OTC 23685

Developing Process Safety Capabilities in New Engineering Graduates

B.K. Kim, R.A. Mentzer, and M.S. Mannan, Mary Kay O'Connor Process Safety Center, Artie McFerrin
Department of Chemical Engineering, Texas A&M University

Copyright 2012, Offshore Technology Conference

This paper was prepared for presentation at the Offshore Technology Conference held in Houston, Texas, USA, 30 April–3 May 2012.

This paper was selected for presentation by an OTC program committee following review of information contained in an abstract submitted by the author(s). Contents of the paper have not been
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Abstract

Various major oil & gas incidents are constant reminders of the importance and distinction between personnel and process
safety. While the North Sea Piper Alpha disaster had a serious impact on both onshore and offshore operations, the more
recent US Gulf of Mexico Deepwater Horizon incident has resulted in new regulatory requirements. The new Safety &
Environmental Management System (SEMS) regulatory requirement emphasizes both process and personnel safety aspects in
Outer Continental Shelf (OCS) oil and gas operations. While primarily a voluntary requirement since the mid-90’s, effective
November 2011, it has become mandatory. Consistent with industry’s focus on process safety, training in process safety is
now a mandatory requirement in Chemical Engineering curricula starting in 2012. Academia has a significant role in
improving process safety and personnel safety by proving training and education for new engineering graduates, as well as
the current workforce. In addition, advanced research programs can help close current gaps in the understanding of process
safety and ultimately improving safety performance of the OCS oil and gas operations. Such studies include safety culture,
fires & explosions, facility layout optimization, inherently safer design, and pipeline corrosion, to name just a few areas.

1. Introduction

Process safety has become one of the inevitable elements in keeping businesses in various industries sustainable.
Various industries have suffered painful lessons from incidents and have taken steps to prevent similar tragedies from
reoccurring. The Bhopal incident in 1984, which caused +2,000 fatalities, and the more recent Deepwater Horizon incident,
are a few examples which show the catastrophic impact of process safety related incidents. Although eliminating risk entirely
is not feasible, recent progress in process safety has improved safety performance through recognizing the risk and
implementing safety measures to prevent or mitigate catastrophic consequences. This paper describes the implementation of
process safety in the offshore oil & gas industry, the new regulatory requirements, and discusses the training of engineers and
research to promote safer operations.

2. Process Safety in Offshore Oil & Gas Industry

2.1 Development of Process Safety

The worst chemical disaster, the Bhopal MIC release in 1984, triggered new comprehensive regulations in the US
chemical industry [1]. Prior to the Bhopal incident, a systematic approach to understand the phenomena regarding process
safety had not been well established, but rather, case studies were conducted for each incident. Following the Bhopal
incident, the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 was passed by the US Congress.
This Act promotes emergency planning for potential chemical accidents and provides communities with proper information
on potential hazards imposed by the chemical processes [2].
2 OTC 23685

After a series of explosions and fires such as at the Phillip’s plant in Pasadena, Texas, in 1989, which took 23 lives,
the Occupational Safety & Health Administration (OSHA) proposed a new standard, ‘Process Safety Management of Highly
Hazardous Chemicals’ which became effective in 1992 [3]. OSHA’s Process Safety Management (PSM) focuses on
preventing release of any chemical substance which is categorized as highly hazardous. The United States Environmental
Protection Agency (EPA) also requires that facilities that operate using highly hazardous chemicals to comply with the Risk
Management Program (RMP) regulation, which addresses hazard assessment, prevention, and the emergency response
program [4]. The information are to be submitted to government agencies, emergency response and planning committees and
are communicated to the communities. While PSM ensures the protection and safety of the employees from exposure to the
risk within the plant boundary, RMP evaluates potential hazards the facility may impose to nearby communities by
considering the worst-case scenarios [5].

Two different approaches, which provide fundamentally different criteria for risk, can be implemented when
developing the requirements for regulating process safety related elements [10]. Performance-based regulations specify a
desired risk level as a goal. The Safety Case from the UK follows the performance-based criteria. The operators must prove
that the operating design and procedures meet the goal with detailed explanation and quantified risk assessments. Although
performance-based regulations require more effort in evaluating compliance, it can provide more flexible approaches in
accommodating the latest technologies under various operating conditions. Prescriptive-based regulations, on the other hand,
provide detailed requirements based on certain engineering best practices. The new Safety & Environmental Management
System (SEMS) requirement for OCS oil and gas operations in the US is a prescriptive-based regulation. The prescriptive-
based regulation provides a better approach for routine operations which have been analyzed and proven to be safe based on
experience. Checking for compliance for the prescriptive-based regulation is more straightforward compared to the
performance-based criteria, as detailed generally numerical requirements have already been set. However, prescriptive-based
regulation provides less flexibility for varying operating situations and new technologies.

