assess the main
factors of safe storage and transport in order to reduce the risk of accident. For this
purpose, analysis of the literature, past accidents, systematization, generalization,
interviews from staff at storage area and tanker drivers and evaluation by experts was
applied.
The article states that in order to ensure the safe storage and transport of methanol by
road, it is necessary to comply with the rules for storage of flammable liquid, loading and
unloading of flammable liquid, the established requirements and instructions, and
technical conditions of storage tanks, tankers and their labelling as well as preventive
measures to reduce the risk.
Recommendations are provided on how to reduce accidents and incidents in the storage
and transport of methanol by road.

Keywords: Flammable Liquid; Storage; Dangerous goods; transportation; risk; safety; by

road transport; accidents, OGRA, MSDS, NFPA, HAZOP, ERP, ISO, IEE
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1. Introduction
Methanol also known as methyl or wood alcohol is a colorless alcohol (organic liquid) at
normal temperature and pressure (72 0 F and 1 atm), hygroscopic and completely miscible
with water, but much lighter (specific gravity 0.8). It is a good solvent, but very toxic and
extremely flammable. This simple single-carbon alcohol is a volatile solvent and a light
fuel. Below are some typical properties.
Typical Properties
Molecular Weight: 32.04 g/mol
Purity: 99.85 %wt min
Water (impurity) 0.100 %wt max
Specific Gravity (20/20°C) 0.7910 - 0.7930
Freezing Point: -97.8°C / -144°F
Boiling Point: 64.6°C / 148°F
Flash Point (closed cup, 1 atm): 12°C / 54°F
Explosive limits in air 6% - 36%
Solubility: Methanol in Water/ Water in 100% / 100%
Methanol

The particular hazards of methanol that matter most to your facility depend in large part
on how methanol is received and stored, how it is used, where it is used, and how much
is stored and used at any given time. Failure to control hazards associated with a small
amount of methanol can be problematic with virtually no consequence; loss of control of
a large quantity can be catastrophic.
Five overriding considerations are important when handling methanol:
1. Methanol is a flammable, easily ignited liquid that burns and sometimes explodes in
air.
2. The molecular weight of methanol vapor is marginally greater (denser) than that of air
(32 versus 28 grams per mole). As a result, and depending on the circumstances of a
release or spill, methanol liquid will pool and vapor may migrate near the ground and
collect in confined spaces and low-lying areas. It is expected that methanol vapor, being
near neutral buoyancy, will dissipate readily from ventilated locations. Do not expect it to
dissipate from non-ventilated locations such as sewers and enclosed spaces. If ignited,
methanol vapor can flash back to its source.
3. In certain specific circumstances, methanol vapor may explode rather than burn on
ignition. Methanol containers are subject to Boiling Liquid Expanding Vapor Explosion
(BLEVE) when heated externally.
4. Methanol is a toxin; ingestion of a small amount (between one and two ounces,
approximately 30 to 60 milliliters) may cause death; lesser amounts are known to cause
irreversible blindness. Do not swallow methanol liquid, do not breathe methanol vapor,
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do not walk in pooled liquid, and do not allow vapor or liquid to contact skin. Methanol
absorbs through the skin and other tissues directly into the blood stream.
5. Methanol is totally miscible in water and retains its flammability even at very high
concentrations of water. A 75v% water and 25v% methanol solution is considered to be
a flammable liquid. This has important consequences for firefighting. Methanol is a
chemical solvent, which has important implications for materials selection and also for
firefighting.
Thousands of tons of methanol (Flammable Liquid) travel by all modes of transport every
day and store in storage area.
The transport of flammable liquid must comply with the relevant rules for the transport of
such goods so that the goods can reach their destination safely. There is a risk of an
event such as a spills, fire, explosion, chemical burns, or damage to the environment
when transporting hazardous materials.
Most goods are not considered as sufficiently dangerous to require special precautions
during carriage. Some goods, however, have properties that mean that they are
potentially dangerous if carried.
Due to the dangerous nature of goods, dangerous accidents in land transport often have
dire consequences for the population and environment.
By road transport is very dangerous is compared to other modes of transport because
due to infrastructure most of the roads are passing inside city or near city. Therefore,
special safety requirements are required for the transport of flammable liquids by road. It
is necessary to regulate, control, and inspect the transport of dangerous goods by rail
because of their characteristics and the real dangers.
The transport of dangerous goods by road presents a considerable risk of accident.
Measures should therefore be taken to ensure that such transport is carried out under the
best possible conditions of safety.
During the transport of dangerous goods, there may be a risk of an accident due to the
absence of incorrectly chosen packaging materials or markings, and the fault of other
road users or climatic conditions.
In the transportation of dangerous goods, it is impossible to avoid risk; however, it is
possible to manage and reduce the risk increasing factors to a minimum. Having analyzed
accidents in the transportation of dangerous goods, it can be seen that accidents or
incidents in the transportation of dangerous goods cause more problems than in the
transportation of usual goods.

1.1 Applications and Uses of Methanol:

•Chemical Feedstock - Formaldehyde, Acetic Acid, MTBE, DME, Biodiesel, Olefins.
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•Fuel & Fuel Additive - Vehicles, Ships, Cooking, Heating

•Hydrogen Carrier for Methanol Fuel Cells
•Windshield Washer Fluid
•Wastewater Denitrification

1.2 Major HAZMAT accidents:

The handling of transportation of dangerous goods is very important due to its potential
damage to health, property, life and environments. The major accidents in the history of
human kinds has suggested that there should be a mechanism to transport such goods
in a safe manner. There are some major accidents reported in the history that are listed
below and this is the reason that the mechanism has been evolved now to a significant
level that such accidents has been reduced.
• 1978 Los Alfaquins Incident (Spain) is the incident reported in Spain due to damage of
vehicle carrying liquefied propylene and killed 270 people.
• 1998 Yaoundé Cameron rail that carrying petroleum products. A fire caused 220 people
killed and hundreds injured due to this accident.
• Torrey Canon, Amoco Cadiz, Exon Valdez, Erika incidents of oil spillages that cause
environment to damage significantly.
• 2017 Bahawalpur, Pakistan incident killed 219 people and injured 34 in which a truck
carrying 40,000 liters was exploded after overturned due to tire burst.

