NOTE. These documents are intended only to supplement and not to replace the prevailing statutory requirements.

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2 NOTE OIL INDUSTRY SAFETY DIRECTORATE (OISD) publications are prepared for use in the Petroleum and Natural Gas industry under Ministry of Petroleum & Natural Gas. These are the property of Ministry of Petroleum & Natural Gas, and shall not be reproduced or copied and loaned or exhibited to others without written consent from OISD. Though every effort has been made to assure the accuracy and reliability of the information contained in these documents, OISD hereby expressly disclaims any liability or responsibility for loss or damage resulting from their use. These documents are intended only to supplement and not to replace the prevailing statutory requirements. ii

3 FOREWORD The oil industry in India is over 100 years old. Variety of practices have been in vogue because of collaboration / association with different foreign companies and governments. Standardisation in design philosophies and operating and maintenance practices at a national level was hardly in existence. This coupled with feedback from some serious accidents that occurred in the recent past in India and abroad, emphasised the need for the industry to review the existing state of art in designing, operating and maintaining oil and gas installations. With this in view, Oil Industry Safety Directorate (OISD) was established in 1986 staffed from within the industry for formulating and implementing a series of self regulatory measures aimed at removing obsolescence, standardising and upgrading the existing standards to ensure safer operations. OISD constituted a number of committees comprising of experts nominated from the industry to draw up standards and guidelines on various areas of concern. The present document on Guidelines on Management of Change for Petroleum Refineries & Oil/Gas processing plants is prepared by the Committee on Management of Change. This document is based on the accumulated knowledge and experience of industry members and various national and international codes and practices. It is hoped that the provision of this document, if implemented objectively will go a long way in improving the safety in the hydrocarbon processing industry. This guidelines in no way supersedes the statutory regulations and requirements of various statutory bodies, which shall be followed as applicable. This document will be reviewed periodically for improvements based on the new experiences and better understanding. Suggestions from users/industry members may be addressed to: The Co-ordinator Committee on Management of Change OIL INDUSTRY SAFETY DIRECTORATE 7 TH FLOOR, NEW DELHI HOUSE 27, BARAKHAMBA ROAD NEW DELHI iii

4 COMMITTEE ON MANAGEMENT OF CHANGE Members Representing S/Shri 1. G. C. Mitra Indian Oil Corporation Limited Leader 2. R. D. Goyal Gas Authority of India Limited Member 3. V. Narayanan Madras Refineries Limited Member 4. K. Madhusudan Cochin Refineries Limited Member 5. M. S. Rathod Hindustan Petroleum Corporation Ltd. Member 6. N.D. Raut Bharat Petroleum Corporation Limited Member 7. N. Rengaswamy Enginers India Limited Member 8. S. K. Sinha Oil &Natural Gas Corporation Ltd. Member 9. A. Ghatak Oil Industry Safety Directorate (Member Co-ordinator) In addition to the above, several other experts from industry contributed in the preparation, review and finalisation of the document. iv

5 GUIDELINES ON MANAGEMENT OF CHANGE C O N T E N T S SECTION PAGE NO. 1.0 Introduction Scope Definitions Types of Changes Procedure to implement Changes Changes due to Modification of Plant/Facilities Additional checks for changes in Normal Operating Procedure,Start-up,Shutdown and Emergency 8 Procedures. 5.3 Additional Checks for introduction of new Catalyst, 9 Additive,Corrosion Control Agents etc. 5.4 Additional checks for changes in Solvents in the 10 Extraction Process. 5.5 Additional checks for Carrying out changes of Logic 10 of Interlocks, Set Point, and Process Conditions 5.6 Additional checks for carrying out Changes of Software Changes of Personnel Additional checks for any Other Changes requiring 12 Orginal Design Review including Service Change. 6.0 References Annexure I 13 v