2.2 Offshore Process Safety

Recent incident rates of US offshore oil and gas operations show a decreasing trend throughout the year, as depicted
in Figure 1. The personnel safety record of the offshore E&P industry show a significantly lower incident rate compared to
the overall private industry. Due to the unique condition of operating remotely and being exposed to harsh environments, the
offshore activities are constantly exposed to various internal and external hazards. Some of the common incident types are
fire and explosion, collision, oil or gas release, and loss of well control.

Figure 1. Total lost workday and offshore incident data [6, 7]

Fire and explosion result from equipment failure or human error which release hydrocarbons to the platform and
ignite. Collisions occur mainly due to human error where a vessel strikes the structure of the platform Collisions may lead to
personnel injuries to the employees or damage to the platform. The loss of well control occurs when the well fluids are not
controlled as designed. Some of the common underlying causes of these types of incidents are inadequate risk assessment,
operating procedures, permit-to-work, supervision, communication, and failure of safety management system (SMS), and
equipment.
OTC 23685 3

Figure 2. Piper Alpha incident and Deepwater Horizon incident [8, 9]

Figure 2 shows pictures of two of the most significant offshore incidents, the Piper Alpha incident in 1988 and the
Deepwater Horizon incident in 2010, which occurred over two decades apart in different parts of the world. Some concerns
were raised over the blowout preventer (BOP) from the recent Deepwater Horizon incident. The BOP, which is designed to
be the last line of defense in case of a well blowout, is the primary layer of protection to prevent uncontrolled flow emanating
from the well during drilling. Having a single-point failure design, the BOP did not serve according to the originally intended
purpose during the Deepwater Horizon accident. Multiple layers of protection and inspection based on various elements, such
as the risk and operating performance, and circumstances can reduce the likelihood of an undesired event from occurring.

A multidisciplinary approach in evaluating the likelihood and consequence of various risks is needed due to the
harsh environmental exposure, as well as drilling of deep high pressure wells. With the development of advanced
computational fluid dynamics (CFD), the risk assessment and consequence analysis can now model and plan for unforeseen
events during the drilling and operation stage.

2.3 Safety & Environmental Management Systems for Offshore Operations

No mandatory regulatory requirements for evaluating the hazards in production of outer continental shelf (OCS)
operations in US territory have been in place until recently. The explosion followed by the fire which occurred at the Piper
Alpha platform in 1989 in the North Sea is recorded as the worst offshore oil disaster in terms of lives and industry losses. A
total of 167 fatalities resulted from the total destruction of the offshore platform which the operation accounted for
approximately 10 % of total oil and gas production in the North Sea at the time of the incident. The Mineral Management
Service (MMS), which is now known as the Bureau of Ocean Energy Management, Regulation and Enforcement
(BOEMRE), requested that the American Petroleum Institute develop a voluntary program for operations in the OCS. API
RP 75 (Recommended Practice for Development of a Safety and Environmental Management Program for Offshore
Operations and Facilities) was developed in 1994 as a response to OSHA PSM, which contains 13 elements. After acquiring
the necessary information to improve and implement the regulatory system for OCS operations in 2006, four main elements
for developing an integrated management system were proposed in 2009; hazards analysis, management of change, operating
procedures, and mechanical integrity. Finally, the final rule for 30 CFR 250 Subpart S (Safety and Environmental
Management Systems) was released in October 2010, making 13 elements of RP 75 mandatory and required to be
implemented by November 2011.

