(102c) Implementation of Design Best Practices for Upstream Safety and Environmental Management System Program

Although not all upstream facilities have been historically obligated to meet the requirements of the federal OSHA PSM standard (29 CFR 1910.119), utilizing this existing set of technical, documentation, and procedural practices can be expected to achieve the same results as in the downstream, chemical, and petrochemical industries. Namely, to ensure the safe operation of a facility, various hazards associated with the facility process and the plant equipment need to be addressed in a systematic manner.

As a result of the Deepwater Horizon incident on April 20, 2010, the Department of the Interior adopted the Safety and Environmental Management Systems (SEMS) regulation (30 CFR 250). This regulatory program, which imposes a process safety management-like program on oil and gas facilities operating on the Outer Continental Shelf (OCS), replaces a voluntary program that had existed since 1993.

Those working in the oil and gas industry are reminded with depressing regularity of the importance of process safety management, as post-incident investigation invariably points to one or more deficiencies related to process safety as root causes. This paper challenges the predominant notion that upstream facilities can be safely operated without following methods similar to those dictated by OSHA based on technical comparisons of pressure relief system design findings for upstream and downstream facilities. An adequate pressure relief system plays an important role in safe facility operation both through avoidance of catastrophic events and through prevention of incident escalation.

Similarities in relief system design issues for 60 process units of representative upstream and downstream production facilities are presented in a comparative case study. Alignments and points of divergence in typical practice between the example facilities are discussed. Significant similarity in the nature and types of the pressure relief systems deficiencies between upstream and downstream facilities is concluded.

The information presented helps upstream asset owners better understand standard practice for OSHA regulated facilities, align the corporate approach to safety, especially for vertically integrated owners, and demonstrate benefits achieved through proper design and documentation.