ATTACHMENT 1 ABS Consulting General Technical Specifications for Performing HAZOP Studies

INTRODUCTION ABSG Consulting Inc. (ABS Consulting) specializes in hazard evaluation, reliability engineering, and risk assessment. Our principal engineers are recognized experts with considerable experience in all aspects of complex process systems analysis; they are complemented by professional computer programming, technical support, and technical publications personnel. We have performed thousands of hazard and operability (HAZOP) studies of facilities that handle many toxic, flammable, and reactive materials in both batch and continuous operations. We also wrote the book on how to apply the HAZOP analysis technique as well as other hazard analysis methodologies, entitled Guidelines for Hazard Evaluation Procedures, Second Edition with Worked Examples, published by the AIChEs CCPS. The following sections outline our general approach to performing HAZOP studies. This basic approach can be modified to suit individual client needs. If the specific requirements for a particular HAZOP analysis include exceptions to this specification, those exceptions will typically be detailed in our proposal cover letter for that work. TECHNICAL APPROACH An analysis team composed of client and ABS Consulting personnel perform the HAZOP analysis. During one or more HAZOP meetings, the team reviews and evaluates the systems and procedures that are designed to limit employee and/or public risk, economic loss, and/or environmental impact. The analysis team uses the HAZOP technique to identify and evaluate process hazards. The HAZOP technique is a systematic method used to identify the ways that process equipment can malfunction or be improperly operated, leading to undesirable conditions. The key elements of the HAZOP technique are defined by the following terms: Intentions Deviations Causes Consequences Safeguards Recommendations successful operating states for process sections departures from the design intentions reasons why deviations might occur effects of the deviations
features designed to prevent the causes or mitigate the consequences of deviations

suggestions for design changes, procedural changes, or further study

To apply the HAZOP analysis technique, the equipment shown on the piping and instrumentation diagrams (P&IDs) for the system to be analyzed is divided into process sections (tanks, vessels, reactors, furnaces, interconnecting piping, etc.). The HAZOP team then reviews the P&IDs, other appropriate process safety information, and the equipment itself to help identify hazards associated with deviations from the design intentions for each process section. For each deviation, the team (1) decides whether any consequences of interest (e.g., employee hazards, public risk, economic loss, and/or environmental impact) would result from credible causes of deviations, (2) identifies the engineering and administrative safeguards protecting against particular deviations, (3) qualitatively evaluates the risk associated with the deviations, and, if necessary, (4) makes recommendations that might reduce the likelihood of the deviations or the severity of the consequences.

ATTACHMENT 1 General Technical Specifications for Performing HAZOP Studies (contd)

Depending on the level of documentation required by each client, ABS Consulting typically will record the proceedings of each HAZOP meeting on a worksheet, similar to the example shown in Table 1. The table comprises six columns: Item, Deviation, Causes, Consequences, Safeguards, and Recommendations. The first column, Item, is simply an assigned index number that refers to the process section and deviation. The remaining five columns are described in the following paragraphs. Alternate worksheet headings can be used to suit specific client needs. Each meaningful Deviation from a process sections design intention is listed in the second column. The review team evaluates a standard set of potential deviations for each type of process section. Deviations are considered only if they are meaningful for a particular process section. Table 2 lists example deviations considered for typical types of equipment in continuous process operations, but this list is often modified to address process-specific issues (e.g., reaction rate, agitation, pH). Causes of each deviation are listed in the third column of Table 1. Generally, only functional failures or single failures of equipment are considered, since they are typically the most likely causes. Each listed cause includes all command faults or other failures that would produce a similar effect. For example, the cause flow control valve transfers closed would include failures of the flow sensors, the transmitters, and the wiring, as well as any operator errors. Personnel errors considered in the review will generally be errors of omission, such as an operator failing to align valves correctly or a maintenance worker failing to completely purge or isolate a component before opening it. Operator errors of commission are usually limited to valve misalignments that might occur during operations. For each deviation, there are many other causes that would involve multiple equipment failures, but these are usually not listed. Also not listed are certain generic causes of process hazards (personnel actions with malicious intent, software programming errors, etc.). In addition, most external events such as tornadoes, airplane crashes, and construction accidents are not generally listed as causes for the process deviations they could produce. The Consequences column in Table 1 identifies the hazards that can result from a particular deviation. These consequences could include items such as potential releases of flammable/toxic material, major process upsets, and explosions. The consequences listed should be interpreted as reasonable worst cases, assuming that the causes would be severe enough, persist long enough, and all controls fail. Deviations with no significant impact or with no single active component failure as a cause will have no consequences listed. The consequences listed will reflect the specific scope of the HAZOP study (e.g., operability impacts can be included, if appropriate). Safeguards are equipment features and operating procedures designed to (1) reduce the likelihood of one or more causes of the given consequence(s) or (2) reduce the severity of the given consequence(s). The specific controls or safeguards protecting against a particular deviation, such as remote shutoff of a valve from the control room, will be discussed and listed in this column in the HAZOP meetings.

