An older post, with updates…Ever since the 2005 BP Texas City tragedy, refineries and chemical plants have been working diligently to review “facility siting” risks for their facilities. As with all of the PSM elements, many of us took this new focus as a learning opportunity. We had all done something we called “facility siting” in our Process Hazards Analysis, but in the early 1990’s many of us “did not know what we did not know” in regards to what a real facility siting analysis was suppose to look like.
These days, there are single facility siting projects being done in such detail that they cost hundreds of thousands of dollars. These studies look at very specific scenarios as they relate to process location and it’s impacts to neighboring process units, control rooms, contractor/maintenance shops, administrative buildings, etc. In other words we have come a LONG WAYS in the past seven years with how we conduct facility siting analysis. But we may be overlooking something in our facility siting analyses that I come across quite often in my work around the world and this is what I want to present.
We have spent hundreds of millions of dollars across the chemical and refining industries to look at how our process(es) can impact our workers, processes, and buildings and then implementing the necessary improvements. Some facilities have even done off-site modeling to determine what off-site impacts can occur with certain scenarios from those process units on the outer edges of their facilities (note: this is much different than our RMP worst-case and alternative-case scenarios). One specific item that I want to use as my example is “Turn-Around (TA) tents”. These temporary structures are the much like the temporary trailers that were involved in the 2005 BP explosion, but instead are true tents and not a “structure” as most of us would envision. If you can envision going to the circus and watching the lion shows or the circus clowns, you are envisioning the right kind of tent! These tents are used for large and long-term projects where there is a need for temporary facilities to house workers for meals, breaks, safety talks, out-of-unit maintenance, etc. We most often seem them used during turn-arounds/shutdowns where the facility is hosting hundreds or thousands of contractors for a couple of weeks.
Most facilities will perform some type of facility siting to determine a safe location for these tents based on several factors (e.g. use, maximum number of personnel, time personnel spend in the tent(s), etc.). However, in these assessments, most facilities are SOLELY looking at what the process can do to those workers gathered in these tents if a process unit was to have an emergency. It is this current practice where my concern lies.
In the mid 90’s I was working a Turn-Around (TA) at my facility and we had erected a couple of these “circus tents” for our 1,000+ contractors who would be on site. In these tents we had vending machines (drinks and snacks), microwave ovens, cool-air conditioners, chilled drinking water dispensers, etc. And of course, we had issues with NOT ENOUGH electrical outlets for everyone, so there was a lot of “daisy-chaining” of extension cords going on. To make a long story short, we overheated a cord, which led to catching a tent flap on fire while the tent was unoccupied, and before anyone could even sound the fire alarm or pick up an extinguisher the tent was fully involved and we had sheets of flying-flaming tent heading towards our emergency scrubber and vent line, which unfortunately was only about 50’ away!!! I think we can all form a mental image of a circus tent on fire and sheets of the burning tent flying in the air dropping miniature napalm bombs on vehicles, grass, tanks, process units, etc. as it flies over. We can also envision what it would look like with one of these flaming sheets getting snagged on the 36” Fiberglass Re-enforced Plastic scrubber tower and vent line… it was UGLY. In less than ten minutes, well before the fire brigade could assembly and establishes a water flow in this “remote location” with no nearby hydrant, we had one process unit involved in fire, approximately 20’ of the 36” scrubber duct work destroyed, and the entire scrubber tower seriously threatened (also posing a significant caustic release!) . All in all, this was over a $40,000, 000 loss, due to a much longer TA than we had planned for – if you know what I mean!!! The company leadership and the site manager I was working for would NOT bring any process unit back on line and required ALL operating units that relied on this emergency scrubber to come down until the emergency scrubber was fully functional.
Doing the investigation with some real PSM experts that were brought in, it came down to one simple question… why did we allow a huge combustible tent to be erected so close to such a critical process component? Our response… it was outside the blast zones and TIH/PIH zones for the process units. We never thought about the risks the tent and all the !@#$% that came with it, such as improper electrical wiring, no control over activities inside or outside the tent, no fire extinguishers, a bunch of uncontrolled combustibles (e.g. cardboard boxes of Styrofoam cups, paper cups, napkins, coffee maker filters, piles of paper plates, plastic forks/spoons/knifes, wooden tables and chairs, etc.). In essence we built a “tender box” and we got what we asked for.
