Torus Risk Engineering

Best Practice Centre

SAFE ISOLATION OF PLANT AND EQUIPMENT

Petrochemical Plant Incident

During a routine maintenance operation to unblock a settler on a HDPE reactor loop the reactor contents of 39 tonnes of iC4 and ethylene were released. The ensuing VCE killed 23 people and injured 124, destroying two HDPE plants. The accident investigation found that the 8 inch ball valve, used to isolate the reactor, was in the open position with the actuator air hoses connected. Procedures called for this valve to be closed with a disabling pin inserted and the air hoses disconnected. Employees stated that this had been done two days prior to the incident. Piper Alpha, 1988 and Cactus 1996 were also initiated by failures in isolation.

BEST PRACTICE ADVICE

All isolations under the PTW procedure should be controlled by a Safe Isolation procedure which requires the lock out of the isolation and tag out to identify the isolation: LOTO. The LOTO procedure should incorporate minimum isolation requirements for standard jobs and specify risk assessment methods for unusual work. Generally, working on a pump seal would require single valve isolation, as inserting a spade would usually involve more intrusive work than the seal repair itself. However, removing the pump to the workshop involves disturbing the pipework and so positive isolation with a blank flange reduces the risk. For a small number of isolations, these can be listed on the PTW form, but a more complex situation will require a separate Isolation Certificate. This should have a schematic/P&ID which shows the location of all the isolations and an insertion-removal list to control the isolation and re-instatement. Each isolation valve should be locked using a chain or wire cable and padlock. The valve should be tagged, cross referencing the Isolation Certificate/PTW and the key kept in a lock box, which is usually in the control room or permit office. The lock box is closed with a multi-lock, which is first locked with the operators padlock and then each tradesman will apply his padlock whilst working on the job. At the end of the job, only the operators lock will remain until approval is given for reinstatement. For pneumatic isolation valves the air supply should be disconnected and the valve locked/secured closed. Motor actuated valves should have their supply isolated and the valve locked/secured closed.

Background
Investigations into industrial accidents show that the loss of containment due to improper isolation, as part of maintenance intervention, is a major contributory factor in these accidents, and is a key feature in the escalation of the incident into a major fire or explosion. All installations handling hazardous materials should have procedures to ensure safe isolation during intervention activities.

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SAFE ISOLATION OF PLANT AND EQUIPMENT

BEST PRACTICE ADVICE Continued

Electrical isolation is usually a separate procedure, due to local legal requirements and specialist technical requirements. The requirement is for a lock and tag on the local start button, as part of the operations LOTO, and the key goes in the lock box. The electrical department isolate the switchgear at the MCC with a lock and tag, or withdrawing the switch/fuse. The electrical isolation permit and LOTO cross reference with the PTW and operations LOTO. The use of strong cable ties, in place of chains and padlocks is acceptable with a strongly enforced, detailed procedure. However, this does not have the built in security of the lock box, which minimises the potential for errors.

References
HSG253 The Safe Isolation of Plant and Equipment, Health and Safety Executive, U.K., 2006. HSG250 Guidance on Permit-to-Work Systems, Health and Safety Executive, U.K., 2005. OSHA Directive The Control of Hazardous Energy (Lockout/Tagout),CPL 02-00-147, 2008 and standard Title 29 Code of Federal Regulations (CFR) Part 1910.147

Contact us
For further information please contact our Engineering Practice Leader for Onshore Oil & Gas Peter Wong +1 (832) 314 2810 pwong@torusinsurance.com

Summary
The LOTO procedure is a key part of ensuring the plant integrity and safe isolation of plant and equipment. It has a major role to play in a good PSM system. Torus RQR Guidelines Onshore Energy Section 4.4.3 PSM

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