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storage tank which store and handle large quantities of ammonia imported for fertilizer
manufacturing.
Industrial accidents remain a major concern before the Governments consequent to the loss
of lives, damage to property and environment that is inflicted on the society besides upsets in
tranquil and a heavy economic strain. Along with the growth of the processing industry, the
problem of accidents caused in the industry poses a big question with its regional and global
implications and efforts are also underway to minimize the damages and ensure all safer
working environments around industrial installations.
caused in the industry over and again caution us that the price of process safety is
increasingly becoming a concern on the profitability of the unit, morale of its employees and
the public image of the institution. Still, the growth and development of the processing
industry is not deterred by occasional mishaps. At the same time these lessons from past
industrial accidents urge industry
standards and enhance pubic perception of the industry. Incidents like Flixborough, Sevaso,
Bhopal, Chernobyl, North Sea and recently Toulouse etc have taught us where do we stand
with regard to achieving an accident free operating environment in the chemical processing
industry, which direction we are to go,
and
Everywhere and especially in the matter of process safety, Murphys Law holds good and it
also provide the impetus for continuous research and improvement to unearth , identify and
overcome the hidden and the unknown through a process of elimination.
Key Words: hazard, risk, ammonia
The safety and environmental concerns are often shared by public interest groups, which lead
to outcries, litigations and in certain cases even closure of units. The loss to the society on
account of such closures is enormous and thus it is in the interest of the industry and the
community that dialogues to address the conflict between them are always maintained. This
prescription, though looks simple, is difficult to practice in the real operating environment of
the industry. More often, a cultural change is needed to understand and effectively address
the communitys rights to know and Governments concern on public health and safety.
Efforts are to be organized from the side of the industries to empower the public understand
what is happening with in the processing facilities and effectively communicate the risk from
such operations. Major industries have a specific role in this regard in building public
understanding as a first step to enhancing public confidence and build a better community
perception on the industry. At the State level, there shall be efforts to organize effective
mechanisms to ensure public safety through well-defined policy prescription and legislation.
In the past 20 years since Bhopal, there is an increasing concern and resurgence of public
interest in the matter and so also the efforts to address them have increased considerably.
Major contributory factors to accidental releases in the hydrocarbon chemical industries are
mechanical failures and operator error. Today, industries use a predictive maintenance
strategy based on condition monitoring of equipment to overcome the shortcomings of
preventive maintenance. It is also possible to most satisfactorily assess the integrity of
equipment and structures with the help of modern inspection tools and methods and predict
likely failure situations well in advance to enable them to take effective remedial action. A
recent development in ultrasonic technology with its patented equipment and technology
eliminates the use of hazardous chemicals associated with radiographic examination
commonly used for flaw detection. Better training, simplified procedures and work practices
and a ready access to vital information help to reduce human error and enable the operator to
spot exact locations in the plant where problems are likely to crop up and take corrective
actions before the situation go out of control. Thus with the currently available technology
and skill it is possible to operate and maintain hazardous installations with a very high degree
of safety and environmental protection standards.
The following case study illustrates the success of the above approach.
The Willington Island Ammonia Import Terminal belonging to the major fertilizer producer
and Govt Company, Fertilizers And Chemicals Travancore (FACT) Ltd came under suspicion
that it posed a serious threat to safety the local community of Cochin. A Public Interest
Litigation (PIL) initiated by a local NGO before the High Court.
The facts came under judicial scrutiny are
In the case of a catastrophic accident to the storage tank resulting in a major crack or
rupture it would lead to disastrous and devastating consequences of annihilating all
living beings inverting the city of Cochin a city of dead and nearby places a morbid
graveyard.
The catastrophic failure of the tank is not an unreal or remote possibility but a credible
and contingent possibility to be reasonably anticipated on the facts unfolded in the
case.
Though the catastrophic event is only a possibility and when it would happen is
unpredictable it is unwise to forget or slur it. Once it happens it is irreversible so
prudence dictates not complaisance, but positive action.
Netherlands. They suggested certain measures to avoid normal deterioration of the tank while
in service FACT implemented their recommendations and the tank was serviced back to
operation.
The tank is insulated by poly urethane foam and bottom of the tank by poly styrene foam
board. The tank is protected against over pressure and vacuum by two relief/vacuum valves.
Other associated facilities included two large capacity refrigeration compressors (for use
during tank loading), two pressure holding compressors (one driven by motor and the other
diesel engine), a diesel generation set to take care of power failure situations, three pumps for
loading rail wagons and barges, three sets of wagon loading and one set og barge loading
arms, connected piping, cooling tower, instruments and a flare system.