The problems of the transportation of dangerous goods are important not only to
enterprises engaged in the transportation of dangerous goods, but also to all of the
institutions responsible for the control of dangerous goods. In the transportation of
dangerous goods, risk and possible danger to the safety of the public and the environment
are inevitable.
Storage of methanol is mainly done an underground tanks encased in concrete. Normally
storage done at room temperature, tanks sides and top covered with sand and a metal
roof was made to prevent from direct sun light exposure.
Tanks must be grounded to avoid hazards associated with static discharge. Ignition
control may be by nitrogen padding, natural gas padding, or by designation of a hazard
zone with ignition control. Because methanol is commonly stored with other solvents and
feed stocks, all piping and valves subject to carrying methanol should be consistently
labeled, and direction of flow should be indicated.
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This research includes evaluation of the documents and records, interviews of personnel,
as well as an on-site review of facilities.
2. Objective of this research study:
The main aim of this study is as follows:
1. To analyze and investigate the different safety risks with storage of methanol in port
and industries and safety best or standard practices follow up.
2. To investigate safety risks with loading unloading of methanol and safety best practices
follow-up.
3. To investigate safety risks with transportation of methanol by road, safety best practices
follow up and compliance of methanol tankers with “Oil and Gas Regulatory Authority”
(OGRA) “S.R.O.900 (I)/2009” and with other international standards/guidelines. e.g.,
NFPA, IEE, NEMA, API, BS EN/IEC, Emergency Response Guidebook ERG2008.

3. Research Question:
What is the present situation of methanol storage and transportation in Pakistan?
Up to what extent they follow the safety standards/guidelines for storage and
Transportation?
What improvement needed in safe storage and transportation of methanol from
prevention of major accident?

4. Research Methodology:
The research methodology was based on the risk-based approach to verify Methanol
storage, loading and unloading activities were carried out following the industry best
practices, international standards/guidelines, and the Methanol tankers compliance with
the “Oil and Gas Regulatory Authority” (OGRA) “S.R.O.900(I)/2009”.
The research included an evaluation of the documents and records, interviews of
personnel, as well as an on-site review of facilities. This research include the site visit of
two factories (X & Y) site i.e. factories storage, loading and unloading facility, E bulk
storage loading and unloading facility and ABC tanker transporter.
The objective of the research was to provide M/S (DPL) management with an
independent assessment on the implementation of the OGRA transport requirement and
industry best practices.
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The highlighted areas for improvement can guide the company to effectively meet the
OGRA transport requirements, corporate expectations and enhance its Environment,
Health, and Safety Management System (HSE MS).
The DPL facilities stored and processed bulk quantities of flammable, explosive, and toxic
materials. The third-party K facility stored various imported flammable and corrosive
chemicals in bulk. The chemicals were pumped directly from the ships into the bulk
storage tanks from where these chemicals were pumped out in the tankers at the loading
bays.
The DPL management was keen on enhancing its safety standards by utilizing its
available resources and skills. A few initiatives highlighted were the metal roofs provided
over the underground (U/G) storage tanks at DPL to prevent direct sun exposure, recently
procured portable gas detectors, windsocks, and diesel pumps for the firewater systems.
Portable and trolley-mounted fire extinguishers were placed near the Methanol Storage
tanks.
The facilities had an adequate water storage capacity in the overhead and underground
tanks that could be used in the fire fighting. DPL provided basic level emergency response
and other safety training to its employee. Its management took immediate corrective
measures on some observations as they were brought to their notice.
Methanol fires are more likely to occur than gasoline fires when the liquid temperature
reaches the flashpoint temperature of (10-120C). DPL should consider the physical and
chemical properties of Methanol and associated hazards and risks in the risk assessment
e.g., Hazard Operability (HAZOP), and the Building Risk Assessment (BRA).
DPL has two facilities having methanol storage tanks yards. Each facility should have
developed its own Emergency Response Plan (ERP) as situations, hazards and
resources may vary. Also, develop emergency response scenarios based on the
identified hazards in the risk assessments and conduct periodical desktop exercises,
unannounced emergency response drills, as well as an annual major drill on the worst-
case scenario e.g., a Methanol storage tank and tanker fire during decanting, major fire
involving Methanol, and Formaldehyde.
Also, consider installing fixed gas detection system. Furthermore, evaluate the fixed fire
protection systems through a “Fire Plan Assessor”, and ensure availability of water for the
firefighting storage all the time.
DPL should train its technical staff in “Process Safety”, and standards and methodologies
e.g., NFPA, ISO, IEE, and Root Cause Analysis. This can significantly improve asset
integrity and safe operations.
Some procedures/Standard Operating Procedures were reviewed had deficiencies e.g.,
improperly written, missing information. Also, written procedures were not developed for
safety-critical activities such as confined space entry, isolation will, lockout/tag-out, and
hold tag and management of change.
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M/S ABC Goods Company tankers were used for the transportation of Methanol. The
visual inspection of tankers at DPL and K failed to comply with S.R.O.900(I)/2009 and
were poorly maintained and unlabeled. The defective and substandard tankers should
have been rejected at the loading sites if their inspection procedure was rigorously
implemented, hence compromising the safety and the regulatory requirements.
The unwashed tanks and unlabeled tankers may have been used for the transportation
of various chemicals which could carry residual liquid that can contaminate Methanol.
Also, at the K terminal, the Methanol pumps inlet and discharge pipes may carry the
residual chemical from the previous load as no residual return system was available that
could credibly empty the lines prior to filling Methanol DPL.
The transport contractor could not provide the tanker’s design information on a checklist
specifically developed from the “Oil and Gas Regulatory Authority” (OGRA) “S.R.O.900(I)/
2009” to identify the gaps.
DPL should persuade the transport contractor to supply well-maintained tankers that
comply with “S.R.O.900(I)/2009” and effectively communicate safety standards and
deficiencies to the contractors and monitor their safety performance.
The material transport “Service Level Agreement” was a general financial agreement that
did not mention the specific regulatory requirements nor the safety expectations from the
contractor e.g., tanker roadworthiness, internal tank washing, and OGRA SRO
requirements.
Third-party K terminal was an old facility. Its storage tanks were not maintained while the
housekeeping was unacceptable. This old facility was unsafe from a business continuity
perspective. DPL should persuade the K terminal management to shift Methanol storage
and filling activities to its new facility.
Additional recommendations have been developed if implemented can improve the asset
integrity and safe operations. Management should develop an action plan to sustainably
implement the recommendations and monitor the progress.
4.1 Key Facility Review Observations:
To identify the areas for improvement as per industry best practices storage, loading and
unloading facilities in K, X, and Y were inspected, the documents received were reviewed
and relevant people were interviewed. Also, the Methanol tankers available were checked
against OGRA “S.R.O.900(I)/2009” and their roadworthiness.
The significance of observations at one facility should not be simply limited and attributed
as only isolated circumstances; similar occurrences may exist at other locations.
Following key findings were observed which have been categorized as per standard HSE
MS expectations and needed to be thoroughly investigated at the
program/process/procedure level to resolve them systematically and sustainably.
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Potential
Sr
SMS Elements Key Observations Qualitativ
No
e Risk
Process safety culture was not developed at all
Additional
the three sites.
Leadership and Safety action plans/procedures for hazardous
1 chemicals e.g., Methanol were not developed
Accountability
based on their flammability, toxicity, and Major
environmental effects by assessing the
associated risks.
Building risk assessment was not done to assess
Major
and mitigate the risks e.g., access and egress.
HAZOP was not done to identify the Methanol
handling and process-related risks from the
Major
associated hazards to take the remedial
Risk measures
Assessment
2 Risk assessment did not address risks associated
and
with hazardous chemicals such as Methanol e.g.,
Management
major fire, tanker rollover on the way, hazards Major
from adjacent facilities hence appropriate
emergency response plan could not be developed
The procedure was not developed to conduct Job
Major
Safety Analysis (JSA) for high-risk activities
The tanker drivers were unaware of
communication actions required in case of an
Additional
accident on the way nor they were provided
emergency services contact details.
Some employees e.g., security guards were
unaware of their safety responsibilities during
Communication High
3 Methanol unloading and actions required in an
s
emergency.
Safety requirements and specific national laws
and regulations were not communicated to the
Methanol transport and storage contractors e.g., Additional
through the Service Level Agreements and other
modes of communication/meetings.
Workers involved in hazardous chemical handling
e.g., Methanol were unaware of the associated
Major
hazards as they did not receive proper training on
Competencies hazardous substances.
4
and Training People involved in the hazardous chemical
handling were unaware of information and
Major
measures stated in the MSDS/CHB provided by
their manufacturer.
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Relevant management was not trained on

