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??