IPTC-19575-Abstract

Process Safety in Contaminated Groundwater Treatment Plants

Paolo Cherubin, Lucia Presotto, and Luca Frattini, EniProgetti SpA

Copyright 2020, International Petroleum Technology Conference

This paper was prepared for presentation at the International Petroleum Technology Conference held in Dhahran, Saudi Arabia, 13 – 15 January 2020.

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Abstract
In many Countries legislation forces Oil&Gas Companies to implement a Process Safety Management
System (PSMS) to prevent and mitigate major accidents associated to the release of energy or hazardous
substances. In plants where activities may have lower process risks, such as contaminated groundwater
treatment plants, the implementation of a PSMS usually is not mandatory. This paper outlines how also
these plants could benefit from a Process SafetySafety framework.
A PSMS can be developed in line with the framework of an internationally recognized organization
(CPPS, Energy Institute, IOGP, OSHA) to be applied to activities with significant HSE risks while it may
be considered as an internal standard for low-risk activities. The effectiveness of the PSMS adopted and
its correct and complete implementation in accordance with the selected framework may be evaluated by a
dedicated audit protocol. The typical findings from audits carried out on reference upstream and downstream
installations as well as on some low-risk plants were collected and performance compared in order to identify
peculiarities in terms of good practices and recurrent areas for improvement.
The main results of the benchmark are presented in this paper. The results confirm that the effectiveness
of a PSMS is strictly linked with the level of risks in the activities and how such risks are managed both
in administrative and operating processes. A robust risk-based approach in all processes, fostered by a
visible commitments of top management, is the successful key for enhancing the Process Safety culture
of personnel and ensuring safe performances and business continuity in operations, irrespective of the risk
level in activities.
The paper also provides a roadmap for implementing a PSMS in contaminated groundwater treatment
plants, tailoring the Process Safety framework to the specific operative needs and risks.

Introduction
As a consequence of some catastrophic events occurred in the past, many Oil&Gas Companies turned
a greater attention to the prevention and mitigation of major accidents associated to their operations. In
many Countries Companies are now required by the legislation to implement a Process Safety Management
System (PSMS) aimed at assessing all risks for people, the environment, surrounding communities and
assets due to the loss of containment of hazardous substances or the release of energy from their installations.
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The final objective is demonstrating that all suitable measures were identified and put in place for assuring
the integrity of the operations.
While organizations in the energy industry (upstream, downstream and hydrocarbon transport) are
commonly considered as having a significant process risk, so that a PSMS is required on a regulatory level,
there are other organizations closely related to the energy domain, such as those dealing with environmental
remediation whose activities pose lower process risks.
For these organizations the implementation of a PSMS generally is not mandatory but may be proposed
as an internal desirable standard.
In the context of sites with a long history of Oil & Gas operations, environmental remediation plants are
frequently set up to process contaminated underground waters by means of chemical and phisical processes
to knock out the concentration of polluttants such as: hydrocarbons, organic and chlorinated substances,
heavy metals.
The output is processed water which is then returned back to the environment.
The amount of hazardous substances treated and chemicals utilized in these processes are limited
compared to those of a typical Oil & Gas plant therefore a major incident impacting multiple people or
causing major asset damages normally is not conceivable while the risk to impact single operators instead
is still possible.
A loss of containment of these process stream may instead generate a significant impact on the
environment as well as in terms of regulatory compliance and stakeholders’ relations.
Furthermore, in case of operations carried out within the boundaries of a live Oil & Gas site, operators
and assets are often exposed to major accident risks imposed by the adjacent producing plants.
The abovementioned considerations suggest that the implementation of a PSMS can be beneficial
alsofor oranizations managing environmental remediation plants in order to achieve a comprehensive risk
management approach and operational efficiency at the same time.
This paper presents the writer experience in the management of Process Safety topics in contaminated
groundwater treatment plants and outlines some key aspects to succesfully implement a PSMS tailored to
this context.