Additional
“Process Safety” management.
Process Safety Systems and procedures were
Additional
not developed.
Most of the flanges of process and high-pressure
firewater lines had missing nuts and bolts
indicating behavioral issues/negligence in the
maintenance system; hence compromising the Additional
process design requirements.
Piper Alpha disaster:
https://www.youtube.com/watch?v=XAGl9codd9Y
No procedure existed to carry out “Management
of Change” for all changes that occurred in the
facilities (temporary or permanent) e.g., new
Major
firewater pump, construction of a new residential
building near process buildings, and Methanol
storage tank.
No evidence was provided to verify if periodic
equipment inspection procedure was developed
Additional
and effectively implemented e.g., bulk storage
tanks wall thickness and corrosion test.
Electric installations were not designed and
5 Asset Integrity installed considering the international standards.
Substandard and poorly maintained electric
installations scattered mainly at Y and Kemari
Major
facilities were a serious threat to the asset
integrity and business continuity perspective.
Some substandard electrification was also
observed at X.
High-risk equipment was unprotected e.g.,
Methanol pumps (if explosion-proof) were not
Additional
protected by a sprinkler system with the auto-
activation sensor.
Methanol tankers were not effectively inspected
prior to loading, to verify if they were fit to safely Major
transport Methanol.
The periodical inspection frequency stated in the
procedures was not according to the industry best Additional
practices.
A procedure was not developed to detect the
presence of hazardous gases prior to carrying out
high-risk activities. Also, the Y and X facilities did Major
not install fixed gas detection and alarm systems
to immediately alert on a gas leak.
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A checklist was developed from (OGRA)

“S.R.O.900(I)/2009” and was provided to the
Methanol transport contractor to provide the
technical design details of its tankers. LPS could
not get the information. However, visual Major
inspection of the tankers revealed that not only
the tankers used for the Methanol do not comply
with most of the OGRA requirements but were
poorly maintained.
The procedure for Isolation, lockout/Tag out was
not developed to safely carry out work on
equipment. Also, several valves handle on the
Major
Methanol process and firewater systems were
removed instead following the lockout Tag out
protocol.
Safety culture was not effectively implemented to
ensure all personnel wears Personal Protective
Additional
Equipment (PPE) as recommended in the
procedures and MSDS.
6 Safe Operations The procedure was not developed to monitor the
presence of hazardous gases to carry out our hot Major
work.
The procedure was not developed/ implemented
for the confined space entry e.g., the entry in the
pit of Methanol U/G tanks, where the high
Major
concentration of Methanol and other hazardous
gases could be present in high concentration
(oxygen-deficient and toxic gas)
Tanker decanting activity was not carried out
Additional
under the work permit system.
The procedure was not developed to carry out
contractor monitoring to assess their safety Additional
performance.
Service Level Agreements did not specify safety
measures, national laws and regulations
requirement Periodical inspection of contractor Additional
Contractors, sites and equipment to ensure business
7 Suppliers, and continuity.
Others K Terminal: The facility lacks preventive
maintenance and housekeeping of the overall
facility. Probably the repairs were carried out on a
firefighting basis to keep the equipment working. Major
This old facility was unsafe from a business
continuity perspective. Refer issues highlighted in
Section VI
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Emergency response resources such as firewater

