Implementation of PSM in Midstream Facilities with Midstream-Specific Hazard Analysis Procedures

The fracking boom in the US led to an enormous task – the safe handling and processing of massive amounts of gas extracted as a byproduct of oil production.

Process safety is often an afterthought in midstream operations since many midstream facilities are constructed and operated by the drilling companies which are excluded from PSM coverage by the oil and gas well drilling and servicing exemption, 29 C.F.R. §1910.119(a)(2)(ii).

Currently, many midstream companies apply the best practice of conducting process hazard analyses (PHAs) and layer of protection analyses (LOPA) on both PSM and non-PSM covered facilities alike to improve company process safety and operational integrity. However, the application of extensive process safety practices that were intended for larger operations such as refineries may further impede the adoption of process safety, and could drive an excessive level of safeguards and unnecessary cost.

This paper will look at actual examples of midstream industry design practices that were derived in actual PHAs that can be used to aid in the development of a midstream-specific process design RAGAGEP. The aim of this approach would be to streamline design, simplify risk assessments/ hazard analyses and improve process safety implementation and consistency.

We will discuss potential RAGAGEP including design, operations and acceptable safeguards for the following equipment:

• HP Emergency Isolation Valves
• Inlet liquids handling equipment
• Reciprocating compressors
• HP/ MP/ LP Drain Systems
• Atmospheric tanks
• Truck loading/ unloading
• Glycol Dehydration
• BTEX Elimination
• Vapor Elimination
• Emergency Flare
• Others