6 1.0 INTRODUCTION A process industry is subjected to continuous modifications to achieve higher efficiency, improve operability and safety, improve reliability, improvement of the plant machineries and equipment and to accommodate technical change. Any changes in the processing units/ facilities may have the potential to destabilise existing safety and to introduce new hazards. The hazards connected with any change are to be identified and controlled efficiently through an appropriate hazard management system. These guidelines lay down procedures covering various aspects of change and addresses the following : - Minimise the mishaps caused due to non-compliance of procedures. - Improve optimisation and utilisation of facilities. - Decrease downtime. - Increase favourable public opinion. - Increase knowledge of plants and process activities. 2.0 SCOPE These guidelines describes the management of procedures to be adopted for systemic - change of process / technologies, - change of hardware excluding replacements (of same specification and kind), - change of software, - changes of personnel, - change of chemicals and - change of catalysts, - change of operating procedures, - change in working environment. 3.0 DEFINITIONS 3.1 Petroleum Refinery Petroleum Refinery is a plant where crude oil is received and processed to produce various intermediates and finished products. 1

7 3.2 Oil/Gas Processing Plant Oil/Gas Processing Plant is a plant where crude oil/natural gas is collected and processed in order to separate oil and gas and to remove impurities like water, sulphur etc. before sending them to refinery or to obtain end products. 3.3 Facility Facility means the buildings, containers or equipment including pipeline operation which contain a process. 3.4 Process Process means any activity involving a hazardous chemical and utilities including use, storage, manufacturing, handling and the on-site movement of such chemicals and utilities or combination of these activities. (These include pipeline operation also). 3.5 Process Hazard Analysis (PHA) It is the application of one or more analytical techniques that aid in identifying and evaluating a process hazard. 4.0 TYPES OF CHANGES IN WORKING ENVIRONMENT The need for change arises out of various reasons like operational flexibility, energy conservation, capacity augmentation, improvement of product specification, yield improvement, compliance with statutory rules and regulations. The various types of changes that take place in a process unit and related facilities are detailed below. i) Equipment changes like addition, alteration or removal of an equipment or a part of it from the plant. ii) iii) iv) Modifications in piping system and process equipment, replacement of equipment or machinery that differs from the original equipment. Change in metallurgy. Change in normal operating procedure, start-up, shut down and emergency handling procedures. 2

8 v) Introduction of new catalysts, additives, corrosion agents, solvents in extraction processes etc. vi) vii) viii) ix) Change in instrument which may include pressure, temperatures, flow, set points, alarm points, speed, logic and control parameters. Mechanical process or instrument system changes made to increase production rates. Change of software in a computerised environment. Introduction of operation or maintenance personnel who are new in respect of the process. x) Any other change requiring original design review including service change and changing pipeline scrapper station / delivery station to pumping or pumping and storage tank station. 5.0 PROCEDURES TO IMPLEMENT CHANGES 5.1 CHANGES DUE TO MODIFICATION OF PLANT/FACILITIES The procedure for implementing modification shall be flexible to include both major or minor modifications. There should be a formal procedure which requires all modifications to be authorised by competent persons and a standard method of making the safety assessment. There should also be a system of inspection of modifications by a competent person to make sure the work has been done as intended and is complete. The competent persons shall be nominated and notified by the management of respective organisations / units. Implementation of any modification / change shall not be done without the formal approval of the said competent persons. There should be a system of documentation to record the change and there should be adequate training so that all personnel concerned understood the system of control. In general, any modification shall cover the following as minimum : i) Origination of modification proposal. ii) iii) iv) Design philosophy. Scrutiny and approval procedure / safety assessment. Execution of the modification job. v) Training of the operating / maintenance personnel on proposed modification. 3