SEMS provides a regulatory approach to replace the earlier voluntary initiative of safety management systems by
imposing the same requirements for all OCS operators. SEMS applies to all the fixed and floating facilities, mobile offshore
drilling units, and pipelines. All the operational activities from drilling, completion, workover, servicing of wells to the
production, construction, and maintenance activities are covered. The 13 elements of SEMS are shown below in Figure 3
categorized in terms of planning, organizing, implementing and evaluating.
4 OTC 23685

Figure 3. 13 elements of SEMS

During 2011 companies evaluated their existing systems to ensure their safety management system is in compliance
with the new regulatory standard. Regardless of the size of operation, updating the P&IDs and making sure the management
of change (MOC) program is well-established should be top priorities [10]. These two elements are keys to the other
elements and closely relevant for everyday operations. The four elements identified by BOEMRE as ones that mostly
contributed to previous incidents, mechanical integrity, operating procedures, hazard analysis, and MOC, could be set as the
starting point of implementation of SEMS. Also, to ensure employees are familiar with the new regulatory standards, proper
training should be conducted and must make certain a proper recordkeeping system is in place for process audits.

3. Academic Role in Process Safety

3.1 Process Safety in Chemical Engineering Education

Another significant incident was that at T2 Laboratory Inc. in 2007, which resulted in 4 fatalities and 32 injuries
from runaway reaction from gasoline additive production. Following the tragic incident the US Chemical Safety Board
(CSB) made recommendations to the American Institute of Chemical Engineers (AICHE) and Accreditation Board for
Engineering and Technology (ABET), Inc. to work together and develop hazard awareness training, associated with the
processes covered in chemical engineering, as a part of the curricula requirement to the baccalaureate chemical engineering
program [11]. ABET accredits the academic curriculum of applied sciences, computing, engineering, and technology to meet
the quality criteria set by the professions and is recognized by the Council for Higher Education Accreditation in US.
Effective with the 2012-2013 academic year, ABET is requiring accredited chemical engineering programs to include
training to provide graduates with knowledge of recognizing the hazards of the processes covered in curriculum objectives.
The new curriculum from ABET for chemical, biochemical, and biomolecular engineering programs is provided as follows
[12]:

“The curriculum must provide a thorough grounding in the basic sciences including chemistry, physics, and biology, with
some content at an advanced level, as appropriate to the objectives of the program. The curriculum must include the
engineering application of these basic sciences to the design, analysis, and control of chemical, physical, and/or biological
processes, including the hazards associated with these processes.”

Since 2002, the core curriculum in Chemical Engineering at Texas A&M University has included a Chemical
Process Safety course, which is mandatory for all graduating seniors. Approximately 1,300 undergraduate students have
taken Chemical Process Safety course since the course was provided in 1995. The objective of the course is mainly to
identify potential hazards and conditions associated with various interactions which can be found in the chemical process
OTC 23685 5

industries. Various methods to evaluate, control, and mitigate the potential hazards are addressed for the processes covered
under the chemical engineering curriculum. The students use engineering fundamentals to understand and predict the
potential hazards using quantitative engineering analysis or various Process Hazards Analysis (PHA) methodologies. The text
‘Chemical Process Safety’ by Crowl and Louvar is used in teaching the course, supplemented by Chemical Safety Board
incident videos, and other materials [5]. The government agencies, regulatory bodies, codes, standards and concepts of
managing risk are covered using various materials, including the latest incident investigations and findings from different
government agencies. The knowledge and techniques for fire and explosion protection, reactive chemical hazard,
toxic/flammable gas release modeling, and designing proper relief system which are currently applied in the industry are
taught throughout the course. The concept of applying inherently safer design to lower the risk of processes is covered.
Ethics, standards, and professional codes of conduct for engineers required for sound engineering decision making is
emphasized for professional engineering practice.

The Mary Kay O’Connor Process Safety Center (MKOPSC) and the Department of Chemical Engineering at Texas
A&M University work together to continuously improve the process safety curriculum. MKOPSC was established in 1995 in
memory of Mary Kay O’Connor who was a victim of the refinery explosion on October 23rd, 1989 in Pasadena, TX. With
extensive experience in hazards analysis, risk assessment, LNG, fire/explosion studies, reactive chemicals, emergency
response and contingency planning, and fire protection, MKOPSC provides comprehensive training with the goal to educate
engineers to minimize losses within the process industry. Over 200 different courses on process safety have been provided
over time by distance learning or tailored to a specific topic to company needs to train personnel in the industry. A Safety
Certificate is available to all engineering disciplines, as well as practicing engineers, and focuses on the interdisciplinary
nature of safety, health, and environmental engineering. Those who finish the required five course curriculum, which covers
a wide variety of engineering disciplines, are certified by the Dean of the Department of Engineering at Texas A&M
University. Students are exposed to the knowledge, skills, and fundamental principles required by the current industry. More
than 140 undergraduate students have graduated with a Safety Certificate since the establishment in 2003. Students with such
certificates are highly sought after by industry.