systems were not effectively maintained and
periodically tested.
In Y, the windsock could not be seen when Major
checked from most of the places, while at X one
windsock was installed after the LPS visit and at
K terminal, one installed over the tank was torn.
Unsure if the existing fixed fire water system was
designed by a competent person.
Unsure if the fire water line was designed and
installed to form a ring (no tail ends connecting
Additional
multiple points).
The fixed firewater systems were equipped with
hose reels and sprinkler systems at X and Y,
however, fixed fire monitors were not installed.
The fixed firewater system as well as the foam
fire suppression systems operated manually.
Consider changing to an automatic activation
system as it will immediately act to suppress the Additional
fire at the initial stage instead of human
interaction to detect the fire and respond may be
too late to suppress.
Emergency Methanol related emergency response scenarios
8
Preparedness were not developed based on the risk Additional
assessments
The Emergency Response Plan (ERP) had
several deficiencies e.g.,
- The step-by-step sequential actions in
responsibilities of each role were missing.
- Roles and responsibilities for the crisis
management team, media response person
was not addressed
- The communication plan including
communication with the adjacent facilities in an
emergency was not developed.
- Emergency contact lists e.g., hospitals, burn Major
centers, and other emergency services were not
attached.
- Scenarios on major fires and identified
assembly points based on the worst-case
scenarios were not mentioned.
- Capabilities and available resources with the
local fire brigade were not assessed that should
have been mentioned in the ERP.
Refer: Emergency Response Guidebook
ERG2008
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Safe means of exits in a major fire/emergency

was not evaluated as X and Y facilities had two
main gates. People may get stuck at the back of Major
the facilities and in the tank farm area (K
Terminal)
DPL claimed of no incident occurred related to
Incident
Methanol loading, unloading, and transportation
9 Reporting and
activities. However, unsafe conditions were
analysis
addressed, and corrective measures were taken.
Insufficient evidence was provided if DPL
coordinated with the adjacent communities to be
Community
10 aware of each other’s hazards and associated Additional
Awareness
risks and had a commitment to coordinated
efforts in an emergency.
The procedure was not developed to carry out
SMS Self-assessment to periodically assess the
hazardous chemicals management e.g., to
ensure Methanol handling and storage was Additional
carried out in a safe manner and adequate
emergency services were available to meet the
worst-case scenario.
Continuous No formal system existed to identify industry best
11
Improvement practices and give recommendations to the senior
management to run the business more efficiently, Additional
safely, and economically by utilizing the latest
technologies and techniques.
No formal system existed to identify the lessons
learned from the major petrochemical incidents
Additional
worldwide which can make the operations safe
and efficient.

4.2 Procedures and Document Review

Sr Areas for Improvement

No
1. - “Service Level Agreement” with K Bulk Storage facility had deficiencies:
- Safety inspection requirement was not addressed.
- Sharing of third-party Methanol storage tanks inspection reports was not
addressed.
- Preventive measures to prevent Methanol contamination during ship
unloading and tanker loading were not addressed.
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Sr Areas for Improvement

No
2. “Service Level Agreement” with the Methanol transport company had
deficiencies e.g., the following requirements were not addressed.
- Periodical tanker inspection
- Tanker inspection prior to sending for loading; to ensure roadworthiness.
- The tanker driver periodical medical fitness test.
- Driver training e.g., defensive driving, spill response, and first aid.
- Tank washing prior to bringing for loading.
- OGRA requirement for tanker compliance.
3. The emergency Response Plan (ERP) had several deficiencies e.g.,
- One ERP was developed for all sites instead of a separate ERP for each site.
- Mostly generalized statements were mentioned instead of a sequence of
actions that could clearly explain the responsibilities for each role.
- Scenarios were not developed on major fires involving the filled tanks,
loading activities.
- Media response person was not identified.
- Response to adjacent facilities was not mentioned.
- Communication plan was not effectively developed.
- Emergency and crisis management teams were not effectively mentioned.
- List of emergency contact lists were not attached with ERP.
- Hospital detail for X was not mentioned.
- Burn centers for Y and X were missing.
- Emergency response in a major fire was missing.
- Assembly points were not located based on the worst-case scenarios.
- Responsibilities of the first responder were not clearly addressed.
- Capabilities and available resources with the local fire brigade was not
assessed that should have been mentioned in the emergency management
plan.

Refer: Emergency Response Guidebook ERG2008

4. X and Y facilities were too congested, probably the extensions were built without
the expertise of industrial designers and formal risk assessments such as
building risk assessment, HAZOP study e.g., existing and under construction
accommodation in X were very close to the process area and the Methanol
storage tanks that may not provide a safe means of access in a major fire.
5. The periodical inspection frequency of various equipment looked unrealistic e.g.,
first aid boxes should be replenished when used or once a month, diesel fire
pump should be tested as per NFPA 25 guidelines i.e., weekly, monthly,
quarterly, and annually.
Each frequency of inspection has different requirements that may also be
described in the pump manual from the manufacturer
Refer: SOP 4.4.3.2 and FM-HSE-12 “Emergency Response Equipment and
Maintenance Requirement”.
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Sr Areas for Improvement

No
6. A procedure was not developed to detect the presence of hazardous gases
prior to carrying out high-risk activities e.g., work on live electrical panels,
confined space entry, and hot work.
Note: DPL has recently procured a portable gas detector (Gas Alert Max XT II)
for each site.

