A Holistic Approach to the Safety Lifecycle

A Holistic Approach to the Safety Lifecycle

Holistic Approach to the Safety Life Cycle

Holistic (adj): relating to or concerned with wholes or with complete systems rather than with the analysis of, treatment of, or dissection into parts.

A lot of factors enter into how a Process Safety Culture develops in an organization, but the net result is that either an organization has a positive, effective Safety Life Cycle culture or becomes exposed to major incidents that can cause a business to fail. The history of major incidents in process plants is littered with root causes related to failed Safety Cultures.

A robust Process Safety Management culture in a facility also leads to multiple other improvements. In an operation where Process Safety has a major focus, operators tend to be more attentive to keeping their units stable and on spec and the entire organization tends to be more focused on quality of work. If there is a lax Process Safety Culture, then it is easy for operations to become sloppy and for other groups to just let things slide.

When I stand back a bit and think of what factors determine whether a facility has an effective Safety Culture, the following come to mind. All of these are complex subjects, so only a bit is discussed. However, the combined effect of these items has deep impacts upon whether a Process Safety Culture is positive or toxic. In the end however, people do the work for which they are rewarded, even if it’s just a positive performance review. If Process Safety performance is not a key item on the expectations for an employee’s performance, its probably not going to be something that gets a lot of effort. 

Management Attitude

Unfortunately, the number one factor in determining how successful a Process Safety Culture becomes, is the attitude of the management of an Enterprise or Site. I’ve had the fortune and mis-fortune to work in environments where the management had some level of appreciation of Process Safety and work in environments where Process Safety came right after cost, schedule and getting my next promotion (and I hope I get out of here before something goes wrong).

A successful Process Safety Culture, and the Process Safety Management structure that evolves from it, starts at the top. In order to have an effective system, the management of an organization has to demonstrate that Process Safety is as important as the quarterly results. Management has to continue to reinforce that commitment. A basic philosophy has to be defined and spread through the organization, and the expectations of that philosophy need to be rigorously applied at all levels of management and supervision. Failure to meet those expectations has to have real consequences.

Management has to demonstrate a basic knowledge of, and high and continuous interest in the Process Safety Management System. The status of Process Safety needs to be as high on the priority list as more measurable things like production results and costs. Plant staff needs to understand that missing key performance targets for Process Safety functions such as periodic testing, having too many demands or tolerating poor safety function performance have the same consequences as other financially related shortfalls. If management isn’t actively following the Process Safety Life Cycle, they are really telling their staff that they don’t care, and the staff is going to let things slide to pursue things that they think that management cares about.

The systems also have to be robust enough that they become embedded in the organization’s operating culture so that it can survive the changes in personnel, including management, that always happen. Personnel need to have clearly defined responsibilities and be trained to meet those responsibilities. When an individual takes on a new position, the Process Safety responsibilities and procedures need to be part of the transition process. It’s tough to build a Process Safety Culture, but it’s fairly easy to destroy one. When the first question out of manager’s mouth is what does it cost? Or why are you doing that? it’s a good sign that the Process Safety Culture isn’t doing very well.

Information Availability and Training

Part of implementing a robust Process Safety Management System is making sure that all of the personnel that are expected to perform tasks related to the system are fully trained and have access to the information they need. This extends far beyond just the mechanics of performing their assigned tasks.

The training they receive needs to include a clear identification of how their tasks fit in with the Safety Life Cycle Management System, and full training in the underlying process hazards and access to usable reference data. Training needs to be routinely reinforced. Refresher training should be routine and training on changes to Process Safety Systems should be an integral part of the Management of Change procedures. As noted above, Process Safety requirements and procedures need to be part of all transition plans.

Operations personnel in particular require comprehensive initial training and periodic refresher training. Operations personnel need to be fully aware of the protective functions that are installed in their units, what process hazards are responsible for their installation, and how they are operated. Operations supervision needs to take an active role in making sure that this knowledge is current, and operators are routinely drilled in the properly responses to process safety related events.  Procedures for collection of event data for demands, failures, bypasses and similar events need to be reinforced and accurately captured.

Procedures

Written procedures need to be prepared and maintained for Process Safety related activities. This includes validation and periodic testing procedures, operating procedures and procedures for capture and transmittal of Process Safety related events such as Demands, Tests, Failures and Bypasses. These procedures need to be readily available to all individuals whose jobs involve Process Safety, which means just about everybody.

Personal Experience and Biases

Everyone who is part of the Safety Life Cycle comes to the process with their own experiences and biases. The most general categorization is those who have experienced a major incident and those who have not. The members of the those that have group seldom need to be convinced of the need to have a robust and effective Safety Life Cycle Management process.

The those who have not group often are the most difficult to bring into compliance as they often do not recognize the critical value that the process has. This is an especially difficult problem if the members of management at the higher levels believe that “it can’t happen here”. Unfortunately, these folks get multiple opportunities to join the “those that have” group and its just a matter of how severe their lesson is. Trevor Kletz’s books, What Went Wrong, and Still Going Wrong should be mandatory reading for those folks. They need to be convinced that it can happen to them.

Silos, Tribes and Conflict

Every process facility is organized into various departments and work groups. Over time the divisions between these departments and work groups can become tribal with each group working in their own silo and not sharing information. Information becomes power and often isn’t readily shared.

Process Safety Information is unfortunately one class of information that is far too closely held. This is partially due to the isolated nature of the common process hazards analysis software packages, but in some places, especially those with poor Process Safety Cultures, process hazard data is almost treated as a state secret. I recall on multiple occasions attempting to get copies of HAZOP data from a Process Safety Group and getting the equivalent of “who wants to know” before I could force release of the data. Not a healthy environment. Process Safety information was distributed to operations and maintenance personnel in heavily curated forms and very few people had access to the actual HAZOP data.

The same thing can happen between operations, engineering and maintenance groups. They end up performing day to day work in a vacuum and data sharing is determined only by what is available on the common operation and maintenance tools that are available. It isn’t always intentional, that’s just the way the work processes end up dividing people.

Process Safety Management Systems require a lot of data sharing and organizational barriers need to be broken down, or at least partially broken down. In a robust Process Safety Culture, these barriers are not as firm and you see a lot more data sharing that can be observed in organizations that don’t have a good Process Safety Culture.

See how industry leaders like Shell are digitizing their process safety lifecycle!

System Capabilities, Limitations and Performance

I’ve long had a private theory that the operating culture in a plant is set by the design, capabilities and failures of the plant’s process control systems. It’s not that personnel set out to make it that way, but over time people adapt their behavior to match what the process control system allows them to do or what the system’s performance and reliability imposes upon them in forced work around or other less than optimum practices. Everything an operator sees on a daily basis is viewed through the lens of the information provided by the process control system and that shapes a lot of culture. This ends up affecting how other organizations behave, as in most facilities operations is king no matter what the organization chart says.

In the same manner, the presence or lack of presence of Process Safety Systems and the importance that the plant management and supervision place on those systems shapes a plant’s process safety culture and determines how effective these systems are. This determines whether they become the assets that were intended to be or become perceived as an obstacle to operations

Poorly designed systems may fail to provide the protection with which they have been credited. Even worse, poorly designed systems result in loss of credibility with the staff that have to work with them. Operators will not tolerate a system that causes false trips, operating difficulty or is just too hard to understand. Before long the systems are disabled, and nobody asks why.

I’ve seen lots of skepticism, some well-earned, from operators when a new safety system was installed. Often, they get handed a system designed by a contractor that had little guidance other than a Project Engineer beating them up for cost and schedule. Upon the first operational difficulties, the criticism starts. In an organization that has a poor Safety Life Cycle management system, the criticism is often just accepted, and management starts hearing the complaints and decides that the safety systems don’t really have much value.

The first requirement is that the design all Safety Related functions get adequate direction and review from qualified engineering staff who are skilled in design for reliability and design of human interfaces and understand how the plant operators view things. When performance issues do occur, the design needs to be looked at to determine where the problem occurred. In some cases, it’s a learning experience as prior poor operating practices may have caused the operators to be careless and allowed the process to go where it should not have gone. In other cases, the protective system operated exactly as it should have, and the operators don’t initially appreciate the bullet they dodged.

