Operations within
the hydrocarbon industry involve numerous hazards to be identified, mitigated
and maintained at as low a level as reasonably practicable. In the very early
stages of a new facility’s conceptualization, hazards are identified, and
mitigation controls are incorporated during all design stages. Facility construction
is also managed to meet all minimum design criteria. Exercising best management
throughout all stages still does not ensure that the risk level as identified will
remain the same. When implemented as an actual process facility, the design has
many limitations, such as waivers issued, technical concessions provided, punch
points left out and many other scenarios where the actual deficiency may not be
communicated to technical personnel and can become a part of the facility. Even
if approvals are obtained, a formal risk assessment is rarely part of the
process. There are many reasons for this besides the obvious timeline pressure under
which process facilities are constructed and commissioned.
Process facilities face other challenges when they are put into operation where many changes are implemented to enhance the process throughput, reduce downtimes, improve maintainability and reliability, fix the bad actors and support other requirements that arise during regular operation. Although systems enable users to register changes for any reason, changes may be put into practice without completing all the necessary reviews. Typically, these changes are not particularly related to the hardware but are practices followed by a smaller group of personnel addressing only one side of an issue. The classic example includes incompletely following a procedure to keep the facility running or avoiding certain maintenance practices demanding resources or plant downtime. Therefore, the need to identify hazards and declare risks is paramount.
Issues are faced daily in hydrocarbon processing facilities during normal operations, maintenance and inspection activities. Not all issues are selected to evaluate the root cause and take appropriate action to further analyze and fix them. These issues can arise during trials through commissioning and pose some level of risk that should be assessed, mitigated and eventually normalized; however, this does not always happen. Cathodic protection not provided for certain assets during construction can lead to corrosion, resulting in the elevated risk of unplanned operations costs. For example, there are cases where carbon-steel bolts were provided instead of stainless-steel bolts in flange connections, leading to galvanized corrosion; and piping externally painted with the incorrect painting specifications—due to the unavailability of the correct material—when the plant had to be started to meet targets.
Long lists of such punch points are often available to asset owners, but once the plant begins operation, addressing punch points becomes challenging with the reduced presence of contractors and their resources onsite. The running plant becomes the priority for all frontlines at the facility. Pulling out punch point lists should be the priority of the asset integrity team onsite after the plant becomes operational. Addressing them through contractors is not the main point—awareness of what has been critically missed at the plant is the goal. Identifying the cases that pose a great threat to plant operations and maintenance, performing formal risk assessments to record the mitigations and controls, and agreeing on the residual risk level and the resulting action plans are vital to successful and efficient operations. Risk identification and management have a head start if these things are given priority in a new facility. This would be categorized as a proactive move to identify and manage risk.
Risk assessment
addresses issues related to continued operations and sustained maintenance when
the plant is running and operational. Any reoccurring problem requires
attention to assess whether it elevates the existing risk onsite. However, not
all issues are selected for resolution due to repeatability. Every department
should investigate reoccurring issues and understand the potential consequences
affecting health, safety and environment (HSE), asset integrity, finance or
company reputation. Operations have unique issues, similar to other
departments, including maintenance, technical and HSE. Typically, risks are
known to the personnel and management working within these departments;
however, there can be cases where inherent risk is unidentified and unassessed
in the system for an extended period. Some ways in which risks can be
identified in any department include:
The company should obtain data identifying the peaks in financial spending and analysis to understand the constant spending areas categorically. Such data obtained for at least the previous 5 yr would provide indicators of a potential risk. Similarly, events triggering incident investigations and HSE leading and lagging indicators should be explored. Safety incidents provide data that can potentially hit the HSE aspects of risk. Logging and communication are necessary when risk assessments are being carried out. The probability of any safety incident largely depends on the data available to the risk assessment personnel. A team can incorrectly conclude the probability of a wide range of categorized safety incidents if data is unavailable. Any case investigated for root cause analysis should also be identified when categorizing an inherent risk in a specific department.
A system of records for all root cause analyses would assist in a search for cases relevant to any risk assessment. Corrective maintenance is one area where irregularity is not uncommon. Problems with weak-performing assets can be addressed after examining the data available. This becomes true when failure records of preventive maintenance are analyzed. The preventative maintenance barriers that fail more frequently can provide information related to identifying risks. Plant inspection data supports an overview of asset health before any failure occurs. This area and preventive maintenance can provide all the necessary information required to ensure that the present risk is identified and kept as low as reasonably practicable. Audits can be used to support the identification of issues in any process. If performed, logged and addressed through a reliable system, audits identify the areas that carry potential risks to the process’s performance and sustainability.
The problem that triggered the root cause analysis should also be linked to the risk assessment, and the particular risk assessment should remain a record of why an analysis was performed or not considered. Once a root cause analysis is performed, it should validate the completed risk assessment and provide recommendations to lower the risk to an acceptable level. In cases where the recommendations are not implemented, they should be kept in the company's risk folder.
The primary purpose of plant personnel running plant operations, handling asset maintenance and being responsible for process safety is to minimize risk throughout the plant's lifecycle. Efforts should be focused on high-risk items and how they can best be managed. Maintenance and inspection processes, asset integrity and process safety assurance programs should also be risk-based. Risk should be a defining priority in the process industries. If the risk is assessed in all processes, management can formulate a more precise action plan for the problems that require the most focus and have the greatest financial importance. HP
ASHFAQ ANWER
is an Inspection Professional with 15 yr of experience in ammonia-urea
complexes, petrochemical units, and the oil and gas industry. He has extensive
expertise in material selection, corrosion mapping and control,
fitness-for-service studies, defining inspection framework and implementing
inspection plans for old and new units.