Title Slide. Nigel James March 2016

Transcription

1 Title Slide Nigel James March 2016

2 Discussion Topics: Safety Burrow Global Update Challenges to PSM / SIS compliance Confusion of S-84 and RAGAGEP Best Practices - SLM Q/A

3 Burrow Global Business Model

4 Burrow Global Locations Angleton, Texas Houston, Texas Beaumont, Texas Lake Charles, Louisiana Baton Rouge, Louisiana Deer Park, Texas Crystal City, Texas

5 Automation Business Model

6 Vendor Selection FELs Estimating/Cost Analysis PSM Compliance Support Integration Testing Cutover Commissioning Application Training Operational Optimization Automation Program Pillars Control System Lifecycle Planning Project Execution

7 Successful Project history from TEAM Have worked directly with OSHA we understand what they are looking for Have presented several papers on tips and tricks in implementing SLM in ISA safety symposium SLM/SIS GAP closure with major refinery - $15MM Developed the SLM now world wide standard Developed IPL assessment criteria Developed RAGAGEP protocol OSHA verification - $1MM Validation of random 10% of LOPA and SIFs for large refinery Directly reports to OSHA Area director Large Chemical company SIS Gap closure - $3MM SIL gap closure IPL validation SRS preparation Develop SLM program and GAP assessment for numerous chemical facilities Instructor for HIPPS workshops at TAMU instrument symposium Numerous SIS projects (our bread and butter)

8 Are you a Safety Hypocrite? $30 device Vs $10,000 F&G System 8

9 Challenges to PSM SIS/SLM Compliance

10 Acronyms SIS Safety Instrumented System SIF Safety Instrumented Function SIL Safety Integrity Level SLC Safety Life Cycle SLM Safety Life Cycle Manual LOPA Layer of Protection Analysis IPL Independent Protection Layer SFF Safe Failure Fraction PFD Probability of Failure on Demand HIPPS High Integrity Pressure Protection System ESD Emergency Shutdown System PHA Process Hazards Analysis BPCS Basic Process Control System HAZOP Hazard and Operability Study 4/26/

11 PSM Model four core pillars for engineering PSM Model SIS and RV have very similar characteristics PSM/SIS/SLM PSM/P&ID PSM / Relief Valves PSM / PSV Engineering Execution

12 Challenges to PSM compliance Not understanding the regulations Gathering of base data is an effort in itself Difference of opinions of subject matter experts No clear consistent way to implement key engineering activities Lots of discovery up front Information overload and no existing systems

13 Jeopardy Question 100 pts Answer What happens when you put 20 Subject Matter Experts in a room and you get 50 different opinions Question What is RAGAGEP? 13

14 Industry Challenges Lack of a consistent SLM manual need clear roles and responsibilities LOPA consistency can t extract the IPL s quickly and cleanly Too many IPL s Too conservative of an approach has over engineered the solution. No single view into the IPL Registry Excel, Access, or Software solution SRS too big, too long, too expensive SIL Calcs spend too much time on an order on magnitude number. No what-if exercises Major documentation GAPS. Low bearing of FSA and FAT/SAT documents Operating procedures too long (thus too expensive and not sustainable). Not enough operator input Poor testing record work processes. Make the testing unsustainable

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16 The What Develop a Safety Lifecycle Management program for SIS systems. Ensuring SIS systems are OSHA RAGAGEP compliant. Use S-84 as a primary guideline for the RAGAGEP basis but not the only guideline. Document who does what.

17 OSHA Process Safety Management of Highly Hazardous Chemicals Process Safety Information (d)(3)(iii) For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested and operating in a safe manner Operating Procedures (f) Training and Training Documentation (g) Pre-Startup Safety Reviews (PSSR) (i) Mechanical Integrity (j) Inspection and Testing Requirements Maintenance Training Test Frequency Management of Change (MOC) (l) Compliance Audits (o) Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) (d)(3)(ii)