Well-designed systems can have the opposite effect. Engineering and Process Safety personnel need to take the performance of the installed protective systems very seriously. These are not install-and-forget systems. Operations often needs considerable hand holding for quite a while after commissioning. This involves continued contact with operations personnel about their experiences and seriously listening to their feedback. Sometimes there are explanations, clarifications and follow up training, but just as often there is something that needs to be fixed.  All trips that occur need to be investigated to determine if a trip was valid and then operations needs to be brought into the loop on the findings. 

Sometimes they just have to learn by being saved by a process safety system. I recall installing a rather complex protective system on an FCCU. The operators were very afraid of the system (first question during training – How do I turn it off? Answer – You don’t. Second question What do I do if it trips – Answer – Secure the unit, calm down and then start the restart procedure). It took a lot of convincing to get them to turn on the system and more than a few questions over time about what it really would do.

You could tell it was always on their mind as I seldom could walk through the control room without someone having a question or complaint, but I did make it a point to wander by fairly regularly and start a conversation before I got hijacked. One day they had an equipment failure that resulted in the system tripping the unit. First response was that it was the trip system that caused it. After a couple of days of the investigation, one operator realized that it really was a valid trip, and it saved them from a lot of equipment damage and people getting hurt. The operator passed on his epiphany to others on his crew. The questions stopped and there wasn’t any more grumbling. I knew we had broken through when the operators were reminding each other about putting the system into service before they started back up.

A lot of factors affect how a Process Safety Culture develops in an organization. 

 Rick Stanley has over 45 years’ experience in Process Control Systems and Process Safety Systems with 32 years spent at ARCO and BP in execution of major projects, corporate standards and plant operation and maintenance. Since retiring from BP Rick has consulted with Mangan Software Solutions (MSS) on the development and use of MSS’s SLM Safety Lifecycle Management software and has performed numerous Functional Safety Assessments for both existing and new SISs.

Rick has a BS in Chemical Engineering from the University of California, Santa Barbara where he majored in beach and minored in Chemical Engineering… and has the grade point to prove it. He is a registered Professional Control Systems Engineer in California and Colorado. Rick has served as a member and chairman of both the API Subcommittee for Pressure Relieving Systems and the API Subcommittee for Instrumentation and Control Systems.

Non-Instrumented Independent Protection Layers (IPLs) – Hiding in Plain Sight

Non-Instrumented Independent Protection Layers (IPLs) – Hiding in Plain Sight

Non-Instrumented independent protection layers (IPLs) are hiding in Plain Sight. A few of the often-missed non-Instrumented IPL types are often forgotten in the real world. This blog is not a complete list of non-Instrumented IPLs but instead it highlights how easy it is for these types of protective features to be forgotten and unintentionally disabled. An organization needs to rigorously manage these “invisible” IPLs to assure that they receive the maintenance and management of change procedures they require to continue to be able to perform their functions.

When an Organization conducts Layer of Protection Analyses, IPLs are identified by the LOPA teams. As described in the CCPS publication Layer of Protection Analysis: Simplified Process Risk Assessment-there are a wide variety of functions and design features that may be credited as an IPL, provided that other criteria such as the ability to prevent a consequence, independence and availability are also met.

Many Organizations tend to focus on Instrumented IPLs such as Alarms and Basic Process Control System functions. However, there are a significant number of other non-Instrumented IPLs for which credit may be taken. Many of these IPLs are passive or mechanical functions that often fade from the Organization’s attention as they are often look just like non-IPL equipment.

See how industry leaders like Shell are digitizing their process safety lifecycle!

Tank Berms and Dikes

One of the most common non-Instrumented IPLs is installation of Berms and Dikes (Bunds if you are outside of the US) that contain the contents of a storage tank or vessel should there be a loss of containment event. Berms and Dikes get a fair amount of attention during their initial design, but soon become just a background feature in the tank farm. Over time, they can degrade or be compromised by ongoing operations.

One of the more recent and spectacular failures of containment IPLs is the Buncefield storage facility fire that occurred in the UK in 2005. As with most major incidents, there were a number of contributing causes, but one of them was the failure of the tank containing walls to contain the liquid released by a tank failure. This allowed inventory to escape the secondary containment. The investigation of the incident found that seals in the concrete wall containment system had not been maintained and significant material flowed beyond containment.

Drainage Systems

When sizing pressure relief systems, credit is often taken for the presence of drainage systems that will prevent the accumulation of flammable liquids around process vessels. This allows the designers to eliminate or reduce the size of the pressure relief systems for fire cases. A drainage system consists of physical grading or installation of drainage trenches or lines that carry away flammable material to a “safe location”. These systems are usually dry for years and decades and aren’t that hard to compromise. Drains and trenches can become plugged with debris or the “safe containment” area gets compromised or even built over. The Buncefield fire and explosion mentioned above was aggravated by the fact that the drainage systems failed to function as they were designed, and material that leaked from the tank containment did not flow away from the area as intended.

 

Frangible Tank Roofs

Storage tanks are subject to overpressure from a variety of sources as described in API RP-2000. For the more extreme cases, such as external fire, designers may choose to specify that the that tank be constructed with a weak roof to wall connection, or a frangible roof. The design is intended to provide a failure point which would allow a path to relieve vapors generated prior to failure of the tank at more catastrophic locations such as at the floor to wall seam.

The difficulty with constructing tanks with a frangible roof specification is that externally it is extremely difficult to verify that the welds at the roof seam meet the requirements for a weak seam. In tank over pressure audits conducted many years after tank construction, it was found that it was basically impossible to verify that the existing tank roof to wall welds qualified as a frangible roof. During the study, a few reports of welds not meeting frangible roof specifications were found. There is no practical means of testing the seam, so there was little alternative other than to not take credit for a frangible roof, which resulted in retrofit installation of some very large emergency roof vents.

Excess Flow Valves

Excess flow valves are typically installed to prevent the uncontrolled flow of hazardous material from a vessel to the environment should an external failure occur, such as failure of light ends pump seals or other loss of containment events involving equipment downstream of the process vessel. They are also found in transportation applications such as truck loading racks or in pipelines.

In regulated industries such as transportation and pipelines, excess flow valves typically have high visibility and usually get tested and maintained. However, in process applications, this isn’t necessarily the case. Process excess flow valves are often installed at the outlet of a process vessel and are of a design that uses a check valve installed in a reversed position. The check valve is held open by a mechanical linkage that is released by either a fusible link that melts when exposed to a fire or a solenoid valve that releases the linkage, and sometime both.

Once installed, these valves appear remarkably common. They look like most any other check valve and often get ignored and sometimes forgotten about. I recall being in an older process unit on other business when I just happened to notice a couple of wires hanging from an open conduit. In itself this was a big issue as if those wires were energized an ignition event could occur. So, I started to look around and found an old, solenoid operated excess flow valve nearby that was missing its wires. Worse yet, the excess flow valve hadn’t operated. A bit of inspection showed that the solenoid was indeed deenergized, but the mechanical latch mechanism was severely corroded and had not allowed the valve to operate. Even more interesting was when I reported this to the Operations group, they had no idea that the excess flow valve was there. No wonder it never got looked at. The wiring disconnection appeared to be some casual modification that no one had any idea of when or who did it, or why. This incident started a hunt for other excess flow valves in the plant, which turned up another handful of issues. After decades of neglect, the excess flow valves got added to an inspection and maintenance list.  

Check Valves

In high pressure applications, such as feed pumps for hydrocrackers, other services where liquid is being pumped from a very low pressure to a very high pressure, or when a high pressure process can back flow into a low pressure process, check valves are often depended on to provide some level of overpressure protection for the low pressure system. API RP-521 recognizes this practice and recommends that credit only be taken for installations consisting of two check valves of differing designs installed in series and describes considerations that should be used in assessing potential leakage through the check valves.

The difficulty in operating these systems is that almost every pump in a process plant has at least one check valve installed in its discharge lines, so keeping track of which check valves are being credited for over pressure protection can be a challenge. It’s quite easy to lose track of these valves and not give them the routine inspection and leak testing required for those services which are being used at IPLs or to reduce the low-pressure relief system requirements. The check valves that are used for these purposes are usually high-pressure designs (2500 or 1500 pound class) and are difficult to maintain due to weight and sometimes being installed with welded ends. At the same time, the hazards of a failed check valve service are quite high, as high-pressure backflow will generally result in the rapid unscheduled disassembly of the low-pressure equipment.