4.3 On-Site Observations - Unloading Facilities X and Y.

Sr Areas for Improvement Location

No

1. Ferrous metal tools were used for the nuts and bolts fastening/ X
unfastening of the hose-tanker flange that can cause a spark.
2. A flange connection was used for the hose connection with the X
tanker decanting valve instead of a coupling.
3. A security guard was unaware of his safety responsibilities during X
Methanol unloading. He was deputed inside the cordoned area
without appropriate PPE.
4. Not all People involved in the decanting process were wearing X
appropriate PPE e.g., chemical coverall/flame retardant antistatic
protective clothing, rubber gloves, or as specified in the MSDS.
5. Unprotected personal e.g., security guards not wearing PPE should X
have been kept away from the decanting area.
6. Tanker decanting activity was not carried out under the work permit X
system. Safe arrangements should be verified by the permit issuer
and receiver through a joint site inspection.
Maintenance and Design Issues
7. Methanol pumps were installed adjacent to the underground tanks X
which were too close.
8. Several flanges of firewater (operates at 4-7 bar) and process lines X&Y
had missing nuts and bolts hence compromising the process design
requirements.
9. Unsure if the activities in the pits of underground Methanol storage X&Y
tanks were controlled through the work permit system. However,
people entered in the pits without the gas test was extremely
dangerous.
10. A patch on Methanol underground tank was welded/repaired. X
Unsure if the activity was conducted after developing a Job Safety
Analysis (JSA) Unsure if a procedure was developed and
implemented for the internal tank cleaning e.g., steam cleaning and
purging the tank with Nitrogen.
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Sr Areas for Improvement Location

No
11. Although the formaldehyde plant was just 40 feet from the Methanol X
bulk storage tanks, the risks to the Methanol storage facility from the
adjacent plant were not assessed.
12. Consider providing safe access to work over the underground X&Y
Methanol storage tanks as people climb the wall around the tanks or
jump over the deep pit.
13. Electrical wiring, loose cables, non-standard junction boxes, control X
panels, and low-quality flammable PVC conduits within the proximity
of Methanol storage tanks and decanting areas were not explosion-
proof (looked like normal residential wiring) e.g., switchboard
(outside the dike wall of over ground Methanol tank), wiring of
Methanol pumps (source of ignition), (Refer NFPA 30 and 70)
14. Lightning Arrestor installed over the Methanol overhead tank was X
installed directly over the tank and connected to the grounding
system. The arrestor should not be connected directly to the tank
body and fire water line.
Refer to Annex B-3 for an explanation and NFPA 70 “National
Electrical Code”.
15. Methanol overhead pipe connecting pumps discharge of both U/G X
tanks was sagging and was tied with pieces of cloth. This may result
in the leak of the pipe flange.
16. U/G tanks vapor exhaust/vents were too low which can result in X&Y
vapor accumulation at low line areas e.g., tank pits.
17. Flange/openings over the roofs of the U/G tanks (e.g., U/G tank # 1) X
were left open, which can result in Methanol vapors accumulation in
the tank pit e.g., the open flange of the removed Level switch
18. Methanol U/G tanks were covered with sand, a small section of the X&Y
side was opened to access the manway and pipe connections. The
oily water was accumulated on the base of the pits which can
corrode the tank base. The sumps were not provided to collect and
remove the water.
19. Methanol carrying pipes were not color-coded nor the flow direction X&Y
was marked.
20. Corrosion marks on the external surface of the O/H tanks. Consider X&Y
painting and wall thickness test.
21. Holes in the dike walls were not plugged hence compromising the X&Y
storage capacity of the spill containment area.
22. Spill containment area of tanks should be kept clean all the time as X&Y
unwanted items were left inside the containment area of the O/H
Methanol tank
23. Substandard electric fittings and wiring, temporary electrification, Y
hanging, and jumbled cables were observed all around the facility
that can become an ignition source e.g., switch outside Methanol
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Sr Areas for Improvement Location

No
U/G tank. Hence, the purpose of explosion-proof electric system
was compromised.
24. Oily sludge was present in the pit of U/G Methanol tank. The root Y
cause was not investigated
25. The roof of the U/G Methanol Tank had several corrosion/pitting Y
marks under the peeled paint.
26. The roof of the U/G and O/H Methanol tank roofs had no walkways X&Y
hence people had to walk directly over the roof. Walking directly
over the old tank roofs is risky as they may collapse due to
undetected thin wall due to internal corrosion.
27. Electric cables for Methanol pumps were unprotected and lying on Y
the ground. They should be secured.

Emergency Response
28. Emergency eyewash was not provided at the Methanol storage area X&Y
while a substandard shower was installed at the Y facility.
29. Several valve stems of the firewater system were painted that may X
have been jammed or difficult to operate.
30. To assess the wind direction in an emergency, windsocks were X&Y
either not installed or were not visible at the different locations in the
facilities. X HSE representative confirmed the installation of one
windsock. Unsure if it was visible all around the facility.
31. Fixed gas detectors were not installed to immediately alarm the X&Y
presence of flammable gases (with audible and visual alarms)
32. No battery charger was provided with the new diesel generator to X
keep the battery charged when the engine was OFF.
33. The exhaust pipe of the new diesel fire water pump was inside the X
room which will significantly increase the room temperature.
NFPA 20 11.5.3.1: Exhaust from the engine shall be piped to a safe
point outside the pump room
NFPA 20 11.5.3.3: Exhaust systems shall terminate outside the
structure at a point where hot gases, sparks, or products of
combustion will discharge to a safe location
NFPA 20 11.5.3.4: Exhaust system terminations shall not be
directed
toward combustible material or structures, or into atmospheres
containing flammable gases, flammable vapors, or combustible
dust.
34. The fuel tank of the new diesel fire water pump may provide fuel for X
a short period. To check the fuel requirement, note the running
hours (on full load) with the filled tank.
 P a g e | 20