Ever since that incident I have looked at “facility siting” from both directions:
WHAT can the process do the temporary structure
and
WHAT can the temporary structure do to the process
As a consultant now, I get a lot of eyebrows raised when I asked about procedures or MOC’s for the placement of these “temporary” structures and the risk assessment for what this “change to facilities” will have on the process (e.g. a MOC). It is my professional opinion that the placement of these temporary structures should trigger a Temporary MOC, which should include a risk assessment with consideration of the workers safety in the structure and the risks the structure poses to process unit(s) and even those critical pieces of process equipment remotely located that could be impacted by the structure. And folks let me tell you, 50’ for a circus tent just ain’t going to cut it! I do not care how many extinguishers you put in the tent, how much you restrict the storage of combustibles, etc.; if the tent catches on fire it will be gone in minutes and you will have one huge nightmare staring you in the face. At this particular facility we had some really nasty toxics and very few flammables; but I can clearly imagine the escalation of this incident if it had occurred at one my “flammable” process businesses and rained down napalm into my flammable liquid tank farm!!!!
If your facility plans to erect tents and temporary building for large project or TA, I offer up these painful learning for your consideration. PLEASE keep in mind, these tips are based on the ASSUMPTION that a facility siting analysis has already been conducted and a safe location (for workers and process protection) has been established!!!
1) ENSURE that all electrical is to code. Be CAREFUL assuming that the building is temporary when wiring up the electrical. There are different requirements for “temporary wiring” vs. “permanent wiring” and when these structures become “popular” they tend to become “permanent” (e.g. loner than 90 days) with temporary wiring! It is especially CRITICAL that all wiring be routed through some form of protective barrier as it passes under/through the tent. Be sure enough power outlets are provided for ALL the appliances and RESTRICT personnel from bringing in other cords for their personal use in order to prevent daisy-chaining of cords which will lead to overloading the cords.
2) CONTROL all combustibles and flammables inside and around the outside of the structure. As these structures become more popular and more workers use them, they tend to become a “catch-all” for all kinds of !@#$!!!! In my own plants and auditing as a consultant I have seen everything from chlorine to propane cylinders stored inside these temporary structures. NEVER assume a tent will not contain propane vapors – THEY WILL! Some tents have personnel cooking meals for contractors and propane is the fuel of choice. Do NOT let your caterer store 20 propane cylinders behind the tent! Create a “designated cylinder storage area” that complies with OSHA/NFPA gas cylinder storage or just allow the one cylinder in use and one spare. And if we have multiple vendors using propane, we need to assess the total fire load from all vendors together and not individually! My practice was to rent an ISO container and use it for ALL storage of combustible supplies. This keeps all my ordinary combustibles inside a metal storage container located a safe distance (but convenient) – protecting the material from fires and my tent if the material does catch fire.
3) CONTROL ignition sources! Do NOT allow smoking inside or outside these structures. Many businesses will lift their smoking restrictions during TA’s because it is such a hassle with the traveling contract crews and enforcement. In a process unit that has been evacuated, purged, and isolated at its battery limits, smoking may be less of a risk than allowing smoking inside a tent with a grass floor!!! If you want to have a “smoking area” in close proximity, buy a load a gravel and make a CLEARLY MARKED graveled smoking area. Provide a fire extinguisher and PROPER disposal equipment for buts. I also provide a fixed lighter at the smoking location, as I NEVER allowed lighters in my facilities!
4) PROVIDE FIRE PROTECTION as needed. Depending on the size and use of the structure, there may be a need for only one fire extinguisher; however, there may be a need for much more extensive fire protection, such as 150 pound wheeled units or multiple portable units depending on what will be happening inside the structure/tent. On one TA we were involved in for a client we found deep fryers being used for the “TA safety celebration” fish fry and nothing but water extinguishers in the tent. Without the grease, water extinguishers were the right choice for a grass floor and ordinary combustibles; however, when we changed the fuel we should have recognized the need for a change in fire protection. I have also seen tents used for welding shelters. Not only are there risks with fire, worker ventilation is also a major concern and very difficult to manage. It seems the more toxic the metal the more precise the welds and these tents are erected to act as wind breaks and weather shelters so that the welding can be done around the clock. We need a damn good Industrial Hygienist if this situation arises.