18 What is RAGAGEP? The Process Safety Management (PSM) of Highly Hazardous Chemicals (HHC's) standard, 29 CFR is intended to prevent or minimize the consequences of a catastrophic release of toxic, reactive, flammable or explosive HHC's from a process. Specifically, OSHA 29 CFR (D) (3) (ii) states: The employer shall document that equipment complies with recognized and generally accepted good engineering practices. EPA Risk Management Program (RMP) also refers to RAGAGEP in 40 CFR 68.73: Inspection and testing procedures shall follow recognized and generally accepted good engineering practices. Therefore, RAGAGEPs are engineering, operation, and maintenance activities based on established codes, standards, and recommended practices. Such a practice establishes engineering performance criteria based on these established codes, standards, and recommended practices. It is a benchmark against which performance can be judged. However, without a specific engineering expectation, this is still too vague. Per OSHA Fact Sheet (10/12/2010) RAGAGEPs are voluntary guidelines often produced by organizations specializing in producing industry standard documents. Examples of RAGAGEP producing entities include the National Fire Protection Association (NFPA), and the American Petroleum Institute (API). The PSM standard requires employers covered under the standard to comply with RAGAGEPs. 18

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20 How does S-84 Fit? Regulation and Standards move from a Prescriptive to a Performance basis OSHA Process Safety Management of Highly Hazardous Chemicals IEC (International Electrotechnical Commission) Recognized as world standard on Safety Instrumented Systems 1996 ISA (Instrument Society of America) issued standard S84 Application of Safety Instrumented Systems for the Process Industries Then adopted by ANSI now replaced by ANSI / ISA S Achieve performance thru analysis of hazards and protection using tools such as LOPA Contains a grandfather clause not part of IEC61511 for existing equipment Specifies aspects of a Safety Lifecycle for covered systems OSHA linkage

21 Normative vs Informative?? In a Standard Interpretation Letter issued November 25th, 2005, the Director of the DEP, Richard Fairfax, supports this: With respect to SIS, OSHA does not specify or benchmark S84.01 as the only recognized and generally accepted good engineering practices. There are two terms used in industry that are critical for adherence to requirements. The terms are informative and normative. The definitions are: Normative text is that which describes the scope of the document, and sets out provisions. Any text related to meeting requirements is considered normative. Informative text is that which provides additional information intended to assist the understanding or use of the document. Informative text is not related to meeting requirements. However, OSHA, in its enforcement of the PSM regulation, reserves its right to pursue a broader interpretation of RAGAGEP which may include materials designated herein as Informative. The Normative standards and codes listed in 1.1 above may include both normative and informative text. (e.g. a federal register notice includes the normative rule but may also have a preamble with informative text.) 21

22 S-84 Summary

23 Challenges of using S-84 Need a cost effective list of questions for both design and verification. Needs to be organized for the application. Needs to be appropriate for the need S-84 parts 1-3 TR-84 parts 1-4 Number of sections Clause referencing "shall" Number of "shalls" Totals

24 Best Practices

25 Don t Overengineerit 25

26 Don t under Verify it 26

27 Forest for the Trees If the policies are so complex yet don t improve safety, we have missed the point. It must be simple and sustainable 27

28 First Step get SLM! Write your Safety Lifecycle Management (SLM) Manual Key sections 1. Staffing / Competency 2. HAZOP/LOPA 3. Design 1. SRS 4. Installation / Validation 1. FSA 2. FAT/SAT 5. Operations/ Maintenance 1. Proof Test Procedures 2. Training 6. Auditing 7. MOC 28

29 Policies and Procedures Objective Develop a single roadmap document to navigate (80% complete) Modify existing procedures to align to the umbrella document Develop new supporting procedures (SRS design, PTP process) Develop deliverables list of existing documents that will require updating Develop functional forms and checklists to review and validate the process defined in the above procedures Compile all documents into a single binder/manual

30 Document Roadmap EXAMPLE ONLY

31 S-84 Workflow with Swim Lanes Hazard Analysis Conceptual Design Detail Design Validation Operations Verification PSM PHA LOPA Audit SIS/SME IPL Assessment FSA Failure/Demand Engineering FEL-3 Detailed engineering FAT/Sat Operations PSSR Maintenance Training PTP s

32 Design Phase of Project Use Inherent Safe Design Principles (KIS) Search out relevant Standards and Codes Get SIS Team involved (earlier the better) Answer Questions for Safety Requirement Specification (SRS) Verify Design from a Safety standpoint Document and Clarify

33 Estimate and Bid Phase of Project Find out if a PHA has been done? Find out if a LOPA has been done? What are the clients Constraints and Guidelines? Make sure client is aware of Safety Requirements. Get SIS Team involved (earlier the better). Document and Clarify.