Sr Areas for Improvement Location

No
NFPA 20 9.6.2.3: The fuel supply capacity shall be sufficient to
provide 8 hours of fire pump operation at 100% of the rated pump
capacity.
NFPA 20 11.6.4.1: The fuel storage tanks shall be designed and
installed so that they can be kept as full and always maintained as
practical but never below 66 percent (two-thirds) of tank capacity.
NFPA 20 A.11.4.3: Diesel fuel storage tanks preferably should be
located inside the pump room or pump house if permitted by local
regulations. Supply and vent lines in such cases should be
extended outdoors.
35. The type of fuel and the tank capacity was not displayed on the fuel X&Y
tank of the diesel firewater pump.
NFPA 20 11.4.5.4: The grade of fuel oil shall be indicated on the
fuel
tank by letters that are a minimum of 6 inch. (152 mm) in height
and in contrasting color to the tank.
36. The battery for the new diesel fire water pump was placed on the X
ground almost touching the base frames of both the pumps, hence
will be subject to excessive vibration. Also, battery periodical
inspection may be difficult. Consider relocating the battery and
placing it over a portable rack.
NFPA 20: 11.2.7.2.4.1 Storage batteries shall be rack supported
above
the floor, secured against displacement and located where they will
not be subject to excessive temperature, vibration, mechanical
injury, or flooding with water.
NFPA 20: 11.2.7.2.4.3 Storage batteries shall be readily accessible
for servicing.
NFPA 20: 11.2.7.2.4.4 Storage batteries shall not be located in front
of the engine-mounted instruments and controls
37. Insufficient evidence was provided if the fixed fire protection system X&Y
was periodically inspected and tested as recommended in NFPA 25
“Requirements for Fire Pump Tests”
38. Unsure if the foam blanketing system for the Methanol tanks comply X&Y
NFPA guidelines.
Refer NFPA 11 “Standard for Low, Medium, and High Expansion
Foam”
NFPA 13 “Standard for the Installation of Sprinkler Systems”
39. The fixed firewater system as well as the foam fire suppression X&Y
systems were designed to operate manually.
NFPA 15 “Water Spray Fixed Systems for Fire Protection”
40. Insufficient evidence was provided to verify if the sequence of auto X&Y
starts and stop of fire water pumps was as stated below and
pressure sensitive.
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Sr Areas for Improvement Location

No
Start Stop
st
1 Jokey pump st
1 Diesel driven pump
2nd Electric driven pump 2nd Electric driven pump
3rd Diesel driven pump 3rd Jokey pump
41. No evidence was provided to verify if the electric firewater pump X&Y
and fire alarm system received electric supply through an
uninterrupted dedicated supply line that continues power supply
even if the main power supply is switched off in an emergency.
NFPA 20 9.6.1.2: The normal source power supply is required to be
a service connection dedicated to the fire pump installation when
the source supplies load other than those associated with the fire
pump.
42. The selection, placement, and inspection criteria for the portable fire X&Y
extinguishers were not according to the associated hazards and the
safe distance from that hazard.
Refer NFPA 10 “Standard for Portable Fire Extinguishers”
43. No evidence was provided that at least one person per shift was X
trained to operate the fire water system, replenish the diesel in the
diesel pump tank, etc. Also, ensure the presence of at least one
trained person all the time in the facility
44. Firewater System Header had weak base supports that may not Y
withstand during prolonged use.
45. Dry spot marks were observed on the outer walls of the Methanol Y
O/H tank that indicate blocked sprinkler system nozzles or improper
design of the sprinkler system. This should be further investigated.
46. The valve of the foam system for the old U/G tank had a minor leak Y
i.e., water was dripping over the tank roof.
47. Portable fire extinguishers were removed from their designated Y
place. Refer NFPA 10 (7.1.3) Portable Fire extinguishers
48. A CO2 fire extinguisher was placed outside the generator room. The Y
CO2 fire extinguisher is not recommended for outdoor use.
Refer NFPA 10 (C.3.4)
49. A CO2 fire extinguisher outside the generator room was painted Y
black. Black was the old color for CO2 fire extinguishers.
50. MSDS of chemicals were not displayed at prominent places e.g., X&Y
manufacturer supplied MSDS should be displayed with its translated
version in the local language
51. Employees randomly interviewed during the site visit were unaware Y
of their actions in an emergency
Others
52. Methanol samples were collected in an unsafe manner as the lab X
attendant used mugs to collect Methanol from the tank top that
exposes the person to Methanol vapors.
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Sr Areas for Improvement Location

No
53. Two vehicle speed limits inside the facility were displayed i.e., 10 X
and 15 KPH, while the Safety orientation mentioned 10 KPH
54. Sand and gravel were filled in barrels will be difficult to tilt in an Y
emergency.
55. Wet roads in the process areas were slipping hazards for the Y
pedestrians as well as vehicles. Management explained the water
was from sea salt stored on the roadside.

4.4 On-Site Observations Loading Facility K Bulk Storage (Pvt.) Ltd

Sr Areas for Improvement

No
General
1. The safety culture in the facility was nonexistent with exception of the
maintainability of portable firefighting equipment, and the fire detection system.
2. Methanol and standby pumps, bulk storage tanks and their piping had no labels
or flow direction arrows e.g., content in the bulk storage tanks.
3. Some walkways were without railing in the tank farm.
4. No safe means of access was provided in the congested pump rooms.
5. A standby diesel generator was about 50 feet from the nearest loading bay. The
room had housekeeping issues.
6. Unsure if DPL staff monitored and ensured e.g., the right product was filled in the
tankers, no residual liquid other than Methanol was present in the lines.
Loading Bays Design
7. Instead of providing a properly designed loading arm, the tanker loading facility
comprised of about 6 feet solid PVC pipe hung with the valve to flow Methanol in
the tank. The top-loading system had no vapor recovery system.
8. Al-Hamad staff could not explain if the liquid from the piping system (suction and
discharge lines) from the tank to the discharge valve at the loading bays was
removed/emptied before pumping Methanol for DPL nor they could show a liquid
return system. The staff also showed a pump claiming to be a standby pump
which was also allocated for Ethanol. However, several pumps installed in the
pump room had no label to indicate if they were assigned for a specific liquid nor
did their suction and discharge lines had labels to indicate the content in the
pipes. In such condition, human errors and behavioral issues cannot be ruled
out.
9. Unsure how the lines from the ship to the bulk storage tanks was emptied or if a
pipeline was dedicated for Methanol transfer. DPL management should
investigate.
10. The operator filling the tank was wearing a facemask with a dust filter, hence
exposed to Methanol vapors.
11. Electric wiring and fittings were not explosion-proof. Substandard, old, and
poorly maintained electric wiring at the loading bays, in the control room e.g.,
 P a g e | 23

