Process Safety Management

Operating Procedures
 Now that the PHA’s Are
Competed or Underway…
 Operating Procedures
& Safety Programs
Must Be Developed

 PHA Information Can

Be Used
 Operating Procedures
1910.119(f)
The employer shall develop and
implement written operating procedures
that provide clear instructions for safely
conducting activities involved in each
covered process consistent with the
process safety information and shall
address at least the following elements.
Operating Procedures & Safety
Programs Must Consider:
 Initial start-up
 Normal operations
 Temporary operations
 Emergency shutdown
 Emergency operations
 Normal shutdown
 Start-up following turnaround
 Consequences of deviation
 Steps required to correct or avoid deviation
 Operating Procedures or
Standard Operating Procedures
(SOP’s)
 Where Did This Methodology Come From?

 Answer: The Military

 Definition: A standard operating procedure is a set of instructions

having the force of a directive, covering those features of operations
that lend themselves to a definite or standardized procedure without
loss of effectiveness. Standard Operating Policies and Procedures
can be effective catalysts to drive performance improvement and
improving organizational results. Every good quality system is based
on its standard operating procedures (SOPs).
 Operating Procedures
 Develop and implement written operating procedures*
consistent with the process safety information and addresses
at least the following elements:
 Initial start-up, normal and temporary operations
 Normal and emergency shut-down procedures
 Operating limits and consequences of deviation
 Hazards presented by the process

*Must be Readily accessible to employees

 Operating Procedures

 The operating procedures addressing operating

parameters will contain operating instructions
about:
 pressure limits
 temperature ranges
 flow rates…and
 what to do when an upset condition occurs
 what alarms and instruments are pertinent if an upset
condition occurs, and other subjects.
 Operating Procedures
Many Covered Processes are Operated by Automated &
Manual Procedures
 Operating Procedures
Operators Must be Trained in Software Use
 Operating Procedures

Must Provide Procedures for Controlling the Process

 Operating Procedures

 Compliance Directive Asks:

 Do written operating procedures exist for each
covered process? Do the procedures provide
clear instructions for conducting activities
safely?
 Do the operating instructions address, as a
minimum, step for each operating phase?
 Operating Procedures

 Compliance Directive Asks:

 Do the operating procedures include
operating limits that outline consequences of
process deviation and steps required to
correct or avoid deviations?
 Operating Procedures
 Compliance Directive Asks:
 Have safety and health considerations been included
in the operating procedures?
 Properties of, and hazards presented by, chemicals
used in the process?
 Precautions necessary to prevent exposure, including
engineering controls, administrative controls, and
personal protective equipment?
 Control measures to be taken if physical contact or
airborne exposure occurs?
 Quality control for raw materials and control of
hazardous chemical inventory levels?
 Any special or unique hazards?
 Operating Procedures
 From the OSHA PSM NEP for “Refineries”
 Information typically listed in EOP and/or ESP
includes, but is not limited to the responsibilities for
performing actions during an emergency, required
PPE, additional hazards not present during normal
operations, consequences of operating outside
operating limits, steps to shutdown the involved
process in the safest, most direct manner, conditions
when operators must invoke the emergency response
plan, or scenarios when they themselves must stop
and evacuate.
 Operating Procedures

 From the OSHA PSM NEP for “Refineries”

 From interviews with at least three control
board operators in the Selected Unit(s), have
these operators received sufficient training,
initial and refresher, to be qualified to
shutdown the Selected Unit(s) per the
requirements of 119(f)(1)(i)(D)?
 Operating Procedures - Start
Up…We Must

 Describe normal SOP's

 Describe start-up SOP's

 Describe Shut-down
SOP’s
 Operating Procedures
 Company Must Have a Method for Developing
Procedures With Elements Such As:
 SOP Preparation
 SOP Review and Approval
 Frequency of Revisions and Reviews
 Checklists
 Document Control
 SOP Document Tracking and Archival
 Standardized Format
 Operating Procedures - Start
Up…We Must
 Include Sections such as:
 Objectives
 Purpose
 Concerns
 Procedures
 Department
 Operator
 Equipment Involved
 Location
 Related Documents
Operating Procedures
Let’s Look at an Example
 Operating Procedure for NASA E-Complex

1.0 INTRODUCTION
1.1 PURPOSE

The purpose of this procedure is to establish a step-by-step detailed method for assuring
a safe transfer of liquid hydrogen at the E-1 facility low pressure liquid hydrogen
transfer and storage system by purging/inerting and transfer of liquid hydrogen from
trucks at the trailer transfer stations to the liquid hydrogen storage sphere.

