This summer we saw a 300,000-gallon water tank fail which pushed a generator into a covered process which led to a release of the HHC/EHS. The questions I wish to pose are:
- Should the water tank have fallen under the PSM/RMP program due to its proximity to the covered process?
- Should the proximity of the water tank be part of the facility siting assessment in the PHA?
Of course, we have all 20/20 vision AFTER THE INCIDENT, but how many would have viewed the 300,000-gallon WATER tank as a “threat” to the integrity to the covered process? The facility where this incident occurred had just completed an RMP inspection by NC-EPA, in which EPA issued $7,118 in citations and NOTHING was mentioned about the water tank that failed less than two months later. Yep, that was a ROUGH two months for any facility – first an RMP inspection and then a PSM/RMP incident!!!!
This is NOT the first time a co-located process/vessel that did not involve an HHC/EHS has impacted a covered process. We have written findings against the placement of 1,000-gallon propane tanks on several occasions when they were sited right next to the covered process. Even though the propane was exempted from PSM because its use was as a fuel only; due to its physical hazards and location we considered it “covered” under the definition of co-location. Most of the times when these issues are identified it is involving a flammable liquid or gas, but as in the water tank incident we can see how even a “water tank” (albeit 300K gallons) can have a negative impact on a covered process.
When doing a “facility siting” assessment as part of a PHA, does the team consider items/objects NOT associated with the process but that could impact the process in a negative way? From everything such as vehicle impact to overhead cranes that pass through the process have been dynamic concerns we have identified in some PHA’s. As for static concerns, we have seen abandoned pipe bridges that pass over active process piping and this abandoned piping is in deplorable condition, including the pipe bridges and their foundations. Yes, it may seem weird, but even an abandoned pipe bridge that has supports along roadways NEED vehicle protection if their collapse could impact a covered process.
In 2009 I wrote about how a large tent used during a turn-around caught on fire and flaming fragments blew a distance only to come lodged on plastic ductwork causing a major failure of a safety system for my facility and the lessons learned from that “facility siting” failure. CLICK HERE to read that article.
We can learn from the misfortunes of this facility and in fact we owe it to ourselves to review our processes to assess the risks posed by items/objects that are located in such a way that their failure could impact our covered process(s) and that would include the “safety systems” associated with our covered process(s).