Liquid ammonia at -33 deg C is moved in rail wagons to the plant. The tank terminal is a self
contained facility with provisions for emergency supplies and is guarded round the clock by
security personnel. It was operated and maintained by competent personnel with all
mandatory inspections, tests and certifications.
Based on its finding that the catastrophic failure of the tank is not a remote possibility, but a
credible and contingent possibility to be reasonably anticipated on the facts unfolded in the
case, the High Court
ordered to decommission, empty and close down operations of the installation.
Against the verdict FACT appealed to the Supreme Court of India for reconsidering the case.
The Supreme Court appointed Engineers India Limited (EIL), a consulting group of
international repute to re-examine the issues and submit a report.
Following the Supreme Court directive, EIL conducted extensive inspection and tests to
ascertain the present condition of the tank. It included
1). Visual examination
2). Non-Destructive Test (NDT) methods such as Schmidt Hammer test (as per IS
13311 Part II) on piles, beams and slabs to assess strength of concrete
3). Ultrasonic Pulse Velocity Test to assess condition of structures as cracks, voids etc.
4). Carbonation Test for assessing alkaline protection of reinforcement steel
5). Test of Compressive strength for concrete (IS 456:2000)
6). Half-Cell Potentiometer Test to assess corrosion of steel reinforcements and
7). Chemical analysis of soil samples.
From the above analysis EIL inferred that the foundation of the tank is in a sound condition.
EIL also evaluated the heath and integrity of the tank through visual inspection and with the
help of a series on NDT methods.
These methods involved use of
1). Wet Fluorescent Magnetic Particle Testing (WFMPT) to ensure that weld joints are
free from cracks and discontinuities,
2). Liquid Penetrant Testing (LPT) for weld joints in the annular area not accessible
to WFMPT 3). Ultrasonic thickness measurement (UTT) of shell, plates, piping,
nozzles,
4). Ultrasonic flaw detection (UFD) to detect sub surface defects in T joints of shell
plates of inner cup,
5). Hardness testing of weld heat affected zones to know degradation of parent
material,
Additionally containment of the spill and hence boil off rate will reduce the distance of the
cloud travel and hence the risk to the local population. Comprehensive inspection , testing and
maintenance routines will also help in minimizing likelihood of any failure leading to the
release of ammonia and therefore these procedures should continue to be carried out on a
regular schedule with periodic review of maintenance frequencies. Following the report the
recommendations were implemented by FACT.
CWL concluded that the management and organization structure appears to be well balanced
and efficient with good back up from the technical services, maintenance and inspection
groups. Due to the sensitive siting of the tank the management have taken every effort to
ensure the integrity of the facility is not undermined and that it is operated by well trained,
competent staff Everyone interviewed at ite had a good working knowledge of the plant and
how to react in an emergency situation. All senior operations staff were qualified engineers
and had long experience of the operation of a chemical plant.
Expert opinion
During the course of the hearing, the High Court sought the opinion of Dr John M.Campbell
of CHERRYROSE Ltd, UK to go into the merits of the PIL. Dr Campbell after studying of
the documents made available to him suggested that the issue is not limited to leakages that
can be contained and which may not cause major hazards. He was of the opinion that worst
cases like tank rupture, terrorist attack , aircraft crash, extreme high speed wind or cyclone
and earthquake should have been considered. CWL has not addressed these issues, he pointed
out. Later EIL carried out a separate HAZOP study and Quantitative Risk Analysis covering
all these issues.
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crash rate on to the tank with respect to one of the runways, is 1.36 per million years which is
of the same order of magnitude as that due to inherent failures. The assessed crash rate due to
second runway is estimated about 0.67 times that due to inherent failures. Thus the possibility
of air crash on the tank can be considered as remote and pose a low level of risk.
In the case of a catastrophic failure of the tank, fatalities to one percent of the exposed
population can be expected to reach about 1.5 kilometres from the storage facilities under
stable weather conditions. It is the control room and its personnel that are most vulnerable to
the havoc. On this account, EIL recommended pressurizing of the control room to make it air
tight, provision for ammonia detectors at vulnerable points, provision for alternate breathing
air system and an effective personal evacuation system.