ATTACHMENT 1 General Technical Specifications for Performing HAZOP Studies (contd)

The last column in Table 1, Recommendations, refers to the HAZOP teams specific suggestions described in the text of the HAZOP report. The suggested actions will be developed by the analysis team as it reviews the process systems and may include adding hardware, upgrading equipment, modifying design drawings, performing additional reviews, and modifying procedures. TYPICAL PROJECT TASKS Although we have significant experience in conducting HAZOP analyses, personnel responsible for designing and operating a specific process possess the bulk of the knowledge and experience needed for the HAZOP review. Because an essential element of a HAZOP analysis is the transfer of information about system design, operation, inspection, and maintenance to the HAZOP team, the full cooperation of client personnel is necessary to ensure successful completion of the work. This will require consistent, close coordination between client and ABS Consulting personnel. Our experience has shown that this interaction is a necessary ingredient for meaningful and practical results. Thus, we usually propose several separate HAZOP meetings for information transfer, actual task activity, and review of intermediate results, depending upon the size and complexity of the subject process(es). Our recommended approach is one that we have used successfully in similar HAZOP analyses. It consists of the following steps: 1. Collect data for the analysis. Approximately 2 weeks before the first HAZOP meeting, we will need the following information: Process flow diagrams (these must indicate approximate process conditions) Material safety data sheets (or other pertinent chemistry data) for chemicals involved in the process Piping and instrumentation diagrams (P&IDs) Design temperatures and pressures for major equipment (these data should be compiled if not shown on the P&IDs) Pump/compressor curves and maximum (blocked) discharge pressures Materials of construction for equipment and interconnected piping (if not indicated on the P&IDs) Plot plan with general equipment layout and elevations Standard operating procedures (SOPs) for normal operations, as well as procedures for startup, shutdown, sampling, emergency shutdown, and any on-line maintenance Safe work practices and permits/authorizations Emergency procedures (if they exist)

In addition, the client should assemble the following information that the HAZOP team members may need as reference materials during the HAZOP meeting: Electrical classification drawings/information Equipment testing/inspection plans Process alarm setpoint data, as well as logic/ladder diagrams or loop sheets for complex safety instrumented systems Relief system design basis (including set pressures and relief capacity sizing basis for relief devices) Ventilation system design data
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ATTACHMENT 1 General Technical Specifications for Performing HAZOP Studies (contd)

