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Procedures And Guidelines For Hazardous Materials

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Response / Training

They said it could not happen -but, it did! Heat inside a pulp and paper process was escalating to dangerous levels. Looking for answers, the mill contacted other facilities around the world that used the same equipment. The replies were the same; “It’s impossible ... It can’t happen”. When the heavy steel structure started to melt, water was used to cool the outside walls, eventually an explosion and fire occurred and the process equipment was lost. Later, it was discovered that the computerized emergency fail-safe system was at fault.

Whether an event is large or small, working around Hazardous Material Process Systems is a serious business. Project Administrators have an enormous responsibility to ensure the work is completed according to standard and to operating expectations. Each trade, contractor or individual is an important part of the team when it comes to ensuring that the job is done right. Spills, leaks and releases can result from human error, mechanical failure and chemical reactions.

When working with hazardous material process systems, standard operating practices, procedures and guidelines must be followed.

Careful planning and the selection of competent trades people are two crucial ingredients required in today’s process safety management programs. Working with hazardous material process equipment requires being aware and prepared for potential spills, leaks and releases. This means a balance of pro-active and reactive approaches, plans and procedures to address the needs of the job as well as the needs of the customer.

Planning should consider the operating history, frequency of releases, age of the process and response capability. Oversights could lead to upsetting conditions inside the plant and the evacuation of nearby residents.

Understand The Team Approach

Whether your job involves developing an Action Plan, designing the process or setting the specifications, it involves having specialized skills, knowing your limits and being a team player.

Players must understand:
  • not only what to do but also what not to do,
  • how the equipment works,
  • which chemicals are used in various locations,
  • where safety features and alarms are located,
  • when “safe work practices and permits” are required,
  • who to call for information,
  • who to call in an emergency, and
  • why they are part of the plan.

In addition to knowing how to do the job, all personnel are expected to obey the facility’s general workplace safety rules, work in compliance with local, provincial/state and federal legislation and follow developed Process Safety Management Practices, Procedures and Guidelines laid down by the Project Administrator. In accordance with the Project Administrator’s Action Plan, everyone is expected to do their job effectively, in a timely manner and communicate results and difficulties.

“Safe work practices” such as maintenance, confined space entry, line break-ins / tie-ins, lock-out and tag-out procedures are routine activities at a refinery or process plant. People who do this type of work on a regular basis are skilled, trained and knowledgeable. They know that no one person on the project has all the answers and that it takes teamwork to bring projects to a successful conclusion.

Team leader/project administrator

A team leader, who must be intimately familiar with all aspects of the project, is appointed as the Project Administrator. The Project Administrator is responsible for developing an Action Plan that transforms the approved project into a working reality. Process Safety Management Procedures Practices and Guidelines are developed by the Project Administrator on a job-specific basis to ensure that the sequence of events, proper equipment and work permits are in place and that workers know exactly what, where, when, why and how to do their job. Pro-active planning, actions and preparedness may provide the buffer required to gain control of an unanticipated event.

The ideal team will have an intimate knowledge of the standards, codes, specifications, regulations and the hands-on skills required to do the job as well as a working knowledge of the chemicals involved in the process. The team should include representatives from operations, maintenance, engineering, chemistry, environment, health and safety, as well as outside contractors and consultants as required.

Developing an Action Plan

An Action Plan must address the needs of the job as well as the overall operating, sales and marketing objectives for the plant. Effective planning is based on understanding the needs of the project. Walk-throughs, video footage and drawings of the job site help to explain objectives and focus initiatives

An Action Plan is a series of written operating procedures that provides technically-accurate instructions for co-ordinating and implementing the work. The instructions must be clearly understood by all personnel including those who speak a different language. Failing to address critical issues could result in business interruptions caused by the lack of quality control, loss of production and upset of process equipment.

Considerations to address critical issues may include:
  • stockpiling finished product to meet customer demands,
  • using portable feed tanks to maintain production,
  • reducing the inventory of hazardous materials during periods of construction,
  • eliminating high-risk working conditions or modifying existing conditions.

Respect and Understand the Properties of Chemicals

A planning team made up of experienced people from diversified backgrounds can provide the best foundation for establishing realistic approaches, goals, time-lines and procedures for modifying existing risks and hazards as well as co-ordinating work activities. Informative and readily understood diagrams, charts and documented chemical information should be available to help understand the codes and standards used to establish good engineering and chemical management practices.

Workers need to know, understand and respect the physical and chemical properties of the process chemicals, the chemicals stored or used in close proximity to work areas, the appropriateness and compatibility of discharging residues to nearby floor drains and what action to take in the event of an emergency.

Workers must be aware of the job-site dangers that could affect workplace safety, cause fires, explosions, release toxic vapours and create runaway reactions. Material Safety Data Sheets and workplace labels are the starting point for gathering information about process chemicals. Data from these and other sources should not be taken at face value but rather supplemented with testing, process chemistry information and verified by technical and experienced personnel. Chemical information, in relation to workplace conditions and experiences, will identify the need for special personal protective equipment, portable collection systems, etc., and the need for emergency response supplies, equipment and personnel to be at the site or on stand-by.

Understand industrial equipment

Equipment that is built to handle highly-hazardous chemicals or conditions has to be designed, constructed, installed and maintained to minimize impacts to people, property and the environment. Understanding the compatibility of equipment, hoses, pumps, and containers used to transfer, store and handle the chemicals are all part of the necessary considerations. When system changes are to be made, the Project Administrator must research and adjust the action plan to identify the potential scales of impacts, consequential losses and the requirements of emergency response teams.

Emergency response

Teams responding to emergencies should also view them as opportunity to expand their knowledge, establish project-specific response procedures and ensure that appropriate supplies, equipment and support services are in place during critical phases of the job. The majority of the members involved in an industrial response team are from the maintenance or engineering departments who may have built the systems, operated the chemical processes and seen unexpected events react vigorously or remain dormant. They are used to “safe work practices” and often their judgement and reactions are drawn from first-hand experiences.

Debriefing the job

In spite of all the good efforts, unanticipated events occur. Some are good experiences and some are not but both increase the base knowledge of all involved. Recently, during a hydrochloric acid line break-in and tie-in at a refinery, both an experienced plant engineer and a pipe fitter had concerns about joining old plastic acid pipes to new ones. Acting upon the information of a reputable supplier, a test join was done and the results were satisfactory to proceed with the break-in and tie-in of the HCL line.

After the job was done and pressure tested a minor drip leak resulted at one of the joints. Routine countermeasures were installed. The supplier was contacted concerning the failure results and it was discovered that the recommended resin was not suitable for the old style plastic pipe. The pipe fitter conducted a series of “Peel Tests” that verified there was nothing that could have adequately bonded to meet their engineering standard. Others can benefit from their debriefing process.

The lesson here is ... Never Assume!

Cliff Holland, Spill Management Inc.