A Flare and Overpressure Management System
- Methods, Metrics, KPIs and Software Solutions -
Michael Marshall, PE
Oil Industry Consultant
The highly publicized incidents at BP Texas City in 2005, Tesoro Anacortes in 2010 and Chevron Richmond in 2012 are now driving the reexamination of the PSM rule by the US regulatory community. In addition, the US Chemical Safety Board (CSB) has taken notice that US Oil & Gas industry losses are highest among any industrial sector, and that the US Refining industry accident rate is 3 to 4 times higher than in Europe.
Overpressure protection and relief system design have come under particularly intense scrutiny by OSHA since promulgation of the PSM rule, with several enforcement actions citing missing, inaccurate and incomplete relief system information as well as outdated pressure relief analyses. And alongside OSHA, the EPA has issued numerous citations for the misoperation of industrial flares with consent decrees mandating operational enhancements and costly capital improvements. So, it is clear that this double barrel surge by way of OSHA and EPA has arrived and is progressing rapidly forward.
Furthermore, the PSM rule and its allegedly “less rigorous regulatory framework” are quickly falling out of favor with regulators. As such, the attributes of inherently safer design (ISD) are now being advocated by the CSB. Unmistakably, this would be taking the Oil & Gas industry and its PSM approach from performance-based to prescriptive. Yet, before opting to prescriptively rewrite the PSM rule, I suggest that there is a performance-based option which is more sensible, productive and achievable in the short term, and that is a focused metrics-driven management system approach.
This paper and presentation identifies the attributes and benefits of a metrics-driven management system focused on the process safety design integrity, reliability, and control of flares, pressure relief systems and associated safety systems. Central to the success and sustainability of just such a management system approach is the unique design and implementation of metrics and KPIs created from data lifted and aggregated from an enterprise informational management (EIM) platform.
Of course, knowing what data to capture and display is essential to proper metrics development and analysis. The idea is to tap into the data rich potential of an EIM system, and from this data and informational structure is extracted the 20% of data that 80% of operators, engineers, managers and execs want to see, with the challenge being identifying that 20% of key information, or KPIs.
When considering a performance improvement program in this highly regulated process safety environment, four key business drivers should first be considered, i.e., risk, regulatory, operations, and profits. Then, building a focused flare and relief systems management process around those four drivers involves a unique management system structure of people, processes and tools/technology. And given that a flare and relief system as well as associated safety systems are the last line of defense in overpressure protection, what better application is there for just such a strategic initiative.
A close second, however, would be a focused, metrics-driven management system approach addressing mechanisms contributing to the loss of primary containment (LOPC). The same people, processes and tools/technology (software and EIM) structure and methods employed in a flare and overpressure management system could be easily adapted for a LOPC focused initiative. And, this strategic initiative would involve the same business drivers of risk, regulatory, operations and profits.
What I am suggesting is that we as an industry can be even more critical and innovative in responding to LOPC incidents, data and metrics with enhancements to mechanical integrity proficiencies relative to inspection, maintenance, design and overall systems management. Historical operations, reliability and maintenance data can be better utilized and managed with analytical tools and performance metrics to determine needs, risk exposure, provide direction, and address opportunistic reliability issues. This would certainly include a more critical focus on inherently challenging API 754 process safety event (PSE) LOPC metrics relative to damage mechanisms, operating envelopes, and consequences of deviation, procedures, design and training.
LOPC is preventable, and equipment reliability relative to process safety is by far the leading risk opportunity and ongoing business concern facing the Oil & Gas industry today. A LOPC focused metrics-driven management system would provide a more robust program for facilitating comprehensive process design and engineering relative to reliability improvement, i.e., ‘safety in design.’
However, the scope of this paper and presentation will be limited to the topic of flares, relief systems, and associated safety systems. So, what follows here is the who, what, when, where and how of a flare and relief systems focused, metrics-driven management system and software solutions approach.
Flaring, relief system, pressure relief, process safety, evergreening, management system, mechanical integrity, reliability, risk management, risk assessment, emergency planning and response, training, auditing, layers of protection analysis (LOPA), safe limits, operating limits, RAGAGEP, safety culture, benchmarking, metrics, KPIs, continuous improvement, loss of primary containment (LOPC), enterprise information management (EIM)