9 vi) Commissioning. vii) viii) ix) Updating of documents in line with the modification. Approved handing over / taking over procedure. Post commissioning review. x) As built record. i) Origination of Modification Proposal Process plants and facilities requires continuous updation to increase efficiency, improve operability and safety. It is appropriate that the proposed modification is considered critically. The following three queries shall always be answered before finalising any proposal : - Is it necessary? - Is it economic? There is a possibility of introduction of new hazards as the safeguard s built in original design are changed. The modification proposal should therefore achieve primary objective in a safe manner. Therefore, the following questions are to be considered : - How will the change impact the people and the work environment? - Will people be able to construct / implement and operate "the change" and work with "the change" within an acceptable level of risk? - How will "the change" impact inspection & maintenance activities? - Is "the change" going to adversely affect excess / ingress for operation, inspection, maintenance, emergencies etc. Is there a better alternative? This necessitates the following to be checked before finalising any such modification proposal : a) The technical basis for the proposed change. b) Impact of change on safety, health and working environment. c) Modification to operating procedures. d) Authorisation requirements by the competent persons nominated and notified by the management for the proposed change. 4

10 ii) Design Philosophy The design philosophy shall include both process design information and mechanical design information. The process design information should include a block flow diagram or a simplified process flow diagram, the process chemistry with relief system and where process design material and energy balances are available, this should also be included. The process design information should also take into consideration environmental requirements like safety, health and environment review to ensure compliance with respect to safety, health and environment. The mechanical design information should include materials of construction, piping and instrumentation diagram (P&ID), area classification, design codes and standards employed and equipment and piping specifications. The mechanical design shall be consistent with the applicable consensus codes and standards in effect at the time the design is prepared, or in the absence of such codes and standards, recognised and generally accepted standard engineering practices. Where the original mechanical design information no longer exists, information may be developed from available equipment and inspection records. The provision of design and engineering practice manual and applicable codes and standards shall be followed while carrying out any modification. Applicable statutory requirement shall also be considered while firming up the design philosophy. Ergonomics to be well taken care of during the design stage of modification / change. iii) Scrutiny/Approval Procedure Design shall be completed in two stages. In the first stage, Basic design shall be completed and in the second stage detail engineering shall be completed. Second stage shall be taken up only after verification of first stage design. Design shall be verified after completion of the first stage to confirm the following. - Basic design meets the requirement of the proposal, 5

11 - Design is safe for expected conditions of use, environment and also unintended uses and misuses. - The above shall be confirmed with detailed process hazard analysis. - Compliance of the standards with regulatory requirements, national and international standards, and corporate practices. - Review made by internal and external agency on the problems faced from similar nature of design. Verification after second stage shall confirm the following: - Detail engineering has been carried out as per the requirement of the modification. - It meets the requirement of reliability, serviceability, maintainability and safety as per national and international standards. - There will be least problem in fabrication, installation, erection, assembly and availability of spare parts and consumable items. - Design shall be checked for fail safe characteristic - Ensure modified system / changed system shall not exceed design limitations of the existing relief system. - Aesthetic specification shall also to be met. - Standard materials comparable with existing plant materials are only specified to the extent possible. The system of approval by competent persons at various stages to be fixed by the individual organisations. However, the names of the competent persons shall be nominated and notified by the management of each organisation / unit. iv) Execution of the Modification Job Procedures Modification shall be taken up for implementation only after availabilityof Approved for Construction documents and materials as per the bill of materials and approval of statutory authority for the modification wherever applicable. 6

12 v) Training of the Operating/ Maintenance Personnel on Proposed Modification The operating and maintenance personnel who are responsible for operating and maintaining the plant/facility shall be trained on the possible impact of the modification. This training should include safe practices to be adopted after the proposed modification. Contract employees whose job tasks will be affected by the change in the process shall be informed of and trained in proposed changes prior to the start-up of the process. The plant manager or his authorised person to brief and train the contractor personnel who will be associated with this change. vi) Commissioning Plants/facilities shall be commissioned after the job carried out is cleared by multidisciplinary group approved by management and completion certificate is available. Licence from statutory authority, wherever applicable, is obtained. vii) Updating of Documents in line with Modifications Design basis, assumptions and important points of design, bill of materials shall be provided in the design document. The operating and maintenance manuals are required to be reviewed in line with the modifications. Changes if any need to be incorporated prior to the commissioning of the plant/facility. The Layouts, P&IDs, utility drawings, loop / one line drawings, emergency response plan and PFDs are also to be updated to incorporate changes arising out of the modification. Necessary updation of disaster management plan to be carried out for the proposed modification viii) Handing Over and Taking Over procedure There should be a transparent handing over procedure by the executing departments/agencies to the operating department/agencies. This should include transfer of Facilities, Hardware, Manuals, Drawings etc. Similarly department/agencies taking over the facilities should also have a procedure for the same. ix) Post Commissioning Review: After commissioning of the new/modified facility, safety check-list to be prepared in view of modification / change before conducting any test run for evaluating the modified facility. Subsequently, a test run shall be 7