The Annual International Process Safety Symposium organized by MKOPSC provides an opportunity for industry,
academia, government agencies and other stakeholders to come together to discuss current issues in process safety.
Organized every fall since 1998 in College Station, Texas, the Mary Kay O’Connor Process Safety International Symposium
has drawn record attendance every year, reaching more than 500 participants from industry and academia. Nearly 100
presentations were shared on various process related topics, including safety culture, incident analysis, process management,
and consequence analysis by participants throughout the industries and academia in the 2011 symposium.

3.2 Advanced Research in Offshore Process Safety

Major industrial incidents serve as reminders of the critical importance of process safety. Various wakeup calls
were Bhopal MIC release, Piper Alpha, BP TX City, Deepwater Horizon, and several others. Following each major incident,
there was renewed attention to the importance of process safety, as well as additional regulatory oversight. Of course our
focus here is on offshore safety. By integrating process safety fundamentals into offshore operations, the safety performance
throughout the offshore industry can be improved. The consequence of undesired events can be mitigated by identifying the
vulnerabilities in the system and implementing redundant safety measures and engineering solutions in the design,
construction and operating stages.

MKOPSC runs an extensive advanced research program to improve process safety performance. With new and
emerging areas within engineering process safety, the research provides the industry with science based recommendations
and best practices to better implement enhanced technologies throughout industry. Some of the main research areas
MKOPSC focuses on include safety culture, hazard and risk analysis, facility siting and layout, quantitative risk assessment,
human error, natural gas and liquefied natural gas hazards, explosion and aerosol characterization studies, advanced
computational fluid dynamics applications, corrosion in pipelines, layers of protection analysis, resilience engineering, and
incident database analysis. Let us now provide further details on a few of these areas.
6 OTC 23685

Congestion and space issues on offshore platforms are well known, and an area of research within the MKOPSC.
Computational modeling is applied to optimize the layout of an offshore platform, as shown in Figure 4(a). The results are
validated using consequence analysis models with advanced computational fluid dynamics as shown in Figure 4(b), showing
overpressure calculations at a plant site. Some of the risks and aspects considered in offshore modeling are explosions & fire
and tight spacing, complicated by the multiple levels of the structure and need for appropriate escape routes. The risk
assessment principles are based on accepted standards and practices. The optimal layouts are demonstrated using
computational fluid dynamics for the effectiveness and robustness.

Figure 4. Facility siting and layout optimization using computational codes (a) and simulation (b)

Gas release and liquefied natural gas (LNG) research at MKOPSC is a comprehensive research program, including
experimental work as well as theoretical modeling. This work provides in-depth understanding of natural gas and LNG
hazards, fire mitigation, and flammable cloud suppression. MKOPSC has been involved in experimental work at the Brayton
Fire Training Field (BFTF) in College Station, TX, with support from BP Global Gas SPU, and collaboration with Texas
A&M University at Qatar (TAMUQ) since 2005. Figure 5(a) shows a medium size LNG spill experiment (30 ft x 30 ft x 4ft)
being conducted at BFTF. Various methodologies were tested to effectively detect and quantify gas leak or spills and
advanced computational fluid dynamics has been applied to model gas dispersion in various leak and spill scenarios.
Mitigation measures, such as a water curtain, water deluge, and expansion foam were tested to find the effectiveness in
mitigating the hazards. Figure 5(b) shows simulation results of the effects of passive barriers such as a dike, and active
barriers such as a water curtain on a LNG vapor cloud. The two figures show the impact of a dike and water curtain,
respectively, on vapor dispersion and methane concentrations prior to ignition. Theoretical modeling provides a better
understanding on how to design effective suppression systems.