34 Document List A consistent list / evidence of work performed

35 Step 2 - Setting a Performance Criteria List the known publish standards and practices. (1 st level) [Normative] Identify key engineering activities that require interpretation. (2 nd level) [Informative] Provide 1-3 key examples of engineering outputs that can be referred to. (3 rd level) [Informative] Verify the 3 examples either validate a single practice or identify a range of applications to discuss which example is the right fit for the site. We are looking for either Complementary (reinforces) or Contradictory methodologies. The verifiers will evaluate based on their professional judgment, documented standards and will compare to the corporate standard. 35

36 Example Risk Matrix / RRF Normative S-84 Clause 9 (13 Shalls) Key Points: To allocated the safety functions to protection layers Determine the required SIFS Determine for each SIF a target SIL Key Engineering Activity Following a proper LOPA process / Have a proper risk Matrix Having a key list of layers of protection Using the right RRF number Questions? Consequence Tables/Risk Matrix Consequence Tables Example / CCPS [Pink book], pg19 (Consequence Categorization) & Page 23 (Risk Matrix with Individual Action Zones), Risk Matrix Example / Safety Instrumented Systems (Gruhn), pgs 90 and 91 Consequence Tables, Risk Matrix Example / Example from OSHA Standards Interpretations, pgs 3-4 Verify IPL RRF Values Example of Passive & Active Typical IPL Values / CCPS [Pink book], pg92 and 96 Typical IPL Credits / Modifying LOPA for Improved Performance (Young), pg 2-3 Example Values of RRFs / CCPS [Green book], pg278 and

37 Example -SRS Normative S-84 Clause 10 Only 6 shalls has 27 components of one shall Key Points: Express the SIS requirements in a clear, precise, verifiable, maintainable, feasible, and understandable Key Engineering Activity Document IO requirements (Hardware design) Functional Logic (Software design) SIL of each function (SIL calcs) Questions? Where do I go to ensure I am doing the SIL calc right What software is considered effective? SIS Safety Requirements Specification / ISA-TR Part 1 Technical Report pg 61, clause 10 and Checklist No. 2 pg SIS Design and Engineering / Safety Instrumented Systems (Gruhn), paragraphs and pgs 26-27, section 2, checklist pg

38 Example Operate / Maintain Normative S-84 Clause 16 (23 shalls) x Key Points: Ensure each SIL is maintained for the SIF Key Engineering Activity Proof Testing Procedures Procedures Operating and Maintenance Training for Operators and Maintenance Questions? x? Operations / ISA-TR Part 1, Technical Report Checklist No.8 pgs Operations & Maintenance / Safety Instrumented Systems (Gruhn), checklist pgs Procedures / CCPS [Green book], paragraphs pgs

39 The Elephant in the Room What level of questions should be asked to be considered comprehensive (hence compliant) yet Cost Effective. Audit protocol purpose scope and guidance will decide Staffing, timing and intent. 39

40 PSM Compliance Phases SLM Manual LOPA Validation IPL Assessment Documentation Deficiency Resolution LOPA Gap Analysis IPL Design for Gap Closure 4/26/

41 Summary Conceptual Process Design Use Inherent Safe Design principles (KIS) Search out relevant Standards and Codes Develop Project Description Get SIS Team involved (earlier the better) PHA Identify Hazards (Gaps) LOPA Identify Existing IPLs to minimize Gaps Develop SIF to Prevent Hazards of the Gaps Remaining Identify SIL Rating Conceptual Design Identify Scope SIL Verification Verify that Design meets criteria (SIL Rating) efficiently Design Specifications Safety Requirement Specification

42 Remember it is a program! (PHASED approach) 4/26/