Rupture of the ship-unloading arm could be caused by roughness of the sea leading to undue
stresses subjected on the arm. A quick connecting and disconnecting coupling will be able to
alleviate the above situation. A provision for emergency relief system for the loading and
unloading arms, automatic shutdown facilities for loading and unloading operations and
provision of ammonia detectors at strategic locations etc. would go a long way to render the
installations safe.
Thermal radiation effects at ground level during flaring of ammonia vapors from the flare
were studied. It was found that the maximum ground level thermal radiation intensity is 0.2
KW/M2 and can be considered safe for operating personnel and for general population. The
thermal radiation intensity at the height level of the tank is found to be 3.8 KW/ M2 which is
also considered acceptable.
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The discharge from blow off of the safety valves should be disposed carefully by leading it to
the flare.
Pilot burners of the flare are also to be kept lit.
A well coordinated emergency management plan is to be developed to address the detailed
on-site and off-site action plans that need be initiated in the event of any release from the tank
After the above exhaustive review EIL concluded that the tank could continue in service in its
present condition subject to certain measures being taken by the company as suggested by
them to further enhance the safety in operations.
The final verdict
On the basis of the report the Supreme Court held that On both these issues (structural
integrity of the tank and its operations) EIL has recommended continuance of the tank in its
present condition subject to certain measures being taken by the company The company has
taken those steps. We have to strike a balance between existing utilities which exist in public
interest on the one hand and human safety conditions on the other hand. It is not in dispute
that such plants are needed for the welfare of the society. In modern times we have nuclear
plants, which generate electricity. Their structural integrity and their operations are vulnerable
to certain risk. However, generation of electricity is equally important and within the
prescribed limits society will have to tolerate existence of such plants. It is for this reason that
we called for a report from EIL so that they can examine the structural integrity of the tank ,
its operations and the measures which are required o be taken to minimize the risk factors. If
arguments of the original petitioner is accepted then no such utility can exist, no power plant
can exist, no reservoir can exist no nuclear reactor can exist. We do not discount such risks
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but we have to live with such risks which is counterbalanced by services and amenities
provided by these utilities. The apex court set aside the order of the High Court.
Thus the tools of process hazard analysis have become successful in logically assessing risk
emanating from installations in a credible manner so that the fear in the minds of the public
are removed and pubic acceptability is increased.
Exactly on a similar line the United States Environment Protection Agency (USEPA)
commissioned a detailed study in 1995 viz, Innovative High Risk/High Priority Anhydrous
Ammonia Study Tampa Bay on the various safety aspects in the storage of liquid ammonia
on the Ammonia storage installation at Tampa Bay Area of Florida, USA. The part of the
state of Florida housed three major storage facilities belonging to CF Industries, IMC-Agro
and Farmland Hydro all major producers of fertilizers. The combined maximum storage
facility is just over 100000 MT of Ammonia and every year 2.5 to 3 million MT of material is
handled in these installations. The main thrust of the study was to examine the level of risk
posed to the local community of half a million people. The risk assessment was done by
addressing the severity of the consequences arising out of any harmful occurrence coupled
with the likelihood of such a happening. The report also considered the following location
specific problems of the Tampa Bay area
1. Presence of a small air field only 1.1 KM from one of the storage tanks
2. A scrap metal yard nearby and
3. The possibility of a terrorist attack or earthquake.
The major findings of the exhaustive study were the following
1. The risk posed to the local community by the storage tanks is relatively small in view
of the low probability of a release.
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2. The Ammonia industry in the Tampa Bay area has shown itself to be a model for other
industries in regard to safety and concern for community welfare
3. Each of the industries are to continue to improve operations with a view to provide the
highest degree of safety possible to its employees and the surrounding community
New directions in Hazard Management
Today, industries are tuned towards more and more descriptive approaches to tackle human
error, which is the prime cause for bad memoirs from the industries. At the technology level,
there are several advancements in the bygone years, which culminated into the formulation of
standard practices in addition to occasional audits, adherence to code of practices in design,
operation and maintenance, which were prevalent earlier. The Process Safety Management
(PSM) today is a fully developed engineering stream and supports the industry with a reliable
safety management programme. Its well-defined objectives and goals, clear documentation of
systems and procedures, mechanism for checking projects and designs, risk management
programme, efforts to bring cultural changes in the organization, mechanism to ensure
process equipment and integrity, procedures for instant investigation and provisions for
training people to update their knowledge and understanding.