Figure 5. Outdoor LNG pool fire experiment at BFTF (a) and numerical modeling (b) for gas hazards research

Corrosion is a well-known issue across many industries and operating environments. Corrosion detection research
within MKOPSC aims to examine new non-destructive methodologies for detecting corrosion under insulation, a common
constraint for industry preventative maintenance programs. Various existing technologies are being tested for application in
detecting the pipe corrosion for the oil and gas industries. X-ray computed tomography has been shown to successfully detect
holes in pipe under insulation, as shown in Figure 6(a). Additional numerical research is underway to relate pipe erosion and
corrosion to such hydrodynamic factors as turbulent kinetic energy and wall shear stress. Numerical simulations have been
applied for various pipe shapes using the FLUENT simulator. Figure 6(b) shows the prediction of potential corrosion profiles
for different pipeline configurations, while erosion/corrosion data are plotted to model the most severe points in Figure 6(c).
OTC 23685 7

Figure 6. Corrosion detection (a) and numerical prediction for various pipe shapes (b, c)

Various experimental setups are used at MKOPSC to characterize explosion, combustion, and aerosols, common
areas of process safety research for over a decade within MKOPSC. Different sizes of explosion vessels are tested and
modeled with various chemical compositions to find normalized factors in predicting overpressures. The explosion studies
are conducted with collaboration with the University of Bergen in Norway and various industrial sponsors. Figure 7(a) shows
the experimental vessel used for dust explosions, while a plot to characterize the overpressure and determine the deflagration
index is shown in Figure 7(b). Different flame inhibitors are studied to find effective chemicals to comply with new
environmental regulations. The equipment setup to capture the initial flame interaction with different inhibitors is shown in
Figure 8(a) and the results of the propagating flame for a given inhibitor are shown in Figure 8(b). The results of different
flame propagation are compared to evaluate the effectiveness of various inhibitors in controlling the flame. The aerosol
characterization studies gather data at various states of hydrocarbons to develop and validate numerical modeling to find
universal understanding of aerosol characteristics. Figure 9(a) shows the experimental setup for an aerosol study and pictures
of the aerosol flame propagation. The results shown in Figure 9(b) of temperature vs. time are used to calculate the flame
speed and to define systematic terms and risk criteria associated with aerosol hazards in the oil and gas industry.

Figure 7. Experimental setup for dust explosion (a) and results (b)

Figure 8. Experimental setup for flame inhibitor (a) and flame propagation results (b)
8 OTC 23685

Figure 9. Experimental setup for aerosol study (a) and results (b)

As noted, we have chosen to highlight just a few of the many on-going process safety related research projects
within MKOPSC. Additional details of these and other projects can be provided upon request.

4. Conclusion

The offshore industry is now challenged to improve safety performance in OCS operations with the new SEMS
regulatory standard. Whereas none of the elements are new to current OCS operations, the requirements are now mandatory
for all offshore operations.

With an increase in the level of OCS regulatory requirements and the expected safety performance, academia is
playing an important role in improving both process safety and personnel safety. Academia can provide training and
education to new engineers, as well as the current workforce. With the new ABET requirements hazard identification of the
processes covered in the chemical engineering program must be included in the curriculum. The new engineering students
will have an opportunity to be exposed to the knowledge and skills to meet industry’s needs in safety engineering. Also, for
the current workforce, the continuing education and distance learning programs provide knowledge and skills on various
techniques or methodologies to enhance process safety. Finally, advanced research programs can provide better
understanding of various facets of process safety and can address a broad scope of techniques and technologies to improve
the safety performance of OCS operations.

Reference

1. Mannan, S., Lees' Loss Prevention in the Process Industries: hazard identification, assessment, and control. 3rd
ed. (2005) Amsterdam; Boston: Elsevier.
2. U.S. Environmental Protection Agency (EPA), Summary of the Emergency Planning & Community Right-to-
know Act, http://www.epa.gov/
3. U.S. Occupational Safety and Health Administration (OSHA), Process Safety Management,
http://www.osha.gov/
4. U.S. Environmental Protection Agency (EPA), Risk Management Plan (RMP) Rule, http://www.epa.gov/
5. Crowl, D.A., Louvar, J. F., Chemical process safety: fundamentals with applications 3rd ed. (2011) Upper
Saddle River, NJ Prentice Hall.
6. U.S. Bureau of Labor, Injuries, Illnesses, and Fatalities, www.bls.gov/iif
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9. http://fuelfix.com/blog/2012/01/03/bp-seeks-recovery-of-all-spill-damages-from-halliburton/
10. Sutton, I., Offshore Safety Management, Implementing a SEMS Program, Waltham, MA: William Andrew
(2012)
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Runaway Reaction (Four Killed, 32 Injured), (2009) Report No. 2008-3-I-FL
12. Accreditation Board for Engineering and Technology (ABET), Program Criteria for Chemical, Biochemical,
Biomolecular, and Similarly Named Engineering Prgrams, http://www.abet.org