1.2 SCOPE

This procedure contains only those instructions pertaining directly with control of the
systems configuration to perform necessary purging/inerting of the system to assure
elimination of oxygen and the transfer of liquid hydrogen. The LH2 will be transferred
from trailers to the liquid hydrogen (LH2) storage sphere. The procedure contains
instruction for
a. Facility Status/Set Up
b. Pre-transfer Purging/Inerting
c. Liquid Hydrogen Transfer
d. Facility Securing/Shutdown
 1.0 REFERENCES

 2.1 DOCUMENTS
 SSP-8715-0001 John C. Stennis Space Center Safety and Health Handbook

 SSTD-8070-0089-FLUIDS SSC Facility Cleanliness Requirements for Propellant,

Gas and Hydraulic Systems
 SOI-8080-0027 Preparation and Use of Detailed Operating Procedures (DOP)

 SOI-8080-0030 Contamination Prevention, Field Cleaning and Temporary

Closures
 STP-8830-0012 John C. Stennis Space Center Technical Procedure Commodity
Receipt and inspection

 2.2 DRAWINGS
 PSK-E1-1001-FAC, Sheet 1 – LH Trailer Unloading Storage and Transfer Piping
and Instrument Diagram
 PSK-E1-9001-FAC, Sheet 9 – E1 LH2 Storage Area MFP
 3.0 RESPONSIBILITIES

 3.1 Personnel

 3.1.1 Test Team

 The Test Stand Director shall be responsible for the operations as outlined in
the procedure and personnel requirements. Personnel must either be certified
per the requirements or be approved as trainees. The number of Test
Operations personnel required to perform the operating tasks and functions set
forth in this procedure is three. The test team shall comprise of the test
conductor, two LH2 Storage Area Valve Operators and an LH2 Trailer crew.
Any change in the number of personnel must be approved by the Test Stand
Director or supervisor.

 3.1.2 Sign-Off Instructions

 The assigned personnel performing this DOP shall buy off each Step upon
completion on the buy off sheet.
 3.2 Safety

 3.2.1 General Personnel Safety

 The test conductor shall be responsible for ensuring compliance with

established safety policies and practices by the personnel in the team during
the performance of this procedure. Safe working conditions and personnel
compliance with applicable safety rules and regulations is the responsibility of
safety personnel.

 3.2.2 Hazard Control

 In the event of system and/or component leaks, malfunctions and/or failures

that occur during the performance of this procedure, the test conductor shall
ensure that systems are secured per the Lockout/Tagout provisions of the SSC
Safety and Health Procedures and Guidelines, and that no residual energy
hazards are present prior to inspections or repairs.

 The primary hazards associated with this procedure are:

 a. Bodily exposure to a cryogen
 b. Bodily exposure to a hydrogen flame
  3.1.1 Personal Protective Equipment Required
 3.1.1.1 Cryogenic, flame retardant coveralls
 3.1.1.2 Cryogenic gloves
 3.1.1.3 Face Shields
 3.1.1.4 Ear muffs or ear plugs

 4.1 General Requirements

 4.1.1 Personnel not directly involved with the transfer operation shall be
cleared back from the transfer/storage area during offloading operations.

 4.1.2 Hot work activity (i.e., welding, cutting, usage of spark producing
equipment, smoking, etc.) shall not be permitted within 100 feet of the
transfer system/operation.

 4.1.3 Communications between all work stations via standard headset or

radio is required.
 5.0 PREREQUISITES

 5.1 Verify Facility Status
 _____ An Open Item Review of all work activities at the E-1 facility shall be
accomplished to determine if any constraints exist against the perform of
this procedure
 _____ Verify LH sphere vacuum system is operational.

 _____ Verify GN2 system is operational.

 _____ Verify LH2 Storage Area emergency shower is operational

 _____ Verify LH2 Storage Area washdown hose is operational

 _____ Verify LH2 Storage Area Flare System is operational

 _____ Verify deluge system is operational

 _____ Verify control system is operational

 _____ Verify DAS is operational

 _____ Verify GHe system is operational

 _____ Verify that LH2 delivery has been scheduled

 _____ Verify GH system is operational

  6.0 FACILITY SETUPS

 6.1 Verify Flex Hoses are secured in holders with caps installed.
 6.2 Verify Site GN2 at LH2 Storage Area Panel pressure is > 2,000
psig using PI-10H41-GN.
 6.3 Verify Site GHE at LH2 Storage Area Panel pressure is > 1,800
psig using PI-10H39-HE.
 6.4 Verify Site GH2 at LH2 Storage Area Panel pressure is > 1,500
psig using PI-10H42-GH.