Flame Arrestors

Flame arrestors are static device, usually consisting of some form of metal mesh or similar convoluted flow passages at the location where a tank or other vessel is vented to atmosphere. Flame arrestors are designed to prevent flame propagation from the vent outlet back into the tank or vessel, usually by cooling an external flame and reducing the flame propagation velocity.

Flame arrestors are passive devices and may remain in place for many years without any attention. This often results in the functionality being compromised due to build up of dirt, insect nests, corrosion or other degradation. Flame arrestor design is also based upon a very specific set of conditions such as the flammable material contained in the tank and environmental conditions. It is not that difficult to compromise or plug up a flame arrestor, and there are reports of them failing to function when needed or being found in an inoperable condition when inspections were eventually performed.

Block Valve Lock Systems

In some process designs, safe operation of the process is depended upon block valves installed for maintenance, startup or shutdown operations being kept in specific positions, either opened or closed. For example, pressure relief system designs are often dependent upon block valve installed under pressure relief devices being kept open at all times, or other block valves required to isolate parallel equipment being kept open whenever process fluids are in the system.

Often block valve lock systems are manually managed with only manual monitoring. The physical “lock” varies with the operations, ranging from simple aluminum car seals such as those used on rail cars or truck doors, to new plastic designs, to designs that used metal cables or chains with physical locks. In some cases, an organization will attempt to not use physical barriers and rely only upon hanging warning tags on valves.  

Use of block valve lock systems requires that there be a robust administration system whereby the status of all locked open or closed valves are continuously kept and logged, and that procedures to follow when removing or installing a block valve lock/seal and changing of the valve positions are clearly specified and followed. If locking systems are used, an additional layer of tracking of keys is also required.

For a process plant of any size, there may be a large number of block valves that are designated as CSO, CSC, LO, LC etc. (Car Seal Open, Car Seal Closed, Locked Open, Locked Closed). Administration of these valve seals or locks is no small task and more than a few units have failed surveys of their valve lock systems.

Captive Key Systems

Captive key systems are a step above the use of simple valve seals and locks. In most cases, captive key systems are used in applications where a number of valves or other equipment must have their status changed in a specific order. In these systems, the valves or other operating equipment are provided with a mechanism that requires that a key be used to unlock the valve or system for operation. The mechanism captures the initiating key when the operation is performed and releases another key that is used to operate the next valve or system in the sequence. The system has multiple keys, all of which are different. When using a captive key system, the operator starts with an initiating key that is used to operate the first device in the chain. Keys are trapped and released in sequence, with the final device releasing a key that then is stored in a safe location. When the sequence is to be reversed, the operator starts with the final key and the sequence is reversed.

Captive key systems are often used to assure that equipment is safely isolated for entry or maintenance, such as in high voltage electrical systems, or in systems that require a large number of sequential valve movements to isolate equipment such as a spare reactor. The challenges of ownership are administration of the starting and ending keys, so they do not get lost and keeping the various locking mechanisms clean and operable. The use of these systems is often very infrequent and it’s not difficult to lose track of keys or find that the locking mechanisms aren’t working when needed.

Conclusions

Non-Instrumented IPLs have process safety roles that are every bit as important as Instrumented IPLs. However, as they are often passive design features and may be so similar to other equipment, they often fall out of view and fail due to age, neglect or modifications. It is of critical importance that these Non-Instrumented IPLs are clearly documented and that their process safety functions are clearly communicated to Operations and Maintenance personnel so they can be taken into account during Management of Change activities. A system that manages only Instrumented IPLs and does not allow management of Non-Instrumented IPLs is incomplete and can be an obstacle to effective IPL and Process Safety Management.

 

Rick Stanley has over 40 years’ experience in Process Control Systems and Process Safety Systems with 32 years spent at ARCO and BP in execution of major projects, corporate standards and plant operation and maintenance. Since retiring from BP in 2011, Rick has consulted with Mangan Software Solutions (MSS) on the development and use of MSS’s SLM Safety Lifecycle Management software and has performed numerous Functional Safety Assessments for both existing and new SISs. 

Rick has a BS in Chemical Engineering from the University of California, Santa Barbara and is a registered Professional Control Systems Engineer in California and Colorado. Rick has served as a member and chairman of both the API Subcommittee for Pressure Relieving Systems and the API Subcommittee for Instrumentation and Control Systems. 

 

 

Bring Back the Basics-A deeper Dive to Practical Field Instrumentation in Process Safety Service (Part 2)

Bring Back the Basics-A deeper Dive to Practical Field Instrumentation in Process Safety Service (Part 2)

Bring Back the Basics – A deeper Dive into Practical Field Instrumentation in Process Safety Service

(Blog Series Part 2)

 

General Requirements 

When it comes to specification of field instrumentation used for Process Safety related applications, designers are often left on their own to specify the instrumentation. SIF input and output performance may be specified in a Safety Requirements Specification, but all too often I’ve observed that these specifications are minimal or go directly to specifying a manufacturer and model number without defining what the performance requirements actually are. I’ve also observed some level of carelessness in specifying field instrumentation for Process Safety related applications. Engineers, being Engineers are often attracted to shiny things. This doesn’t really have a role in selecting field instruments for Safety Related Services. I’ve seen quite a few instances where inappropriate selections were made in pursuit of the bright and shiny.

Field instrumentation must be specified and installed so that it meets the requirements of the IPL or the SIF Safety Requirements Specification. Some of the considerations to include when selecting the field instrumentation and its installation are:

  • Ability to make the required measurements with the required accuracy and response time
  • Independence of the measurement from IPL Initiating Causes and from other IPL’s
  • Ability of final elements to execute the required Safe State actions with the required response time and performance
  • Availability of the instruments and the ability to deliver performance that meets the IPL or SRS Integrity Level requirements
  • Reliability of the instruments and their installation to deliver the SIF Spurious Trip Rate specified in the SRS.
  • Maintainability and Testability of the instruments

 Making the Measurement

Quality input measurements are critical to a SIF’s or other instrumented IFPL’s successful implementation. Selection of input field instruments must be reliable and provide the level of accuracy of the measurements needed to provide a well performing IPL or SIF.

Input measurement instruments should be selected based upon a User Organization’s experience with the measurement methods and the devices specified. They also only need to perform well enough to meet the requirements. Over specifying accuracy or attempting to use measurement methods that don’t have an established track record can result in poor IPL performance. This isn’t always obvious to a lot of SIS engineers or to the engineers specifying the field instrumentation. Specification of new, untried measurement techniques has gotten more than one engineer in trouble in the pursuit the new, bright and shiny. A few applications where this has resulted in problems are highlighted below

  • A Site was moving towards greater use of guided wave radar level measurements. Early experience in a few test applications had been limited, but positive. A decision was made to apply them to a retrofit of a set of reciprocating compressor protective shutdowns. The designs proved to be unreliable for shutdown applications as the measurements would frequently drop out for short periods, but which the shutdown systems saw and shut down the compressors repeatedly. Since then, guided wave instrument manufacturers have refined their designs to address the problems that were causing the instrument signals to drop out.
  • A Site was moving towards the use of vortex shedding flow meters as an alternative to traditional orifice plate and DP transmitter flow measurements. A decision was made to apply them to a process heater low feed shutdown. Further, to save the cost of multiple flow meters a two-head vortex shedder design was specified. During an FSA for the SIS, the selection of this flow meter was questioned. After some investigation it was determined that the two-headed design was a prototype for the manufacturer, and that there was no data at all on its performance. The design had not even been flow tested in the lab. The FSA report recommended that this device not be used in SIF applications.
  • A Process Licensor specified a feed gas specific gravity analyzer be used in correcting a feed flow measurement, and that the corrected value be used in the unit master shutdown. The system was installed as specified by the licensor, and within the first week of operation a spurious trip occurred due to a brief power interruption to the analyzer. It was suspected that a technician had mistakenly shut off power and then turned it back on after realizing their mistake. The shutdown system saw the dip and tripped the unit on low flow. As a result, the analyzer was taken out of the flow correction calculation.