Process Safety Management Framework

A PSMS may be developed conforming to one of the frameworks suggested by internationally recognized
organizations like: CPPS, Energy Institute, IOGP, OSHA. Such frameworks are intended to be applicable
to any Company irrespective of the nature of the organization’s activities so that the level of PSMS
implementation may be commisurated to the scope and complexity of their operations.
The PSM framework considered in this paper consists of 20 elements structured into four main pillars
(Process Safety Leadership & Commitment, Hazard Identification and Risk Assessment, Risk Management,
Accident Management and Management System Verification), as reported in the following Table:
IPTC-19575-Abstract 3

Table 1—Process Safety Management Framework

The PSM framework sets out the basic requirements to assure a correct asset management through
adequate management practices together with organizational and technical methodologies typical of
different areas (design, construction, production, maintenance, HSE, etc) in each stage of the asset’s life
cycle.
The PSM framework is designed to be integrated with existing Health, Safety and Environment (HSE)
management systems implemented in the organization.
As part of a PSMS implementation, the organisation is required to adopt an audit protocol to evaluatethe
effectiveness of the PSMS adoption and its correct and complete implementation.
The audit approach here presented includes a scoring model to provide a quantitative level of development
(or maturity) for each element of the PSM framework, as shown in Figure 1.

Figure 1—Criteria for Element Maturity

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The 4 levels of element maturity indicate:

1. Inadequate Element missing or there are significant gaps in its fundamental components
2. Incomplete Element has some gaps in various fundamental components
3. Standard Element is adequately developed in its fundamental components
4. Advanced Element is adequately developed in all its components

This audit protocol was applied to various upstream and downstream organizations as well as in some
contaminated groundwater treatment plants, taking in consideration the different depth of PSMS application
depending on the scope and complexity of their operations.

Audit Results
The data relevant to the experience carried out on PSMS audits to contaminated groundwater treatment
plants were collected and elaborated in order to identify trends on good practices and recurrent areas for
improvement.
The results, in terms of maturity levels are graphically represented in Figure 2.
The analysis shows that not all PSM elements have the same maturity level which means that Process
Safety topics have not been completely embedded in the HSE management systems of these Low Risk
Plants.
In particular, the PSM items in need of strenghtening are:

• Process Safety Competency:

Typically, in the training matrix the desired competence level on Process Safety is not established
for each role; consequently, Process Safety topics are not addressed in training program at the same
level of the occupational safety ones.
• Process Knowledge:
Process knowledge ownership not clearly allocated is often an issue. This is very critical when
process changes or plant modifications need to be carried out. In these situations, the risk is not to
have a clear reference in the organization whit a comprehensive know-how on the processes that can
ensure all Process Safety aspects and associated risks are systematically taken into consideration
in the design of the change.
• Pre-Start up Safety Review:
a Pre-Start up Safety Review process is not properly established and implemented. This may result
in the risk of not systematically ensureing that plant modification or new equipment is aligned to
the project design and all measures to eliminate or reduce risks are ready to work as intended prior
tothe handover to Operations department.
• Performance Indicators:
key performance indicators (KPIs) tend to be utilized more for monitoring economic performances
ofthe processes rather than the efficiency in managing Process Safety risks.
IPTC-19575-Abstract 5

Figure 2—Element Maturity of Low Risk Plants

To fill these gaps, the Low Risk Plan would benefit from reviseing some internal processes, as
summarized in the next paragraphs.
Process Safety knowledge and competencies should be enhanced through a structured training system
and a more effective dissemination of technical and process knowledge to appropriate functions withinthe
organization.
Competencies on Process Safety should be established for each relevant function and responsibilities
assigned for ensuring that required competencies are properly developed and maintained
Specialist functions with process knowledge ownership responsibility should be appointed in order to
maintain an accurate know-how of the processes and to provide a technical reference for any process or
plant modification or appropriate support for the development of new projects.
The Pre-Start up Safety Review process should be enforced to systematically ensure that a plant
modification or a new equipment conforms to the project design and all measures to eliminate or reduce
risks identified were implemented and works as intended.
The system of key performance indicators (KPI) should be comprehensive for monitoring the
effectiveness of a PSMS and identifying criticalities or areas of improvements.

Benchmark Results
The benchmark between Significant Risk Plants and Low Risk Plants in terms of maturity level of the PSM
elements does not provide useful information because of the different level of implementation required on
a regulatory level.
More interesting information were obtained by elaborating the findings from Process Safety audits,
specifically the percentage distribution of finding occurrences for each PSM element. The comparison
between Significant Risk Plants and Low Risk Plants is shown in Figure 3.
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Figure 3—PSMS Findings

Focusing mainly on the higher differencies in terms of the percentage distribution of finding between
Significant Risk Plants versus Low Risk Plants it was possible to really determine which are the most
relevant good practices (↑) and areas of improvement (↓) in the PSMS of contaminated groundwater
treatment plants. These elements are reported inTable 2 with reference to the corresponding pillar.