 6.5 Verify/Set E1 LH2 Storage Area MFP as follows:

 _____ Station 1 to 1,500 ｱ 50 psig

 _____ Station 2 to 1,500 ｱ 50 psig

 _____ Station 3 to 225 ｱ 10 psig
 _____ Station 4 to 20 ｱ 10 psig
 _____ Station 5 to 50 ｱ 10 psig
 _____ Station 6 to 50 ｱ 10 psig
 _____ Station 7 to 80 ｱ 5 psig
 _____ Station 8 to 300 ｱ 50 psig
 _____ Station 9 to 50 ｱ 10 psig
 _____ Station 10 to 60 ｱ 10 psig
 _____ Station 11 to 50 ｱ 10 psig
 7.0 PRETRANSFER PURGING/INERTING

 7.1 Purging and connection of trailer unloading station flex hoses

 7.1.1 Make the following announcement. Attension E-1 personnel.

LH will be transferred from LH trailers to the E-1 LH storage tank. All non-
essential personnel maintain a clearance of 100 feet from the liquid hydrogen
storage tank and trailer unloading area.� Repeat.

 7.1.2 Set the area warning light(s) to Flashing Amber.

 7.1.3 Verify Deluge Water System is in Standby.

 7.1.4 Verify LH2 Storage Area Deluge Water Isolation Valve VA-
10G32-DW is Open on East Side of Sphere.

 7.1.5 Verify the LH2 transfer crew is ready to proceed. Position

trailer and the unloading station and note which unloading station(s) are used.
 Perform Steps 7.1.6 – 7.1.24 if there is a trailer at the Trailer Unloading Station
No. 1. Else DNA.

 7.1.1 Open VA-10J34-HE, Unloading Station No. 1 GHe purge block

valve.

 7.1.2 Open VA-10B01-GH, Unloading Station No. 1 Fill Line Bleed.

Purge line for 2 minutes.

 7.1.3 Close VA-10B01-GH, Unloading Station No. 1 Fill Line Bleed.

 7.1.4 Close VA-10J34-HE, Unloading Station No. 1 GHe purge block

valve.

 7.1.5 Verify/connect grounding cable to the trailer at Trailer

Unloading Station No. 1.

 7.1.6 Open VA-10J34-HE, Unloading Station No. 1 LH2 Transfer

Line GHe purge block valve, partially to cause a slight helium flow out of the
flex hose during connection. Sniff the connection with an LEL meter prior to
disconnection for presence of hydrogen ( > 20% LEL unacceptable) in the
line. MIP

 7.1.7 Request the Truck Driver to disconnect the liquid transfer flex
hose from the holder and connect to the trailer at Trailer Unloading Station
No. 1. Maintain clean to Level 2. MIP
 Operating Procedures

 Operating Procedures May be a

Combination of Written Instructions

and

 Graphic Illustrations
Operating Procedures
Refinery Operation Flow Chart
 Operating Procedures
 Must be Developed for Each Equipment
Operation in the Covered Process

 Refer to Block Diagrams

 Refer to P&ID
 Must Cover Normal Operating Conditions,
Normal Operating Parameters, i.e..
Pressure/Flow/Current/ etc.
 Operating Procedures
 Must Follow Procedures & Recommendations
in PHA’s
 Must Follow Form

Remember the 3rd Grade Rule

“Write Clear Enough that a 3rd Grader
Could Follow the Procedure”
 Operating Procedures

 For Shut-down Procedures…Remember:

 Most operations must be shut down in a
specific order!
 Failure to follow these shut down procedures
could results in a catastrophic release or
system failure
Ammonia Plant Explosion Caused by
Improper Shut-down of Engine Room
 Operating Procedures

 Operating Limits
 Operating Limits Must
be Understood
 Pressures
 Flows
 Electrical Potential
 Tolerances
 Operating Procedures

 Team Exercise Will be Performed in the

Next Session with Safe Work Practices
 What’s Next?
Now That We’ve Completed the
Operating Procedures
We Must Develop Safety Work Practices,
Programs & Procedures for Covered
Processes