2. Prepare for the first HAZOP meeting. In preparation, we will divide each process system into appropriate sections for analysis purposes. We prepare (1) HAZOP worksheets listing the process sections and a proposed list of deviations for each section and (2) an introductory presentation designed to inform participants about the HAZOP technique. 3. Conduct the first HAZOP meeting. ABS Consulting assigns an experienced process safety engineer to serve as project manager and team leader for each analysis. The team leader meets with the client members of the HAZOP team and may be assisted by another ABS Consulting hazard analyst (depending on the documentation selected) who participates in the hazard evaluation meetings and serves as the scribe, taking extensive notes of the meetings. The objective of this first meeting is to analyze as many process sections as possible during 6 to 8 hour-per-day sessions. Of course, some questions will arise that cannot be answered immediately. The HAZOP sessions will progress, however, and any open issues (e.g., whether an unused line is blinded) will be resolved after the session. 4. Document the results from the first HAZOP meeting and prepare for subsequent meetings, if necessary. We complete the documentation of the HAZOP meeting and prepare a list of potential recommendations discovered during the first HAZOP meeting. Shortly after the first meeting, ABS Consulting will transmit a preliminary list of the teams recommendations to the client. 5. Conduct subsequent HAZOP meetings and document their results. The objectives of subsequent meetings are to (1) complete the analysis of the subject systems, (2) answer unresolved questions from the previous meeting(s), (3) review the HAZOP results from those meetings, and (4) review the recommendations that were suggested during the HAZOP analysis. 6. Prepare the report. Depending upon the documentation needs of the client, the ABS Consulting leader (and scribe if required) will integrate the HAZOP teams recommendations with a detailed HAZOP table into a report for transmittal to the client for review. 7. Revise the report (if necessary). If a client has review comments, we address the comments and reissue the report. Although it is likely that the HAZOP team will have some practical suggestions for dealing with potential problems uncovered during the study, the primary objective of a HAZOP analysis is to identify not to solve immediately potential problems. We carefully direct the HAZOP team to ensure that the analysis stays focused on identification of hazards; however, we record team ideas and suggestions for improving the safety of the analyzed process systems. These recommendations may result in modifications to the process design and/or changes in the operating and emergency procedures for these processes. ABS CONSULTING PERSONNEL ABS Consulting assigns experienced HAZOP leaders to serve as project managers for our HAZOP analyses. These engineers are responsible for coordinating all aspects of the work with the designated customer technical contact. Depending on a clients documentation needs and the size of the system to be analyzed during the HAZOP meetings, the HAZOP leader may be assisted by another ABS Consulting hazard analyst who participates in the HAZOP meetings and serves as the HAZOP scribe. An independent ABS Consulting engineer technically reviews all written work products we produce and provides quality assurance for HAZOP studies.
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ATTACHMENT 1 General Technical Specifications for Performing HAZOP Studies (contd)

CLIENT PERSONNEL REQUIREMENTS Performing HAZOP reviews requires the significant involvement of client personnel who have detailed knowledge of the subject process and/or facility. A HAZOP study can be successful only if adequate effort is committed throughout the project. We do, however, appreciate our clients desire to minimize impacts on personnel. Therefore, we design our HAZOP projects to make the most efficient use of available design and operations personnel. The primary commitment our clients must make is the commitment of personnel to participate in the HAZOP meetings. The following types of individuals are usually needed each day during the HAZOP meetings; other types of personnel may also be needed, depending upon the specific process being analyzed: A process and/or design engineer who is knowledgeable about the process/facility design (mandatory) One or more senior operators and/or supervisor who have significant experience in operating the various processes to be reviewed (mandatory) A person knowledgeable about the maintenance of the subject process/facility (mandatory) An instrument engineer familiar with the subject process/facility (on call) A person knowledgeable about inspection and testing of equipment in the subject process/ facility (on call)

ATTACHMENT 1 (contd)

TABLE 1

Example Worksheet for Recording HAZOP Meeting Proceedings

Causes Consequences Safeguards Recommendations

Item

Deviation

1.0 Vessel - Railroad Tank Car Containing Chlorine Vendor overfilling the tank car Small release of chlorine through the tank car relief valve because of thermal expansion No safety consequences Unloading hose connections leaking Gasket and packing failures in the dome area of the tank car Relief valve seat leaking External impact Relief valve failing to open when demanded Tank car movement during unloading Small release of chlorine Personal injury to the operator on top of the tank car Operator periodically monitoring the tank car valves while unloading Personnel safety equipment 1 4 9 Good vendor loading practices

1.1

High level

1.2

Low level

1.3

Leak

1.4

Rupture

Large release of chlorine Personal injury to the operator on top of the tank car

Personnel safety equipment Tank car brakes on, wheels chocked, and blue flag posted Installing train derailer on track Excess flow valve in tank car lines

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ATTACHMENT 1 (contd)

TABLE 2 Example Deviations for Typical Process Section Types

Process Section Type Deviation High flow High level High interface High pressure High temperature High concentration Low/no flow Low level Low interface Low pressure Low temperature Low concentration Reverse/misdirected flow Internal leak or rupture Loss of containment Startup Shutdown Maintenance/Sampling X X X X X X X X X X X X X X X X X X X X X X (if applicable) X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Column Tank/Vessel Line/Heat Exchanger/Pump X Fired Heater X