 Some general thoughts on specification of input instrumentation

  • The SRS for SIF’s should specify functional requirements for input instrumentation such as the basic instrument type, required accuracy of the instrument and the trip point, and the measured range. The SRS should also identify the service severity of the process measurement (high temperature, high pressure, corrosive, high vibration, etc.).
  • Input instrumentation should be selected from types for which the User has significant experience and be as basic as possible. Process Safety related instrumentation is not a place to try out new stuff. Complex instrumentation, especially analyzers should be kept out of any shutdown applications. Where possible, the User should have a list of qualified instrumentation, either due to prior use experience or vetting though manufacturers service data or third party certification.
  • Input instrument ranges should be selected to provide a live measurement at normal operating conditions and have sufficient signal margin around the trip point to provide a reliable indication of a trip condition. This can be a problem in some applications such as low flow trip that uses an orifice plate and DP transmitter. There is a square relation between signal and flow, so a trip set point of 10% of the instrument’s flow range is actually only 1% of the DP transmitter signal. This is generally too low of a signal to reliably indicate a trip condition so either the trip point needs to be raised or a flow measurement method that doesn’t have this behavior should be considered.

It should be noted that many times a trip point is specified based upon maintaining a comfortable margin between normal operation and trip conditions, and that sometimes a too wide of a margin is specified. There is a balance between maximizing this margin and specifying a trip point that is too low to reliably measure.

Final Element Design

Final elements need to be carefully considered for their availability and reliability in being able to bring a process to a safe state. Shutdown valves need to be selected based upon high reliability so they should be of a design where critical parts are not overly subjected to severe process conditions.

For SIF’s the allowable leakage across closed shutdown valves needs to be specified and needs to recognize the realities of how valves behave in real services. Those with operational experience know that no leakage specification survives the first day in process service.

Dedicated shutdown valves with open flow paths and whose critical seating surfaces are protected during the 99.99% of the time the valve is open should be considered. Standard control valve designs typically should not be used where plugs and seats may be subjected to process wear and high pressure drop. Sharing of control valves in shutdown designs is often considered in order to save the cost of a trip valve but in my view doing so to avoid an extra trip valve is usually false economy

Stroking speed needs to be carefully considered and oversized actuators that can break any sticking forces that develop over time are not a bad idea. Actuator designs should be fail-safe and use of double acting actuators or motor actuators should be avoided. Where non fail-safe actuator designs are used, the loss of motive power such as air supply or motor power must be included in PFD calculations and the motive power sources fall under the testing and MOC requirements for SIF’s.

Most shutdown valves use a solenoid valve to vent air off the actuator. Single solenoid valves are subject to spurious trips should a coil burn out or a circuit problem occur. A common application is to use 2oo2 solenoid valves for shutdown valve services. This provides high reliability and allows for frequent online testing. Some of the original home-grown designs with which I was involved were fairly expensive to implement but justified considering the costs of spurious trips. Since then commercial packages with full diagnostic and testing functionalities are now readily available on the market.

Shutdown services may include shutting down of motor driven equipment. Usually a SIF or Interlock that shuts down a motor uses 1 or 2oo2 interposing relays, but often the designer doesn’t consider the reliability of the motor starter itself. This is a particular issue with high voltage, high power motors that use full blown switchgear to operate the motor. These applications usually have an energize to trip motor trip coil, so the performance of this SIF is often dominated by the availability of switchgear power. When a energize to trip motor controller is used, the power systems for that system now fall under the testing and MOC requirements that apply to any SIF.

Independence

The design needs to be independent from other IPL’s or from the IPL’s Initiating Causes. For example, a high-pressure alarm that warns of failure of a pressure control loop requires its own pressure transmitter and process connection.

Instruments associated with a SIF should not share services with BPCS functions, although some organizations allow for minimal sharing, such as allowing one of three transmitters in a 2oo3 voting scheme to share inputs with a BPCS loop. This requires some special attention as now there are two functions involved when maintaining or testing the field instrumentation. In these designs, the transmitter should directly drive SIS inputs using SIS power. The input to the BPCS should be taken from an isolator that will not affect the SIS loop performance if the BPCS circuit is broken

Reliability

While HAZOP’s and LOPA’s concentrate on the required availability of protective functions, in most real plants, reliability is every bit as important. IEC 61511 says almost nothing about reliability and leaves it to the User to figure it out. A key part of specification of any protective function is determining the effect of spurious trips upon a process unit. A spurious trip introduces both process safety risks and commercial risks. It is an adage in the process industries that the highest risk periods are during a unit startup or shutdown. When a unit experiences a spurious trip, the lost production while the unit is secured and restarted, even if no damage has occurred, can be significant. Some processes can take days to restart, and loss of production is measured in the hundreds of thousands to millions of dollars. When an SRS is prepared for SIF’s, the costs and safety risks associated with spurious trips should be identified and specific reliability requirements included.

Process Safety risks are even more of an issue when the shutdown is a crash induced by a protective system’s spurious trip. When a unit is crashed, all sorts of bad things can happen. Hot joints that cool down too quickly can leak or even cause significant loss of containment. Equipment can also be damaged. Some process types are especially intolerant of unit crashes, such of Fluid Catalytic Crackers. A sudden shutdown can result in damage to refractory damage or plugging systems with catalyst or heavy oil. It’s bad enough that an FCC may take days to restart, but if refractory damage occurs, that interruption can spread to weeks and the repair costs can be significant.

The net result is that the costs associated with spurious trips can justify a lot of reliability features in field instrument design. The most common method is the use of voting logic that tolerates a level of faults in the field instrument. Schemes such as 2oo3 or 2oo2d can provide high availability and are tolerant of failures in field instrumentation. I’ve seen places where it was decided to not provide robustness in order to save a transmitter or reduce SIS programming. Those kinds of decisions are usually false economies. Usually the cost of adding robustness to a trip function is covered in the first few minutes after a false trip occurs.

Another aspect of selection of instrumentation for Process Safety Services is to avoid the use of switches. At one time process switches such as float levels, pressure and DP switches, etc. were very common. Their long service history has demonstrated their unreliability. A process switch sits dormant for extended periods and there is no way other than frequent testing to verify whether a process switch is operable or not. As a result of the many improvements made in continuous process measurements and of programmable logic solvers, the justification to use what were perceived as cheaper instruments has become moot. Almost every current standard or recommended practice discourages, or even forbids the use of process switches in Process Safety Services.

Spurious trips can also be significantly reduced by selecting the proper field instrumentation. As discussed above, the field instruments should be a simple and robust as possible. Where an orifice plate and DP transmitter will do, it’s far preferable to use these relatively simple and tried design vs. a complex flow transmitter that may experience signal drop-outs or failure modes that are not well understood.

Accuracy is another area where instrumentation in shutdown services gets over specified. The basis for the specification of a trip point in a SIF or Interlock needs to be clearly understood when field instrumentation is being specified. If the trip point is specified to protect against a specific equipment limit, high accuracy may be required. But if the trip point is needed only to detect when a process has had a failure that can result in hazards, such as a low flow caused by the failure of a pump or compressor, the trip point may be specified only to provide a comfortable operating margin. In these cases, accuracy may not be such a big deal. Attempting to provide highly accurate field instrumentation in a situation where that accuracy isn’t needed can result in designs that are not as reliable as they should be.

Maintain and Test 

All field instrumentation in Process Safety Services needs to be periodically tested. The frequency of testing is based upon the failure rates of the types of devices being used and the performance requirements of the service. Intervals can vary from quarterly to several years apart. In many instances, the test interval is more frequent than the Unit turnaround or outage frequency and provisions must be made for testing while the Unit is in operation.

 Testing provisions can take a number of forms, including

  • Provisions for bypassing of Input signals within the Safety Function logic
  • Provisions for bypassing of commands to final devices
  • Provisions for bypassing of final devices themselves
  • Other on-stream testing provisions such as partial stroke testing

My preference has always been to design testing systems so that the final elements such as valves or motor starters can be bypassed for testing, and that the SIS logic includes detection of when a system is properly isolated and safe for testing. This isolates the trip functions from the inputs and allows for full testing from end to end without running the risk of false trips. Motor starters are difficult to test as generally they can’t be tested without shutting down the motor. Fortunately, the failure rates of motor controllers are low relative to other devices and seldom does the motor controller (other than power for energize to trip switch gear) factor into test interval calculations. However, testing of motor starters at every unit shutdown should be part of any testing program.

Voting systems are usually used in SIF services to provide both availability and reliability. Voting systems can also simplify maintenance of field instrumentation while the SIF and its process are in service. My preference has always been to use 2oo3 voting on inputs, with degradation to 2oo2 during the periods when one of the input instruments has failed. The 2oo3 scheme allows for one instrument to fail and allows one instrument to be removed from service for maintenance with minimum risk of a spurious trip occurring. The fall back to 2oo2d tends to protect against maintenance errors that might take out a second transmitter. In any event, detailed procedures for working on Safety Related instrumentation should be developed during their design.

