(56h) Project PHAs - Startup Correct

This paper presents process safety lessons learned from several project phases for Process Safety Management (PSM) and Risk Management Program (RMP) regulated midstream oil and gas facilities.

New projects are ever occurring, especially in the midstream oil and gas industry. The authors continue to observe much better process safety attention and compliance during the operational steady-state phase of the facility life cycle than in the pre-operational project phases.

The authors are pleased with the beneficial shift over the last few years from a just-in-time Process Hazard Analyses (PHAs) on Issued for Construction (IFC) or As-Built P&IDs (Piping and Instrument Diagrams) to allow on-site chemical inventory above the PSM/RMP threshold quantities (startup) to PHAs that are performed earlier, such as at the Issued For Design (IFD) project state. While earlier PHAs certainly have many benefits including lower cost and less schedule impact of needed process safety changes, it is important to note that the PHA needs to be correct at startup, and having PHAs earlier provides more time and opportunity for things to no longer be correct at startup. A few ways to ensure correct PHAs at startup are:

• Having an effective Management of Change (MOC) program is in place prior to starting the PHA, or
• Performing an additional just in time PHA.

This paper first will discuss both approaches ensuring startup correct PHAs, including what needs to be in place for each approach. Second, the pros and cons of each approach will be discussed. Third, the two approaches will be compared. This will allow the reader to better determine what approach they should be using at their facilities.

Now that the two approaches have been discussed, the authors will present several case studies where PHAs were not startup correct and the associated realized and potential negative impacts. The case studies will identify the root causes and describe both preventative and corrective action plans. This will allow the reader to determine how to mitigate their risks if they don’t have startup correct PHAs.

Applying these lessons learned will result in a quicker startup of lower cost, safer midstream facilities.