13 conducted to evaluate whether the modification have achieved its desired objective or not. The results of such test run shall be recorded. x) As-built Records All modification records generated from the proposal stage to commissioning stage including design review, construction documents statutory approval shall be preserved in approved and accepted locations for quick references. As-built documents shall be prepared incorporating all the approved site changes. 5.2 ADDITIONAL CHECKS FOR CHANGE IN NORMAL OPERATING PROCEDURE, START-UP, SHUTDOWN AND EMERGENCY HANDLING PROCEDURE The design of the plant specifies the conditions at which it is to operate. Any change, major or minor in technology, facilities, plant modification etc. has the potential for disruption. Change in normal operating procedure, start-up, shutdown and emergency handling procedure resulting from any modification /change as mentioned above needs careful consideration to identify incorrect assumptions, to resolve differences and to eliminate inconsistencies. The ultimate responsibility for the operating procedures rest with the plant manager. (The modifications made during the original design process really fall outside the discussions which is mainly concerned with the stages of commissioning and operation). To support operator s performance a written operating procedure shall be provided for safe operation of the plant. The operating procedure shall include the changes/ modifications that plant has undergone and specify sets of conditions within which the plant shall operate and sets of variations which are allowed and in certain cases the variations beyond a limit are not allowed/permitted. At any given time, the operational envelope should be clearly defined and strictly enforced. The plant manager shall develop and implement written operating procedure that provide clear instructions for safely conducting activities involved in each process consistent with the process safety information and shall address at least the following. a) Steps for each Operating Phase i) Initial Start-up ii) Normal Operation iii) Need based Operation iv) Emergency Operations including Emergency Shutdown and Start-up 8

14 v) Normal Shutdown vi) Start-up following a turnaround vii) Start-up after prolonged outage viii) Process Flow Schemes. b) Operating Limits i) The consequence of deviations ii) Steps required to correct or avoid deviation iii) Safety systems and their functions/fail safe position c) Clear instruction for safe operation of each facility that consistent with the process safety information. d) The occupational safety, health and environment considerations including the following: i) The properties and hazards presented by the materials needed in the process. ii) iii) The special precautions required to prevent exposure including engineering controls, administrative controls and personal protective equipment. The control measures to be taken if physical contact or air borne exposure occurs. 5.3 ADDITIONAL CHECKS FOR INTRODUCTION OF NEW CATALYST, ADDITIVE, CORROSION CONTROL AGENTS ETC. Change in catalyst /additives, corrosion control agents is normally done in case of change in process or mechanical design is altered or to accommodate technical innovation, increase in efficiency & cost benefits. A written procedure shall be provided with clear instruction for safety handling of each items and shall address at least the following: i) Handling procedure of catalysts, additives, corrosion control agent. ii) Effect of use of these catalysts, additives, corrosion control agents on process safety, if any. 9