I also prefer that physical bypass piping and a bypass valve be used with trip valves. In most installations the cost is nominal compared to the costs of a false trip caused during testing. The bypass valve should be equipped with position indication that allows the logic solver to verify that the valves are in bypass before allowing testing to proceed, and which provides an alarm whenever the bypass valve is not fully closed.

Many valve manufacturers offer functionality to support partial stroke testing during ongoing operations. This function results in the valve being commanded to move to some partially closed position, typically 10 to 20% of stroke (90 to 80% open) and then return to a full open position. This hasn’t been a real attractive alternative for me. It complicates the installation, often requiring an expensive smart valve positioner to facilitate the testing in addition to trip solenoid valves. Partial stroke testing also makes life harder for instrument technicians who require special training to partial stroke tests. Newer designs do allow for partial stroke tests to be automatically scheduled and executed, which reduces the probabilities of human error.

There are installations where partial stroke testing is justified, such as a requirement for very frequent testing or for large or very high-pressure valves where installation of a bypass for testing is impractical or just too expensive (that high-pressure piping takes up a lot of space). Some organizations have embraced partial stroke testing, but his requires commitment to fully understanding how these functions work and owning and using the additional software required to set up stroke testing and analyze the results.

Conclusions

The performance and reliability of field instrumentation is critical to the safe performance Process Safety Protective Functions. Proper and complete performance requirements need to be clearly defined in documents such as Safety Requirements Specifications. This includes specification of all set points and the basis for the selection of those set points.

The selection of field instrumentation should be based upon proven performance and well-known characteristics and failure mechanisms. The designs must include provisions for maintenance and testing over the life cycle of the instrumentation. Overall designs should be simple as possible but include provisions for high reliability and simple and safe maintenance and testing. Overly complex selections, or systems not designed for high reliability typically result in poor performance, excessive spurious trips and the accompanying high costs of operation and overall reduced safety of operation.

 

Rick Stanley has over 40 years’ experience in Process Control Systems and Process Safety Systems with 32 years spent at ARCO and BP in execution of major projects, corporate standards and plant operation and maintenance. Since retiring from BP in 2011, Rick formed his company, Tehama Control Systems Consulting Services, and has consulted with Mangan Software Solutions (MSS) on the development and use of MSS’s Safety Lifecycle Management software.

Rick has a BS in Chemical Engineering from the University of California, Santa Barbara and is a registered Professional Control Systems Engineer in California and Colorado. Rick has served as a member and chairman of both the API Subcommittee for Pressure Relieving Systems and the API Subcommittee on Instrumentation and Control Systems.

Bring Back the Basics – Practical Field Instrumentation in Process Safety Service (Blog Series: Part 1)

Bring Back the Basics – Practical Field Instrumentation in Process Safety Service (Blog Series: Part 1)

Bring Back the Basics- Practical Field Instrumentation in Process Safety Service

(Blog Series Part 1) 

The selection of field instrumentation in Process Safety Service can make or break the performance of safety instrumented functions. Poor selection and design can result in unreliable and costly failures and unscheduled shutdowns. In some processes, an unscheduled shutdown can cost millions of dollars as well as expose operating personnel and the community to hazards associated with equipment failure or damage caused by uncontrolled shutdowns. This discussion is directed towards the more practical aspects of specifying and owning field instrumentation that is used in IPL services such as Alarm, BPCS functions and Safety Instrumented System (SIS) Safety Instrumented Functions (SIFs).   

Get a demo of Safety Lifecycle Manager  

The Safety Lifecycle for Process Safety applications runs from the initial conceptual designs for a process unit throughout its life to decommissioning. 

  • The first part of the Safety Lifecycle involves the Hazards Analysis that identifies the need for specific Protective Functions that act as Independent Protection Layers (IPLs). Most of these are instrumented functions that have specified availability requirements. 
  • The second part of the Safety Lifecycle is the detailed specification and design of the field instrumentation sensors and final elements that implement the IPL functions.
  • The third part, and longest duration, of the Safety Life Cycle is the ownership phase where the devices selected are operated, maintained and tested over the life of a process.

 

 Click here to Read Part 2 of this blog series: 

Rick Stanley has over 40 years’ experience in Process Control Systems and Process Safety Systems with 32 years spent at ARCO and BP in execution of major projects, corporate standards and plant operation and maintenance. Since retiring from BP in 2011, Rick formed his company, Tehama Control Systems Consulting Services, and has consulted with Mangan Software Solutions (MSS) on the development and use of MSS’s Safety Lifecycle Management software.

Rick has a BS in Chemical Engineering from the University of California, Santa Barbara and is a registered Professional Control Systems Engineer in California and Colorado. Rick has served as a member and chairman of both the API Subcommittee for Pressure Relieving Systems and the API Subcommittee on Instrumentation and Control Systems.

 

Process Safety Data for Pressure Relief Systems

Process Safety Data for Pressure Relief Systems

Process Safety Data for Pressure Relief Systems

Pressure Relief Systems have been around a long time, but the documentation of their Process Safety Data has a pretty tortured past. Due to the relatively long history, dating back to the early boilers in locomotives and steamboats, there are lots of regulations that grew a bit haphazardly in response to early incidents.

Most States in the US have regulations for pressure relief devices, however those regulations are all over the place in defining Process Safety Data requirements. Some are focused on Relief Device Inspection, Testing and Repair while others attempt to address other aspects of Pressure Relief System Process Safety Data. Some states hardly address Pressure Relief Systems, while others have provisions that focus on single applications in great detail. Some cities have their own rules independent of State rules.

The National Board of Boiler and Pressure Vessel Inspections has published a summary of the various US and Canada regulations. These regulations are inconsistent from jurisdiction to jurisdiction, are usually incomplete, and often are well out of date.

 Click here to review The National Board Synopsis

 While most jurisdictions address basics such as identifying ASME Section I and Section VIII Code (often an obsolete, dated version and not the current version), they generally address only a few of the things an owner should be doing to properly administrate the design, installation, operation and maintenance of Pressure Relief Systems. They can focus on the oddest aspects of relief systems and not address other critical requirements. This can result in organizations deciding they only have to comply with a few requirements, when really, they should be doing much more. 

The overall structure of a robust Pressure Relief System Process Safety Data program is illustrated in the figure below. Each of these items is described in the sections below.

 Pressure Relief System Definition

The first consideration in maintaining Process Safety Information is to have a definition of the scope of a Pressure Relief System. A single Pressure Relief System consists of one or more pressure relief devices, the equipment and piping that the Pressure Relief System protects, and any other relevant equipment such as block valves or supplemental devices. Some jurisdictions require this to be clearly documented but others do not specifically address this requirement.

The Process Safety Information for a Pressure Relief System should include material that clearly defines the scope and boundaries of each System. This may take the form of a sketch that shows all relevant equipment, piping and pressure relief devices or a list that contains the same information.

However, an issue with sketches or lists is that it can be difficult to verify that all equipment in a facility is adequately protected from over pressure. The sketches and lists can effectively document what is protected, but it is a much more difficult task to find what may have been left out. Ideally, a database that allows linking of Pressure Relief System definition to a complete equipment data base should be used. Query of this database can rapidly identify equipment that may not have over pressure protection.

Process Sizing Basis

When a Pressure Relief System is designed, a large number of potential Pressure Relief System sizing scenarios, usually based upon the descriptions contained in API RP-521, are evaluated by a Process Engineering group. The case that requires the largest pressure relieving device sizes is recorded as the sizing case. This is the process data that makes it to the pressure relief device data sheets. The full process analysis often then goes into a box that gets sent to the owner with all of the other design documentation. Often this box goes into long term storage somewhere and is seldom seen again.

Processing facilities are dynamic things, and modifications and improvements often affect the required pressure relief capacity. If the original Relief System sizing calculations are stored in an inaccessible box, every change requires a full re-evaluation of the Pressure Relief System from scratch. This is something that becomes prohibitive and the required evaluations often don’t get done, are highly inefficient, or are inconsistent with the initial evaluations.

Pressure Relief System sizing evaluations and calculations for all of the pressure relief causes should be retained in records that are readily available when the Pressure Relief System needs to be re-evaluated. These can take the form of paper records or scanned records stored digitally, but the key point is that a complete, progressive and up to date set of Pressure Relief System sizing evaluations and calculations needs to be kept in a format and location that allows for efficient recall, review and update.