The degree of the havoc itself has been assessed in terms of
A most likely release scenario eg. Leaks from pump seal or relief valve
A most probable worst-case scenario eg. Truck crash or movement of a ship severing a
pipeline during unloading
Absolute worst case scenario eg. Total release from a tank due to an aircraft crashing
in on the facility and
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economic loss rising out of short production outages are indeed high. Remaining life
assessment of equipments, redundancy of instruments, software support operations have all
contributed to maintain a better safety environment around installations. A recent advance in
this line is the online performance monitoring (OPM) which is based on a rigorous
engineering model which is capable of signaling the deterioration in the performance well
before a mechanical collapse. Such dynamic systems are developed to suit individual
installations incorporating thermodynamic efficiencies, process changes such as ambient
conditions, stream composition, operating parameters etc.
Safety standards and regulatory compliance
The regulatory and social requirements for safety and reliability has initiated a revolution in
the safety technologies with an increased dependence on smart instruments, integrated
controls and a variety of system architecture. Though, any new development towards attaining
an increased safety level is welcome it is also necessary that the whole must be done with in
an overall safety framework which maintains an appropriate level of safety and which
provides confidence that this is being achieved. An example of such a framework is the
development in the UK, of a Conformity Assessment of Safety related Systems (CASS),
which certifies safety related systems. It is a conformity assessment scheme that recognizes
compliance with the requirements of the international standard IEC 61508 and IEC 61511.
These standards define the Safety Integrity Level (SIL), the level of protection needed for a
particular safety instrumented system. There are four possible discrete SILs determined by
multiplying the risk level factors based on frequency and severity. If the product is less than 6,
the risk is low and only SIL 1 protection is needed. If it is between 7 and 15, the risk is
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moderate and SIL 2 protection is needed. For a product between 16 and 25 , the risk is
considered high and indicate the need for SIL 3 protection.
Creating awareness and preparedness
A major initiative in the public interest with regard to hazardous installations called
Awareness and Preparedness for Emergencies at Local Level (APELL) was developed by the
United Nations Environment Programme, in partnership with industry associations,
communities and governments following some major industrial accidents that had serious
impacts on health and the environment. APELL is now being implemented in nearly 30
countries around the world. APELL is a tool for bringing people together to allow effective
communication about risks and emergency response by reducing
risk; improving
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or natural. Any party can initiate it, although companies can be expected to take the lead. It
can be facilitated by governments, or by industry associations.
Though things are fine and well coordinated, in most countries the public is little aware of
such strengths associated with the industry. Even in countries where the community right to
know legislation has come to effect, most people do not believe what the industry
communicate to them. Thus, there is need to regularly explain in clear-cut terms what risk
they are posed from an industry and how safe are the neighboring industrial environments.
They have to be told that there is an acceptable level of risk that were subjected in our pursuit
for development and industries are committed to maintain their operations within the levels of
the acceptable limits. The preparedness of the industry for management of the abnormal
situations, real time monitoring of systems and equipment and guard against human error
should be well publicized. The social cause for the industries justify such a risk level and the
efforts to further sharpen the tools for process safety shall also continue.
Even in the best-designed and operated plants accidents take place. The question that is often
asked is, how safe is safe enough when it comes to potentially risky processes in chemical
plants? Here comes the relevance of a workable environment management plans. Industries
are capable of developing such plans. But the most important point is that such plans are to
be updated very frequently, tested and kept ready so that it can be pressed to operation as and
when such situations arise.
In other words, Bhopal reminds us that process safety needs continuous improvement,
training, group exercises, building more and more security incorporating an effective social
repatriation of victims of industrial disasters also.
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References
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2.
Andrews J.D and Moss T.R. Reliability and Risk Assessment, Professional
Engineering Publishing Ltd., London, UK, 2002.
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Barry Lytollis, MTL Ltd, Safety Instrumentation Systems : How Much is Enough?,
Chemical Engineering, McGraw Hill Publications,USA, Dec 2002
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6.
Code of Practice for Liquid Ammonia Storage Vessels, Projects and Developments
India Ltd (PDIL), Sindri, India, 1988
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Reducing costs with PlantWeb digital plant architecture: Safety, Health, &
Environment, Emerson Process Management, Austin, Texas , USA, 2003
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(AIChE), New York, Jan 2001.
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Authors
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Risk Level
Frequency
Descriptor
Occurrence
Frequent
1/year
Probable
1/10 years
Occasional
1/100 years
Remote
1/1000 years
Improbable
1/10000 years
Risk Level
Severity
Descriptor
Consequences
Catastrophic
Multiple deaths
Severe
Death
Serious
Minor
Medical treatment
Negligible
No injury