Sr Areas for Improvement

No
open control panel doors (with 3-Phase supply), openings in the control panel
doors, nonstandard electric fittings, cable joints improperly secured.
Maintenance and Housekeeping
12. Substandard maintenance management was observed e.g., missing nuts and
bolts of most of the flanges (process as well as firewater lines), several
unsecured Nitrogen cylinders near Sulfuric Acid tanks, substandard
electrification, old, disconnected pipes were scattered all over the facility.
Pressurized Nitrogen cylinder valve if breaks due to a fall can result in
uncontrolled projectile especially when they were placed close to the bulk
storage tanks can result in tank rupture.
13. Extremely poor housekeeping in the tank farm, around Sulfuric Acid storage
tanks. It seems there was no procedure to dispose of junk and unwanted
material from the facility.
14. Diesel was spilled on the generator room floor as there was no proper
arrangement to fill the generator fuel tank.
Asset Integrity
15. “E” Bulk Storage facility was probably never inspected to ensure asset integrity
and safe operation; that was essential for DPL business continuity.
16. Several tanks had corrosion marks, especially at their base. Some tanks had
inspection marks; however, the facility management could not confirm if any
rectification measures were taken.
17. Tanks inspection reports were not reviewed by DPL to ensure the integrity and
safety of their stored product in the tanks (with the perspective of business
continuity).
18. Tanks’ top-loading arrangements were disconnected by switching over to the
bottom loading utilizing ship pumps is a good practice as it can minimize the
vapor formation. However, the old pipes were not removed from the tanks.
19. Some walkways connecting the tank top were badly corroded including their
railings (extremely dangerous to walk over such unstable walkways)
20. Some tanks had no walkways over the tank top therefore walking directly over
the tank’s roof may be unsafe (especially looking at the condition of the
walkways and tank external surfaces).
21. Although the grounding system for the tankers parked for the loading is
appreciable, however the system integrity with respect to its maintainability was
doubtful as it failed when asked to check while connected to a tanker.
Emergency Response Management
22. Emergency Response System/management system had deficiencies e.g.,
- Some fixed firefighting equipment were located that could be inaccessible
during major fire.
- First Aid box was containing water contaminated items.
- Assembly area was too close to the loading bays.
- Diesel fire pump was removed for repair.
- Site has only one gate (no other means of escape in an emergency especially
from the tank farm area.
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Sr Areas for Improvement

No
- Only means of access to Hose Reel # 2 and Fire hydrant was to cross over the
covered trench. The trench metal cover was badly corroded from several
locations and was dangerous to walk over it.
23. The staff did not receive formal training to use the portable gas detector as the
person holding the gas detector could not satisfactorily explain the procedure of
taking the gas test from an empty tank.
24. MSDS of chemicals were not displayed at prominent places e.g., manufacturer
supplied MSDS should be displayed with its translated version in the local
language
25. A backup firewater line was available from Al-Noor Terminal connected to the
firewater main header. Need to investigate how much water they can dedicate to
the Al-Hamad facility.
26. Several valve handles were removed from the process lines. Valves should be
Open/Close with car seals/locked and tagged.
27. The electric fire water pump motor did not comply with NEMA MG-1, i.e., should
be marked as complying with NEMA Design B standards, and listed for fire pump
service.
Refer NFPA 20 Table 9.5.1.1.

4.5 Methanol Transport Tanker Issues

Sr Observations Location
No
Driver Training
1. The drivers were unaware of communication actions required in an X&
emergency nor they were aware of emergency response action K
except parking the vehicle on the roadside.
2. Tanker driver did not receive any training e.g., defensive driving, first X&
aid, spill response to handle the minor spill. K
Driver Fitness
3. Tanker drivers did not undergo a periodical medical fitness and drug X&
test. Unfit drivers or drivers under influence of the drugs can be a K
serious threat to life and property while driving.
4. The tanker drivers were not provided any training/refresher. X&
K
Documents
5. “Cargo Handling Sheet or MSDS” for Methanol was not provided to X&
the tanker driver who should present it to the emergency response K
team on the way in an emergency so that the ER team becomes
aware of the Methanol presence and associated hazards.
Vehicle Inspection and deficiencies
6. The vehicle inspection checklist used at K had deficiencies as it did K
not include e.g., ensuring the tank was empty and washed, no other
 P a g e | 25

Sr Observations Location
No
liquid was present, vent valves were installed, Methanol related
labels were displayed, discharge valve caps were placed, and no
impact mark/dent or corrosion mark on the tank (especially the tank
bottom).
Refer Tank Reg K-7090 Inspection Checklist
7. The visual condition of the Methanol tankers gave the impression X&
that the periodical inspection of the tanks for wall thickness was not K
done e.g., welded repair patches on the tank of tanker Reg. No. E-
3097 and corrosion marks on the tank of tanker Reg. No. K-7090.
8. The Inspection details of Tanker Reg K-7090 checked which did not X
record the serious defects in the tanker.
Refer to the Tank Reg K-7090 Inspection Checklist and observation#
10
9. The visual inspection of Tanker Reg E-3097 checked which had K
defects e.g.,
- Damaged/worn-out tires and tires of various tread patterns were
used. (OGRA Ord.)
- The discharge valves had no lid.
- Tanker was not provided with a hosepipe for emergency use on the
way. (OGRA Ord.)
- Chassis was repaired (welded).
- Non-standard discharge valves were installed.
- Tank top fall protection railing was not raised (unsure if it was
jammed)
10. The visual inspection of Tanker Reg K-7090 checked which had X
defects e.g.,
- Damaged/worn-out tires and tires of various tread patterns were
used (OGRA Ord.).
- Unsure if the tank was washed prior to loading Methanol.
- The tanker grounding point was painted.
- Fall protection railing was not provided over the tank top.
- Non-standard ball valves were installed for decanting.
- Methanol was dripping from one of the decanting valves.
- The discharge valves had no lid.
- Tanker did not have a hosepipe for emergency use. (OGRA Ord.)
- The exhaust outlet was directed outwards but not downward/
toward the road surface. (OGRA Ord.)
- Substandard exhaust spark arrestor was used (OGRA Ord.).
- Fuel tank was unprotected from external impact (OGRA Ord.).
- One nut of the left front tire was missing.
- No fog lights were provided. (OGRA Ord.)
- Decanting valves were not sealed
 P a g e | 26

Sr Observations Location
No
OGRA SRO: Bias-ply and radial ply shall not be mixed on the same
vehicle. The entire vehicle must be either fitted with bias-ply tires, or
with radial ply tires, and the spare wheel(s) shall also be of the same
type.