15 iii) iv) Specifications & inventories critical to process safety. Quality control procedure to ensure the use of catalyst, additives, corrosion control agents meet the specification for use. v) Material safety data sheets. vi) Procedure for Catalyst regeneration and disposal of spent catalysts 5.4 ADDITIONAL CHECKS FOR CHANGE IN SOLVENTS IN EXTRACTION PROCESSES. Change of solvents in extraction process is normally done during upgradation of process technology, reduce toxicity, statutory / mandatory requirement, pollution control, cost control, new innovations or for any other reason best suited for a particular process. A written procedure shall be provided for safe handling of the changed new solvent and the procedure shall also address at least the following items: Safe Handling and Storage Procedure Process Safety Information Toxicity of the solvent used in IDLH ( Concentration at which irreversible affects on health could be expected. Material safety data sheets. 5.5 ADDITIONAL CHECKS FOR CARRYING OUT CHANGES OF LOGIC OF INTERLOCKS SET POINT AND PROCESS CONDITIONS A number of modification/addition/alteration are made in existing facilities in the refinery in the logic of interlocks, set points and process conditions. The following procedure in addition to earlier stated standard procedure 5.1 shall be adopted whenever modification/alteration/addition is proposed in existing logic. a) Instrumentation & Process Engineering shall check the existing ladder diagram whether the intended change can be incorporated. 10

16 b) A group of engineers from Process Engineering, Operation, Maintenance Instrumentation & Safety Department shall conduct HAZOP study of the scheme prepared for the changes. c) For incorporating the modification in logic, the group must study whether it can be incorporated in running plant or the plant has to be shutdown. If shutdown of the plant is necessary the downtime loss and pay back period after modification shall be studied. d) To change the set point of the alarm & trips the group must take into consideration of the existing process variable whether it can e) accommodate the change or not, like if the set point of tripping of high discharge pressure of a compressor is changed to higher one, the discharge of the PSV must be taken into consideration. f) After taking into consideration the HAZOP study recommendation, the scheme shall be approved by the competent person. Based on the approved scheme, detailed engineering drawing shall be prepared. The drawing shall then be approved by the competent authority. g) The changes shall be incorporated in the ladder diagram, operating manual once the jobs are executed. The updated records shall be preserved for reference in approved and accepted locations. 5.6 ADDITIONAL CHECKS FOR CARRYING OUT CHANGES OF SOFTWARE a) The compatibility of new software with the existing computer environment shall be checked and approved. b) The software shall be checked offline to ensure that it does not introduce any new bugs. c) After it has been found to function satisfactorily as certified by all concerned department then only it shall be loaded for normal use. d) Training of all concerned personnel who will be operating the software shall be completed before introducing the new software. 5.7 CHANGE OF PERSONNEL Introduction of personnel who is new to the process may introduce new hazards. Therefore each employee before being involved in operating newly assigned 11

17 process shall be trained in an overview of the process and in the operating procedures. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, safe work practices applicable to employees job task. The employer shall ascertain that each employee involved in operating a process has received and understood the required training. A record shall be prepared containing the identity of the employee, date of training and the means used to verify that the employee understood the training. 5.8 ADDITIONAL CHECKS FOR ANY OTHER CHANGES REQUIRING ORIGINAL DESIGN REVIEW INCLUDING SERVICE CHANGE a) Importance of maintaining the integrity of the plant and of avoiding degradation due to process modifications can not be overlooked. Process modifications may be in the form of change in the process parameters of a hydrocarbon producing well due to exploration from previously non-tested horizon, increase in throughput, change in specification of finished products, changes in instrument system involving major measurement signals and/or de-rating of the equipment to allow pressure warranted due to health deterioration etc. The existing system can be put at risk by the operation of the process outside the domain of operating conditions for which the system was originally designed. These changes will call for consideration of the relevant codes of practice and specifications. It may affect any existing trip or alarm system and may require additional trip and alarm protection. Further these process changes will be capable of effecting originally designed /existing operating and maintenance procedure, equipment inspection frequency or may require altogether a new procedure even the composition of effluent and its disposal has to be looked into. One thing which may not go any major changes will be the hardware available within the system as the design review has to be carried out to check the suitability of originally designed and constructed system for the changed process requirement. b) Changes in Services of Equipment The service of process equipment sometimes require change for example class B petroleum product tank changes to class A petroleum service. In such cases changed service requirement shall be studied with respect to 12

18 6.0 REFERENCES earlier condition. Change of facility and Change in Procedure if needed shall be persued as detailed in para 5.1 and 5.2. i) Loss prevention in process Industries, By F. P. Lees. ii) Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents; Final Rule OSHA, USA 13

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