Relief Device Specifications

The physical specifications for Pressure Relief Devices are typically contained on data sheets used to purchase the devices. These sheets contain physical requirements such as manufacturer, model number, materials of construction, body and process connection ratings, required relief area and the process conditions for the relief device sizing case. Often these data sheets are the only Pressure Relief Process Safety data that is readily available to a Site’s staff and are often erroneously considered to be full documentation.

What is often not appreciated, is that the information contained on a Pressure Relief Device data sheet is only a subset of the full information required to own and maintain the Pressure Relief Devices. These data sheets are used as tool for procurement and contain only the information needed to procure a specific device. They are an integral part of the Relief System Process Safety data, but only a small part. In addition to the Pressure Relief System evaluation records described above, a complete set of manufacturer’s manuals need to be available to identify key parts and dimension tolerances.

Relief Device Installation

The proper functioning of Pressure Relief Devices requires that they be properly installed, and the systems around them such as inlet and output piping, block valves and other support devices be properly designed. For example:

Section VIII spring opposed pressure relief valves have rather narrow requirements for the dynamic inlet losses (the 3% rule) and have similar requirements for both static and dynamic back pressures. Inlet and outlet block valves also have size and design restrictions, such as requirements that all block valves be at least full ported valves that do not restrict flow to the pressure relief device. There are also specific limitations of the static and dynamic piping loads that can be imposed upon pressure relief device bodies.

The Process Safety Data for a Pressure Relief System should include full installation specifications and support calculations. Support calculations should include inlet and output pressure losses and imposed back pressures and piping load calculations, including both relieving and non-relieving conditions. These calculations should be kept in a readily accessible format and locations similar to the requirements for Process Sizing evaluations and calculations.

Associated Relief System Equipment

The design of a pressure relief system dependent upon the capacity of other equipment requires that certain equipment be in service at all times the pressure relief system may have a demand placed upon it.  This equipment and other functions must be identified. Some examples are:

  • The capacity of process equipment such as fired heater duties, pump impeller sizes, etc.
  • Relief systems subject to fire cases require that the assumed vessel insulation is in place and of a design that can withstand external fire
  • HIPPS or other equipment installed to reduce the required relief load are in service
  • Block valve locks and required block valve positions

Pressure Relief System Procedures

Any Pressure Relief System Process Safety Data system includes the procedures required to safely operate the systems. This includes items such as:

  • Safe Operating Limits within which the Pressure Relief System is properly sized
  • Lock Lists and Lock/Car Seal status
  • Permissible line-ups for system with multiple relief devices and installed spares
  • Other operating restrictions required to safety operate the Pressure Relief System

Relief Device Inspection, Testing and Maintenance

Almost all jurisdictions require that Pressure Relief Devices be inspected, tested and repaired at regular intervals, and that the results of these activities be kept in a progressive record. The National Board of Boiler and Pressure Vessel Inspectors VR stamp program defines a set of minimum qualifications, procedures and documentation for the inspection, testing and repair of pressure relief devices. Some jurisdictions make it mandatory that any organization doing inspection, testing and repair of pressure relief devices hold a VR stamp. Other jurisdictions may have other requirements. In any event, a pressure relief system management program should include a robust device inspection, testing and repair program including complete documentation of all events associated with the Pressure Relief System and its devices.

Management of Change

All Pressure Relief Systems are subject to Management of Change procedures whenever modifications are made to process equipment or to the Relief System components. Often de-bottlenecking projects will increase equipment capacity, which then can impact the sizing criteria for the Pressure Relief Systems. Modifications to the pressure relief devices can also affect pressure relief system performance or affect the physical installation of the devices and their associated piping and equipment. Even apparently small changes such as modifying a pump impeller or vessel insulation can result in an improperly sized Pressure Relief System. Therefore, it is imperative that whenever a change is made to a process that its effect on Pressure Relief System design be fully evaluated and the required changes to the Pressure Relief System also be implemented and documented.

 

Rick Stanley has over 40 years’ experience in Process Control Systems and Process Safety Systems with 32 years spent at ARCO and BP in execution of major projects, corporate standards and plant operation and maintenance. Since retiring from BP in 2011, Rick formed his company, Tehama Control Systems Consulting Services, and has consulted with Mangan Software Solutions (MSS) on the development and use of MSS’s Safety Lifecycle Management software.

Rick has a BS in Chemical Engineering from the University of California, Santa Barbara and is a registered Professional Control Systems Engineer in California and Colorado. Rick has served as a member and chairman of both the API Subcommittee for Pressure Relieving Systems and the API Subcommittee on Instrumentation and Control Systems.

How Accurate Are Safety Calculations

How Accurate Are Safety Calculations

How accurate are safety calculations: If you have ever sat in a LOPA, inevitably there is someone that questions the accuracy of one factor or another. Usually they are trying to justify making an initiating cause less frequent or take more credit for an Independent Protection Layer (IPL).

As unsatisfying as it is, assessment of Process Safety Systems is a statistical adventure. And when you get down to it, people just don’t like, or understand statistics. They find it a playground in which to argue that their number is the “right” number. Statistics are real, but people don’t like to believe them. Otherwise casinos would not be in business.

Evaluation of protective function performance requirements and performance of the designs for those functions requires establishment of probabilities for things like how often an initiating event may occur and how effective mitigating functions are likely to be. Deciding what probabilities to use is the hard part. The problem when it comes to Process Safety Systems is that these probabilities are very fuzzy numbers. How accurate are safety calculations, unlike a pair of dice, which have very precisely defined odds of 7 or snake eyes coming up, real process related risk and failure data is less than precise.

The Process Safety Standards and Practices used by the Process Industries have developed over the past 20-30 years and the various factors used in Process Safety analysis have tended to converge on consensus values. The AIChE CCPS publication, Layers of Protection Analysis, provides a fairly complete set of values for LOPA related factors, and various publications on Safety Instrumented Systems provide representative failure rates for commonly used devices. In these instances, the publications note that the factors actually used are up to the User.

One of the things these publications generally state, is that absent any hard data supporting another value, all of the factors used should be no more accurate than a power of 10. So, factors used are values of 10, 100, 1000, or their inverse (10-1, 10-2, etc). Attempting to use any values that have more precision is usually an exercise in self-delusion. Even the factor of 10 practice is only an approximation. However, the recommend values in reputable publications are based upon the collective experience and judgement of some very experienced and pragmatic people. Unless you have lots of actual in-service data, you don’t really know anything better. Use the expert’s numbers.

When working with input data that only has a precision of powers of 10, you also have to be cognizant that the answer you get after stringing a bunch of them together in a Risk Reduction or PFD calculation, isn’t going to be any more precise than the input data. So that RRF calculation that tells you need a SIF with an RRF of 186 is giving you a false sense of precision. It’s not actually 186, it could be 100 or could be 1000.

This is why ISA 84 ed.2 and IEC 61511 only recognize Safety Integrity Levels (SIL) specified in decades – RRF’s 10, 100, and 1000.   When you are calculating a PFD of a SIF design, that 186 is often used as a hard requirement, when in reality it is a very, very fuzzy target. There is absolutely no basis to say that that a calculated SIF RRF of 130 doesn’t meet the requirements of a LOPA target RRF of 186. Given the accuracy of the input values used, 130 and 186 are the same number.

This doesn’t say that a practice of requiring a SIF design to meet a higher (but not precise) target is wrong.  It does give a design target and tends to result in more thought about the SIF designs. However, you shouldn’t fool yourself into thinking that you are being very precise. If it’s a major expense to get a SIF from 130 to 186, think about whether that really is making a difference.

 

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Slminfo
Rick Stanley has over 40 years’ experience in Process Control Systems and Process Safety Systems with 32 years spent at ARCO and BP in execution of major projects, corporate standards and plant operation and maintenance. Since retiring from BP in 2011, Rick formed his company, Tehama Control Systems Consulting Services, and has consulted with Mangan Software Solutions (MSS) on the development and use of MSS’s Safety Lifecycle Management software.

Rick has a BS in Chemical Engineering from the University of California, Santa Barbara and is a registered Professional Control Systems Engineer in California and Colorado. Rick has served as a member and chairman of both the API Subcommittee for Pressure Relieving Systems and the API Subcommittee on Instrumentation and Control Systems.