5. Recommendations

Recommendations have been divided into “Major” and “Additional” recommendations

based on their relative importance in providing safety to employees. Recommendations
have been categorized as major if they address any of the following:
 A major improvement is required in the HSE MS.
 A potentially life-threatening behavior or condition.
 A situation that poses serious health hazards to personnel or the community.
 A situation that presents a threat of high monetary loss to the company.
 A situation that poses a serious risk to facility operations or assets.
 A situation that poses a serious risk to the environment.

Open communication with employees is crucial to the successful implementation of

recommendations. Their advice and input on implementation can be very useful, and
employees’ cooperation depends on their understanding of what the Company’s safety
activities are all about, why they are important to them, and how they affect their work.

The status of recommendations should be tracked and periodically reviewed by the Safety
Management Committee (SMC)/senior management.
Major and additional recommendations are listed on below.
Recommendations Category
Develop Safety Action Plans annually based on the best industry
1. practices and track the progress of action items through SMC Additional
meetings
 P a g e | 27

Process safety management: develop a disciplined framework for

2. managing the integrity of operating systems and processes that Major
handle hazardous chemicals.
Conduct HAZOPs and BRA and implement the recommendations
3. Major
to mitigate the risks.
Expand the scope of risk assessment to address risks associated
with hazardous chemicals (Methanol) e.g., major fire, tanker
4. Major
rollover on the way, hazards from adjacent facilities, and develop
emergency response scenarios accordingly.
Address risks posed by adjacent facilities consistently and enhance
5. Additional
ERP accordingly
Enhance the safety procedures/SOPs for hazardous chemicals
6. considering their flammability, toxicity, and environmental effects Additional
by assessing the associated risks e.g., SOP ST-09
Enhance the emergency response plan by following the
“Consequence Based Approach”. Clearly write the step-by-step
required actions in the responsibilities for every role e.g., crisis
management team, media response person. Also, develop
communication plan including communication with the adjacent
7. Major
facilities in an emergency, attach emergency contact list e.g.,
hospital detail, burn centers, and develop
scenarios on major fires, and identify assembly points based on the
worst-case scenarios
Refer: Emergency Response Guidebook ERG2008
Evaluate the existing fixed fire water system design from a
8. Additional
competent person to evaluate its adequacy to meet major fires.
Persuade the transport contractor to supply well-maintained
9. Major
tankers that comply with (OGRA) “S.R.O.900(I)/2009”
Persuade the Kemari Terminal management to shift Methanol
10. storage and filling activities to its new facility or bring significant Major
improvement at its old facility.
Form a team of competent engineers to consistently review the
lessons learned from the major chemical industry incidents
11. Additional
worldwide and present the recommendation to the management for
implementation
Revise the Work Permit process to include.
- The requirement for the gas test during the joint site inspection by
the work permit issuer and receiver.
- Lockout/Tagout/hold tag protocol.
12. Major
- The requirement for the confined space entry.
- JSA was done for all the high-risk activities.
- Work at height safety protocols.
- Excavation
Develop and implement the isolation, lockout, and use of hold tags
13. Major
procedure.
14. Develop and implement the confined space entry procedure. Major
 P a g e | 28

Develop and implement a process for “Management of Change”

15. Additional
(temporary or permanent).
Maintenance activities should be controlled through the work
16. Additional
permit system.
Monitor contractor safety performance consistently to identify the
17. Additional
gaps and ensure the issues are effectively addressed
Consistently test, inspect, and maintain the emergency response
18. Additional
resources for readiness, including the mode of communication.
Identify and replace the obsolete, substandard electrical installation
with an explosion-proof system within the hazardous zone where
19. Major
flammable gases or vapors can be present. Also, place loose
cables in conduits or cable trays.
Provide technical training to electrical technicians on explosion-
20. proof electrical installation and its periodical/preventive Additional
maintenance.
Develop a mechanism to ensure workers involved in the hazardous
21. chemicals handling are made aware of hazards and precautions Major
stated in the MSDS.
Include safety requirements and relevant national laws and
22. Additional
regulations in the Service Level Agreements.
Work closely with the contractors to persuade them in the
23. implementation of safety requirements and specific national laws Additional
and regulations.
Improve the supervision for the maintenance activities to ensure
24. Major
work was accomplished by maintaining the quality, and standards.
Conduct an internal management review of the HSE MS
25. implementation annually to assess the safety performance and Additional
identify the gaps.
 P a g e | 29

6. References:
1. “Oil and Gas Regulatory Authority” (OGRA) “S.R.O.900(I)/2009”.
2. Methanol Institute “Methanol Safe Handling Manual”. www.methanol.org
3. Emergency Response Guidebook ERG2008
4. Piper Alpha disaster: https://www.youtube.com/watch?v=XAGl9codd9Y
5. NFPA 30 (Flammable and Combustible Liquids Code) and 70 (National Electrical
Code)
6. NFPA 20 (Standard for the Installation of Stationary Pumps for Fire Protection)
7. NFPA 11 “Standard for Low, Medium, and High Expansion Foam”
8. NFPA 13 “Standard for the Installation of Sprinkler Systems”
9. NFPA 25 “Requirements for Fire Pump Tests”
10. NFPA 15 “Water Spray Fixed Systems for Fire Protection”
11. NFPA 10 “Standard for Portable Fire Extinguishers”
12. BS EN/IEC 62305 Lightning protection standard
13. Conca, A.; Ridella, C.; Sapori, E. A risk assessment for road transportation of
dangerous goods: A routing solution. Transp. Res. Procedia 2016, 14, 2890–2899.(
http://dx.doi.org/10.1016/j.trpro.2016.05.407)
14. Zhao, L.; Wang, X.; Qian, Y. Analysis of factors that influence hazardous material
transportation accidents based on Bayesian networks: A case study in China. Saf. Sci.
2012, 50, 1049–1055.
15. Handbook of Storage Tank Systems, By Wayne B. Geyer