Table 2—Good Practices and Areas of Improvement for Low Risk Plants
IPTC-19575-Abstract 7

The elaboration of audit findings confirms the preliminary results based on the maturity level of PSM
elements and shows that most of the areas of improvement are related to PSM elements belonging tothe
planning and verification stages of the PSM framework.
This analysis hightlight the areas which deserve higher attention in low risk plant:

• Process Safety culture

In Low Risk Plants’ Process Safety culture is often affected by a lower commitment of
the organization on Process Safety management. Roles and responsibilities on Process Safety
management are not always clearly established and assigned to the key figures of the organization.
Process Safety is not adequately promoted and supported by managementduring site visit, while
personnel are informed on risks of their activities but is not completely aware of the consequences
of major process risks from adjacent industrial plants, in particular, in case of an emergency.
• Involvement of Employees and Contractors
Periodical meeting with employees and contractors are regularly carried out but the focus
of thesemeeting is mainly on occupational safety risks. Occasionally Process Safety topics are
discussed and lesson learned disseminated within the organization.
• Auditing
The auditing process verifies all HSE aspects pertinent to the scope of the Low Risk Plants’
business activities. However, not all relevant Process Safety topics are completely investigated due
to the partial implementation of the PSMS.
• Management Review
Process Safety management is not reviewed by top management on yearly basis even if some
Process Safety aspects are sometimes included in HSE topics. Specific Process Safety objectives
and targets are not established.
The analyses carried out show that in Low Risk Plants the PSMS pillars which tend to be underdeveloped
are: Process Safety Leadership & Commitment and Accident Management and Management System
Verification. Therefore, to achieve a fully developed PSMS and effective management of Process Safety, in
line with the different types of hazards and risks arisen from operations is essential that a consistent Process
Safety culture is promoted and supported at all levels of the organization. The enhancement of the Process
Safety culture within the organization should be fostered by a visible leadership and commitment of top
management in order to make all personnel aware of the responsibilities associated to their own activities
as well as the importance to comply with the applicable rules and regulations. Adequate and competent
resources should be provided for the PSMS implementation, comparable to other management systems.
The development of knowledge and expertise in all technical and operational functions should be ensured
by a proper training system and verified on regular basis to assess the effectiveness of training imparted to
personnel in terms of acquisition, assimilation and maintenance of knowledge.
Information on Process Safety should be better disseminated within the organization with the aim to
increase the understanding of hazardous conditions and highlight the importance to promptly address and
solve any Process Safety problems.
The involvement and participation of employees and contractors in ensuring and maintaining Process
Safety performance needs to be enforced using appropriate systems to encourage everyone’s contributions,
including observation and reporting of abnormal conditions and near misses but also suggestions for
modifying and improving procedural and operational aspects.
Specific objectives related to Process Safety should be established and their achievement monitored
at regular intervals. The adequacy and effectiveness of the PSMS in pursuing such objectives should be
verifyied by a comprehensive auditing system covering alla PSM elements.
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Process Safety performances and audit findings should be reported to top management and evaluated
during the HSE management review process to determine whether the PSMS is working as required and
isproducing the expected results or it needs some improvements.

Conclusions
The benchmark results confirm that the effectiveness of a PSMS is strictly linked with the level of risks in
activities and how such risks are managed both in administrative and operating processes.
The writer experience on auditing both Significant Risk Plants and Low Risk Plants highlighted that
statistically in the later the areas which require strengthening are: Process Safety Leadership & Commitment
and Accident Management and Management System Verification.
A robust risk-based approach in all processes, fostered by a visible commitments of top management, is
the successful key for enhancing the Process Safety culture of personnel and ensuring safe performances
and business continuity in operations, irrespective of the risk level in activities.

References
2007, Guidelines for risk based Process Safety. Centre for Chemical Process SafetySafety (CCPS). Wiley
December 2010, High level framework for Process Safety management, first edition. Energy Institute, London
Process Safety management of highly hazardous chemicals, 1910.119. Occupational Safety & Health Administration
(OSHA). https://www.oshagovilaws-regs/regulations/standardnumber/1910/1910.119