Assessing SIF and IPL Performance using SLM

Assessing SIF and IPL Performance using SLM

Assessing SIF and IPL Performance using SLM 84.01.00 and IEC 61511 Part 1, require that the performance of Safety Functions be assessed at regular intervals. The Operate-Maintain Module in Mangan Software Services’ SLM application can provide the user with real time performance data through availability and Probability of Failure on Demand (PFD) calculations performed on a daily basis. This eliminates the need to manually pull records periodically (or spend excessive time hunting, and perhaps not even finding them) and calculate performance.

Performance data is presented in reports Assessing SIF and IPL Performance using SLM displays at the Enterprise, Site, Unit and Function levels.

  • At the Enterprise Level, data is rolled up by Site
  • At the Site Level, data is rolled up by Unit
  • At the Unit Level, data is rolled up by the SIF or IPL Function

Why use Views and Reports?

 They allow users to easily monitor and identify trends such as unusually good or poor performance in a Unit or Site and bore down to the bad actors. The API Tier 3 Management View/Report provides a summary of Independent Protective Layer (IPL) performance by IPL type using values calculated from Events. Values such as Demand Rates, Failure Rates on Demand or Test, Overdue or upcoming tests, and the overall availability of SIF and IPL’s are presented. SLM also provides performance reports at each level for categories of Bad Actors (items with poor performance indicators), and the Top 5 Highest Risk SIF’s or HIPPS (functions with the worst performance indicators). All these reports are driven by the powerful SLM Event capture capability. Every Safety Instrumented System (SIS), SIF, IPL or Device contained in the SLM database may have many Events of various types recorded against it. For example, A SIF may have Demand, Bypass, Fault/Failure and Test Events recorded for it. A Device may have Test, Fault/Failure, Maintenance, Calibration and Demand Events recorded for it.

Event Entry

 Events are entered into SLM using a guided approach that simplifies the Event Entry Process. Events are usually entered at the Function or Test Group level and the User is guided to identify any Devices associated with the Event and whether or not a failure was associated with the Function or Device. Usually data for Events that did not involve a failure are automatically entered by the system to reduce repetitive data entry tasks. SLM is also capable of accepting data from a Process Historian to automatically generate Events such as Demands, Faults/Failures, and Bypasses. The system is designed to allow Users closest to an Event to record the Event.

 

For example:

  • Operators may be assigned Event entry responsibilities for Demand, Fault/Failure, and Bypass Events
  • A Maintenance Technician or Supervisor may be assigned Event Entry responsibilities for Testing and Maintenance Events
  • Engineering may handle other events such as Status changes or Test Deferrals

 

SLM allows the User to define whether an Event requires Approval before being used in performance calculations. For Event types that require Approval, the primary and secondary Approvers for each Event Type can be independently defined at the Site or Unit levels.

 

Each Event record has a check box which is used to identify if an Event that had a failure was a Safety Related Failure. For example: On a test of a SIF, a shutdown valve was found not to close when it was commanded to do so. When the Test data is entered into SLM, the test on the SIF would be identified as a failed test and the Device Event for the valve would also be identified as a failed test. Both Events would be identified as being Safety Related Failures.

All of this provides the user with a continually updated view of the performance of Safety Functions at whatever granularity the user needs. Event entry provides an efficient way to assure that performance information is captured at the source. The overall result is an unprecedented level of continuous, highly efficient Safety Lifecycle monitoring.

How to Manage Bypasses Using SLM

How to Manage Bypasses Using SLM

IEC 61511 Part 1, contains extensive discussions of the design and operating procedures for SIF bypasses. Clause 16.2 describes operational requirements such as:

  • Performing a hazard analysis prior to initiating a bypass
  • Having operational procedures in place for when a protective function has been bypassed
  • Logging of all bypasses.

How to Manage Bypasses Using SLM – through a robust Bypass management and logging function that meets all of the requirements of IEC-61511 and integrates with the performance analysis and reporting functions of the SLM Operate-Maintain (OM) Module. SLM OM Module uses the Bypass Authorization object and Work Flow to initiate, approve and record the execution of Protective Function Bypasses. SLM does not limit the use of Bypasses to just SIFs. In SLM, any protective function may have a Bypass Authorization associated with it.

Read more about the Benefits of Effective Bypass Management 

The figure below illustrates how the Work Flow supports the tasks required on how to manage bypasess using SLM:

A Bypass Authorization is initiated by any authorized SLM user. In practice this will usually be a member of the Operations Staff for a Unit, often a shift foreman or Operations Engineer. The originator is guided to enter the information required to support the Bypass Authorization. This includes:

  • Basic Bypass information such as the reason for the Bypass, the anticipated start date and time and the maximum time which the Protective Function is to be Bypassed
  • Hazard Assessment information – this includes an identification and assessment of the potential severity of hazards that may occur while the Protective Function is Bypassed and the corrective measures that should be taken if the hazard occurs
  • Operation Procedures that are required to be used to mitigate potential hazards that may occur while the Protective Function is Bypassed
  • Identification of the Devices associated with the Protective Function that will be Bypassed

Once this information is provided, the user then may submit the Bypass Authorization for Approval. The Bypass Authorization is submitted to the designated Approver, typically an Operations Supervisor of Manager. The Approver reviews the Bypass Authorization and either Approves or Disapproves the request.

Once the Bypass Authorization is Approved, the Operations team may execute the Bypass as planned. The originator or other authorized user may then record the start date and time of the Bypass in the Bypass Authorization. If a Bypass is expected to exceed the time requested in the original Bypass Authorization submittal, the user may request approval for a Bypass Extension by filling in the data in the Bypass extension section of the Bypass Authorization object. When approved, this will update the authorized Bypass time and prevent the Bypass from being reported as exceeding its authorized time.

When the Bypass is completed, the originator or other authorized user then enters the date and time when the Protective Function is returned to service and then close the Bypass Authorization. Closing of the Bypass Authorization results in the Bypass data being added to the SLM Events that are used to analyze Protective Function and Device performance.

SLM contains performance views that capture all Bypasses for a Function, Unit and Site. The analysis functions include reporting on the number of bypasses, time in bypass and identification of Bypass Events that exceeded the authorized bypass time. SLM will also compute the effect of Bypasses on a Protective Function’s in-service performance, such as computing the in-service reduction in the Functions’ RRF or PFD. Functions that have excessive Bypasses will also show up on the Unit and Site bad actors lists.

 

Rick Stanley has over 40 years’ experience in Process Control Systems and Process Safety Systems with 32 years spent at ARCO and BP in execution of major projects, corporate standards and plant operation and maintenance. Since retiring from BP in 2011, Rick formed his company, Tehama Control Systems Consulting Services, and has consulted with Mangan Software Solutions (MSS) on the development and use of MSS’s Safety Lifecycle Management software.

Rick has a BS in Chemical Engineering from the University of California, Santa Barbara and is a registered Professional Control Systems Engineer in California and Colorado. Rick has served as a member and chairman of both the API Subcommittee for Pressure Relieving Systems and the API Subcommittee on Instrumentation and Control Systems.

I Like Logic Diagrams

I Like Logic Diagrams

I like logic diagrams, although I’m often in the minority, to do the detailed design of a Safety Instrumented Function (SIF). Others believe that Cause and Effect (C&E) Diagrams are all that is needed. My view is that C&E’s are an effective overview tool when it comes to familiarizing people that aren’t part of the design team with a SIF’s function. However, when it comes to clearly and unambiguously defining how a SIF, or any other logic function works, I find the logic diagram to be the best tool.

C&E’s just are not very good in conveying stuff like timing or sequencing, rather they are quite confusing. C&E’s are good at saying if an input condition exists, this is the output condition. But more complex things such as timing, permissives and other things that usually exist can’t be readily defined in a C&E. Suddenly you are trying to figure out what Notes 6, 12, and 19 actually mean. Users programming from C&E’s, particularly for larger systems can easily make mistakes or misinterpret the intent. I find myself to be quite capable of misinterpreting all those notes.

I like logic diagrams because on the other hand, when done well, they are easy to interpret. The diagram symbols like those identified in a standard such as ISA 5.2 allow the user to clearly define almost everything you need. You can clearly and precisely cover set points, time delays, and complex relationships etc. Personally, I’ve used an amended version where input and outputs get more directly defined as power sources, dead bands for switches, whether the logic operates on an open or closed switch, or energizes or de-energizes a solenoid valve, etc.

