L - MOC
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Transcript of L - MOC
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Management of Change
L - MoC
Effects of Change
Change alters the basic relationship betweencomponents in a system (configuration) andintroduces new modes of failure.
All changes must bemanaged to ensure thatsystem integrity is notcompromised.
Plant
People
Process
Examples of Change
• New regulations• New facilities• New procedures• New tools and equipment• Increased job scope• Altered work sequence• Replacement parts• Inexperienced workers• Inclement weather• Deteriorating materials• Organisational Change
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Potential Risks
1) Are new or unknown failure modes introduced?
2) Are existing failure modes altered as a result ofthis change?
3) Are existing controls adequate for dealing with thenew failure modes?
4) Have changes been made in the organizationalinfrastructure?
Management of Change System
System to ensure that all changes are thoroughlyscrutinized prior to implementation.
Rational basis required to initiate the process.
All changes evaluated, communicated andcoordinated prior to execution.
Applies to physical plant, chemicals, operatingconditions, staffing
Special provisions for spare parts, training, drawings etc.
Flixborough - 1974
Case History - CH11
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Case History 11-Flixborough
1974 – Nypro Caprolactam Plant, Flixborough, UK
• Large site for caprolactam production by oxidation ofcyclohexane
• Two months plus prior to incident:
- Cyclohexane leaking from Reactor No. 5
- Plant shutdown. Reactor removed for repair
• OK to run with 5 reactors, bypass installed between No’s 4 & 6
• Powerful explosion and fire killed 28, seriously injured 36
Process Description
• 6 Reactors 160 ºC, 120psig (8.3 barg) - aboveatm boiling point
• 12 ft (3.7 m) Dia x 16 ft(4.9 m) high
• Carbon steel with
stainless steel cladding• 14 in (36 cm) elevation
change between reactors
The Incident
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What Happened
• Collapse of the temporary bypass caused releaseof cyclohexane
• Main cause of failure was effects of shearforces caused by internal pressure
• 1/8 of liquid flashed off as pressure was reducedto atmospheric, the remainder was carriedupward as a dangerous spray
One Theory of Why It Happened
Sudden pressure surge caused the pipe to fail– No. 4 reactor was equipped with an agitator
– Heel of water was left in the reactor aftershutdown
– On reheating during startup, temperature rose toboiling at the hydrocarbon-water interface
– Two phases mixed and created sudden evolution ofvapor and a pressure surge strong enough to rupturethe bypass arrangement
Damage Details
– People: 28 deaths, 36 seriously injured
– Environment: Onsite & offsite contamination
– Business: Plant totally destroyed, Nyproruined
– Reputation: 1,821 houses, 167 shops damaged
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Major Lessons Learned
• All changes requirecompetent design & carefulreview.
• The report of the Court ofInquiry stated:“ There was no overall
control or planning of thedesign, construction,testing or fitting of theassembly nor was anycheck made that theoperations had been properly carried out.”
M a n a g e m e n t o f C h a n g e
Baglan Bay Ethylene Cracker Cold Box
HPSEPARATOR
35 barg LP SEPARATOR
3 barg
LEVEL CONTROL
VALVE IS HP/LP
INTERFACE
SHELL OF HEAT
EXCHANGER
DESIGNED FOR
3 barg
RELIEF VALVESET AT 3 bargPROTECTS HEAT
EXCHANGER SHELL& LP SEPARATOR
New block valve installed
HPSEPARATOR
35 barg LP SEPARATOR
3 barg
LEVEL CONTROL
VALVE CLOSED
AS NO LEVEL IN
HP SEPARATOR
NEW BLOCK
VALVE INSTALLED
AND CLOSED
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Unit starts up
HPSEPARATOR
35 barg LP SEPARATOR
3 barg
LEVEL CONTROL
VALVE OPENS AS
LEVEL BUILDS IN
HP SEPARATOR
NEW BLOCK
VALVE CLOSED
PRESSURE IN
HEAT EXCHANGER
RISES TO 35 barg
Lessons learned
P r o c e s s R i s k A s s e s s m e n t
O p e r a t i n g P r o c e d u r e s
P r o c e s s S a f e t y I n f o r m a t i o n
M a n a g e m e n t o f C h a n g e
•Process safety informationcontains process equipmentspecification data
•A simple HAZOP wouldhave predicted the outcome
•All changes requirecompetent design andCareful review
•Operating proceduresshould have requiredthe new block valve tobe LOCKED OPEN
Pre-Startup Safety Review
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Pre-Startup Safety Reviews
Equipment considerationsWhat are some of the hazards and risks?
• Cleanliness
• Service testing (hydro test, flow test)• Refractory dry out
• Purging
• Calibration of instruments• Blanketing
• Dewatering
• Process line up (valves and circuits)
Pre-Startup Safety Reviews
Procedural considerations
• All actions complete, including HAZOP
• All PSI updated
• Operating procedures written
• Training complete
• Maintenance procedures written and spareparts available
• Emergency response plans updated
•Recommendations from PHSERS, HAZOPs, etc•Design integrity maintained?•Readiness of P&IDs and other documentation•Hand-over system for project to plant control is in place
•Procedures for startup up, shutdown, normaloperation, emergency shutdown of the facilities•Safe work practices procedures•Facility staffing adequate for startup?•Competencies and skills for safe operation•Punch listing is in place and that all high priorityitems have been completed•Loop Checks and Trip Checks completed?
Pre-Startup PHSSER: Key Activities
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Pre-Start Safety Review??