5) CLEAR a grass/weed buffer around the outside of the structure so any grass/weeds fire will not have a detrimental impact on the structure. I prefer a 10’ buffer, or more, depending on weather conditions. (i.e. in a drought I may require additional distance). This buffer will also help control the four legged critters that come out a night and those that slither!!!
Portable Tanks/Totes and Process Impacts
One last facility citing item I want to mention is the use of “portable tanks” during normal operations and TAs. Many of us have “new chemical” assessment programs that require the EHS group to review the impact/risks of allowing a new chemical on site; however, most of the programs I know of look solely at employee exposure to the chemical and environmental impacts. We need to either take our “new chemical” review process to the next level to pull in facility siting based on where this chemical will be stored and used or build our new chemical review risk assessment process so that it is part of our MOC process to ensure “impacts on the process” are being reviewed.
Bringing small fuel tanks of just 100 gallons into a process unit can have a HUGE IMPACT on that process! For example, a 330 gallon with a flammable liquid is brought into a process unit not designed for flammable liquid (e.g. no electrical classification, no containment, improper fire protection, etc.). This mere 330 gallons, spilled into an area could create a “pool fire” scenario under our process vessels. Our relief valves may not have been sized for a “fire scenario” since our process does not have flammables. This would be EXTREMELY BAD! The other concern with this 330 gallon tote is where we place it. I have seen totes stored under large pipe racks that are not insulated for fire protection, next to and under un-insulated structural supports, and at ventilation intakes for critical process ventilation systems.
We MUST control all risks to our process, even if what we are changing is not touching our process. Whether we do this via your MOC process or some other type of administrative control, these small tanks/totes can pose HUGE risks to our process safety. In my time as S&H/PSM Manager I used my MOC system for all these tanks/totes and required a mini-facility siting assessment for anything over 60 gallons of a flammable or combustible liquids. And let me state this now… EVEN when my process was a flammable liquids or gases process, I STILL REQUIRED an MOC and FS Analysis for a portable tank/tote with flammable or combustible liquid!!! We often times have very focused fire proofing efforts around HIGH RISK structures such as process structure and pipe bridges; but we also have areas that are NOT protected based on the “unlikelihood” that a pool fire would occur in a particular area. We now bring in 330 gallons of a flammable liquid and now our assumptions from our previous risks analysis regarding fire proofing and fire protection are no longer true.
I also developed a SWP/SOP with facility requirements for how these portable tanks/totes are managed. We had some basic requirements for
- inventory control,
- labeling,
- secondary containment,
- bonding/grounding,
- weather sheltering,
- fire protection,
- PPE assessment, etc.
But the SWP/SOP was a COMPANION to the MOC and facility siting assessment. Often times, the operational personnel were shocked at where we would allow and not allow these mobile tanks/totes. The SWP/SOP program had a “Tank/Tote Permit” that had to be submitted to the safety/PSM group for review and approval. These days, I just help clients incorporate the permit questions/checklist into their existing MOC process. The basis for this permit approval process is much in line with what we now call “5-S”. In my early years of using this program I always had one issue that drove me crazy… these mobile totes/tanks would MOVE around – go figure! My team and I would find them in the darndest places. So my brother had the idea of forcing the unit manager to designate where he/she wanted to place the tote/tank and it was then their job to enforce the location, much like we do with our tools in a 5-S program. But user BEWARE, any such program MUST include an audit element in order to ensure the program is followed. The program MUST BE ENFORCEABLE as well, as management needs to understand the risks and controls in place and failure to apply the controls to the risks means we “YANK THE TANK!” (yes the program invented the saying after I canceled permits and had totes removed from units)
I hope this has help you think outside the box a bit when looking at those “temporary structures” and the risks they can pose to our process, as well as how even the smallest of tanks containing hazardous materials can have significant impacts on our process. Keep in mind, everything I mentioned in this posting is based on ONE SIMPLE PREMISE… safety discipline! We are relying on the our people to follow rules and do the right thing 100% of the time. There is NO program in the world that can control risks if the people involved in carrying out the tasks are not in tune with the risk involved.