Logic diagrams also can become a one to one road map for the Safety Instrumented System (SIS) programming. Most SIS programming languages have a function block option. This makes things a whole lot easier and saves a lot of time in programming, quality checking and field testing. It’s true that preparing a good logic diagram takes more time than putting together a C&E, but it’s my belief that you get your money back and then some just in simplicity and reduced errors. It’s simple to put a note on a C&E that someone might easily misunderstand, but in a logic diagram you have to sweat the details up front and not pass it on for a programmer to figure out (and everyone thereafter).

I think that logic diagrams are an investment. They take time to prepare yet start paying back at the time of programming. The real payout comes at the time of pre-startup validation. With well-reviewed logic diagrams, the potential errors in programming are pretty much beat out of the system by the time you get to checkout, loop testing, and validation. Well checked and tested systems can radically reduce startup time.

An example of what a logic diagram looks like:

A case study I cite is a process unit for which I was the lead control systems engineer. The process required over 100 distinct Interlock, sequence and SIFs as well as required over 400 logic diagrams to represent. We spent a ton of time developing the logic diagrams and a bunch more putting together test procedures and executing them.  We taught the Operators to read the logic diagrams, and during the first 6 months of operation, there was always one set or another open on a desk.

It took a lot of effort, and had real costs, when it was all said and done, we only had two logic glitches during startup (one of those was an unauthorized logic change made by a contract engineer at the last minute). The net result was that we were up and making on spec product in the first week of operation. The licensor’s startup engineers were amazed. Their feedback was that they always experienced that there would be 6 to 8 weeks of logic debugging before reliable production could be established. The extra 5 weeks of production paid for all of time we spent on logic diagrams and testing, many times over. That’s why I like logic diagrams.

 

 

Rick Stanley has over 40 years’ experience in Process Control Systems and Process Safety Systems with 32 years spent at ARCO and BP in execution of major projects, corporate standards and plant operation and maintenance. Since retiring from BP in 2011, Rick formed his company, Tehama Control Systems Consulting Services, and has consulted with Mangan Software Solutions (MSS) on the development and use of MSS’s Safety Lifecycle Management software.
Rick has a BS in Chemical Engineering from the University of California, Santa Barbara and is a registered Professional Control Systems Engineer in California and Colorado. Rick has served as a member and chairman of both the API Subcommittee for Pressure Relieving Systems and the API Subcommittee on Instrumentation and Control Systems.

Promoting a Sustainable Process Safety Culture

Promoting a Sustainable Process Safety Culture

Promoting a sustainable process safety culture can be difficult. The Chemical Safety Board just issued their report on the November 2014 incident at the DuPont La Porte plant in which 4 people were killed:

Click here to read the full report.

Summary of the Report 

The report reads like so many others highlighting some issues with promoting a sustainable process safety culture.  The root cause was said to have been the fact that site and corporate management failed to implement Process Safety Management Systems. Furthermore, the report also cites multiple failures in the overall management of Process Safety. The core failure in this incident was that the facility had a very poor Safety Culture as summarized in the excerpt from the CSB Report. The CSB Report devotes an entire section on how the Process Safety deficiencies in this incident parallel the findings in an earlier CSB report on the 2005 BP Texas City Refinery explosion, despite the site being aware of the report and its findings. ®

DuPont La Porte did not use any type of robust, formal process safety culture assessment. Process safety culture can affect whether a site has a sense of vulnerability in terms of process safety management risks; complacency or overconfidence; and transparent, timely, and thorough responses to PSM concerns, action items, and issues, including leadership measures to prevent a “check-the-box” mentality (i.e., simply accomplishing a task as the objective rather than ensuring a high degree of focus on risk management and prevention). The Safety Perception Surveys conducted at the DuPont La Porte facility before the November 2014 incident were designed to lower OSHA total recordable injury rates [59, p. 8]. DuPont did not intend for these surveys to measure or address the perception of process safety performance.

One of the issues with promoting a sustainable Process Safety culture is that it’s hard without the right tools:

  • The tools that an organization typically has to manage day to day operations don’t fit the needs of Process Safety Management.
  • The tools that do exist are typically single purpose and result in isolation of data and limited availability across organizational boundaries.

It’s extremely easy for individuals to become disconnected as they often are not involved in day to day management of Process Safety and it becomes the perception that it’s taken care of by others. Add a management attitude such as existed at La Porte where there was a misplaced emphasis on measuring personnel safety with no corresponding concern for Process Safety and establishment of a sustainable Process Safety culture becomes impossible.

An effective Process Safety Program needs to make Process Safety information widely available to all employees involved in design, operation, and maintenance of the processes in order to keep them all involved on a daily basis. When a site is using the tools traditionally available for plant operations, information becomes isolated from personnel and is difficult to access. 

Safety Lifecycle Manager (SLM®)                                   

The SLM® application was developed to address the many shortcomings relative to Process Safety that exist in many plants today. The origins of the application were a direct result of the CSB and Baker Panel findings relative to the BP Texas City Refinery explosion.

The objectives of the development of SLM were:

  • Unify Process Safety data in one location so it is accessible to all personnel that need it. This includes PHA, LOPA, IPLs, Plant Assets that perform the functions required by IPLs or other functions, and Field Devices that are used to implement the functions and performance records for Plant Assets and Devices.
  • Provide the tools to perform PHA and LOPA studies within the SLM application.
  • Link Plant Assets to PHA, LOPA, and IPL data so the Process Safety requirements such as LOPA IPLs or PHA Safeguards that resulted in the Plant Assets being installed can be directly accessed from Plant Assets and vice-versa. This provides a very clear linkage between real functions and devices in the plant to the Process Safety reasons that they exist. This addresses the very real issue of IPLs not being clearly identified by LOPA Teams, or multiple LOPA teams identifying multiple IPLs that correspond to the same Plant Asset. The figure below illustrates these relationships.

  • Provide engineering tools that support design of safety instrumented systems (SIS) and safety instrumented functions (SIF) and maximize consistency of design. This includes tools to rapidly develop Safety Requirements Specifications (SRS) and evaluate SIF Probability of Failure upon Demand (PFD). Functional requirements for Safety Related Devices are clearly defined as are testing requirements and any operational requirements.
  • Provide the ability to define functional requirements for other non-SIF Protective Functions and Safeguards and their field Devices including alarms, interlocks, BPCS functions and non-instrumented protective functions.
  • Provide the ability to upload or link key documents directly with Process Safety related Assets. These may be operation and testing procedures or other documents or drawings.
  • Provide a complete Life Cycle management capability that allows for management of Protective Functions during operation and maintenance after initial design and installation. Events associated with the operation of Safety Related Plant Assets such as Demands, Testing, Bypasses and Failures may be recorded using simplified and consistent Work Flows. The figure below illustrates the relationship of Events to Plant Assets and Devices.

  • Provide a real time view of the performance of Protective Functions and their field Devices based upon the Event data contained in the database. Various Key Performance Indicators (KPI) allow the plant to understand the current state of performance and manage periodic testing and identify bad actors for which corrective action is required. Examples of various KPI’s are shown below.

How SLM® can help when promoting a sustainable Process Safety Culture

  • Instead of separation of various aspects of Process Safety, they are integrated in one web-based application that makes Process Safety information available to all personnel who have Process Safety interests.
  • SLM® allows personnel with Process Safety responsibilities to participate in Process Safety Management on a routine basis. Furthermore, personnel that are closest to various Events may be assigned responsibility to record those Events.

For example:

Operations personnel are responsible for entering Events for operational related items such as Demands, Bypasses, and Failures while maintenance personnel are responsible for monitoring testing that is approaching its due date as well as entering the results of testing and any other maintenance Events. This keeps personnel involved in the day to day management of Process Safety related Assets.

Rick Stanley has over 40 years’ experience in Process Control Systems and Process Safety Systems with 32 years spent at ARCO and BP in execution of major projects, corporate standards and plant operation and maintenance. Since retiring from BP in 2011, Rick formed his company, Tehama Control Systems Consulting Services, and has consulted with Mangan Software Solutions (MSS) on the development and use of MSS’s Safety Lifecycle Management software.

Rick has a BS in Chemical Engineering from the University of California, Santa Barbara and is a registered Professional Control Systems Engineer in California and Colorado. Rick has served as a member and chairman of both the API Subcommittee for Pressure Relieving Systems and the API Subcommittee on Instrumentation and Control Systems.