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Global Congress on Process Safety - 2012
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How to safely operate Multifunctional Pilot Plants:
A Case Study at the Dow Chemical Co.
Luiz A. Zacharias
Process Safety Technology Leader
The Dow Chemical Co.
2301 N. Brazosport Blvd. – Freeport – TX - 77541
[email protected]
Roger B. Painter
Senior Research & Development Manager
The Dow Chemical Co.
2301 N. Brazosport Blvd. – Freeport – TX - 77541
[email protected]
Disclaimer:
The Dow Chemical Company has provided for the compilation of the information in this document as a part of an effort by its employees to
collect and share their experience and expertise in safety, loss prevention and security. The contributors to this document believe the information
provided is accurate, and they have provided this information in good faith. However, no warranty, express or implied, is given by The Dow
Chemical Company. Other than The Dow Chemical Company employees, those who use this document should use their independent judgment
in evaluating information contained herein, and assume the risk for using the information provided in this document. The user is solely
responsible for compliance with applicable laws and regulations.
Prepared for Presentation at
8th Global Congress on Process Safety
Houston, TX
April 1-4, 2012
UNPUBLISHED
AIChE shall not be responsible for statements or opinions contained
in papers or printed in its publications
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How to safely operate Multifunctional Pilot Plants:
A Case Study at the Dow Chemical Co.
Luiz A. Zacharias
Process Safety Technology Leader
The Dow Chemical Co.
2301 N. Brazosport Blvd. – Freeport – TX - 77541
[email protected]
Roger B. Painter
Senior Research & Development Manager
The Dow Chemical Co.
2301 N. Brazosport Blvd. – Freeport – TX - 77541
[email protected]
Keywords: pilot plants, risk assessment, management of change
Abstract
Located at Dow Chemical’s Freeport, Texas site, the Multifunctional Pilot Plant (MPP) facility
has safely supported diverse research initiatives related to the development of chemical processes
and evaluation of catalysts, raw materials and products since 2000. MPP provides the necessary
infrastructure such as raw materials, utilities, process automation, analytical services and waste
management. Due to the variety of the different chemistries and processes located within the
same structure, a detailed safety risk assessment protocol is applied equally to each project
irrespective of size, chemistry or complexity. Reactive Chemicals and Process Hazards
Analysis, aided by the use of a diverse set of tools, is required to be completed during early
stages of new projects. Interface issues between different operating processes within the facility
are also studied and evaluated for managing future scale up activities once the project is
concluded. Over its life, a project goes through multiple reviews to ensure the initial and
continued safe operation. Unit engineers, technicians, and researchers working in partnership
with Dow’s Process Safety Technology Center identify, investigate and implement best practices
to ensure the ongoing safe operation of the project.
This presentation will cover the following topics:
1. Infrastructure and Pilot Plant capabilities
2. Risk Assessment Protocol
3. Training and Personal Development for Engineers and Technicians
4. Environmental, Health and Safety Performance
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1. Introduction
The Dow Chemical Company’s Multifunctional Pilot Plant (MPP) facility is located in Freeport,
Texas and has supported diverse research and development initiatives related to the chemical
processes, catalysts, raw materials and products since 2000. It provides the necessary
infrastructure to assure safe and reliable continuous operation of each project. The variety of
chemistries and processes located within the same structure requires a detailed safety risk
assessment protocol which is applied independently to each individual project and holistically for
the entire facility. A pilot plant project goes through multiple reviews to ensure the initial and
continued safe operation, including:
-
Hazard Assessment during the project development phase identifying, quantifying and
reducing risks compatible to the planned operation;
-
Pre-startup Safety Review prior to introduction of chemicals and actual operation of the
project to assess the readiness of equipment (hardware and software) and personnel for
the operation;
-
Periodic Process Hazards Analysis for continuing operations;
-
Management of Change process covering any modifications to the project once in
operation.
2. MPP Infrastructure and General Capabilities
The Multipurpose Pilot Plant (MPP) is an ISO 9001:2008 certified facility consisting of
multiple process research bays each equipped with raw materials and utility tie-points for
installation of pilot and market development scale plants as pictured in Figure 1.
Figure 1: Multipurpose Pilot Plant Facility
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Control room, storage, laboratory space, waste management and disposal also support the
facility’s projects. The facility is designed to accommodate multilevel plants and is covered to
provide protection from the elements. The bays are prewired with power connections and a
centralized process automation and data collection system that facilitate true plug-and-play
installations. The centralized process control system ensures implementation of consistent
process control strategies across all projects. All infrastructure systems for the facility are
operated, maintained and managed by a central group independent of the projects.
3. Project Development and Hazard Assessments
Once a new Research and Development (R&D) project is defined to be scaled up from the
laboratory bench into a pilot plant scale in MPP, a systematic risk assessment and management
protocol is engaged. The objective is to evaluate and control the risks associated with the hazards of
materials and processes which may have the potential to injure people, or damage property or the
environment.
The Dow Chemical Company defines requirements for management of process hazards in its
Process Risk Management Standard. MPP established a risk assessment and management protocol
which starts once the project is to be installed within the facility. Dow’s risk assessment program is
an integral part of Dow’s overall environmental, health and safety program. The risk assessment
portion of the program at MPP identifies and estimates the risks associated with the activities
within each project as well as the support units. Identification and quantification of risks are the
beginning of Dow’s process for maintaining the health and safety of our workers and the
neighboring communities. Equally important are Dow’s worker education and training
programs, hazard warning and communication efforts, design controls and features of our
facilities and processes, operational procedures and practices, and our overall quality assurance
effort.
Risk management also utilizes risk analysis which is the estimation of risk from identified hazards
using qualitative or quantitative techniques and engineering judgment. Risk analysis is the process
whereby the identified hazards are evaluated to provide an estimate of the risk and includes
answering these three questions:
-
What potentially can go wrong? (hazard identification)
-
What are the potential consequences? (consequence impact estimation)
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How likely is it to happen? (frequency estimation)
The MPP risk management protocol has several steps with defined inputs and deliverables:
-
Determine the requirements for risk reviews (internal standards, operating permits, etc.) and
define when risk reviews are expected to be completed and identify responsible parties to
complete the defined risk reviews independent of projects’ scale and complexity.
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Identify the hazards related to the system being studied. The role of hazard identification is
vital to the risk management process because it establishes the foundation for risk analysis.
If hazards are not identified the risks cannot be analyzed.
-
Analysis of the risk associated with the identified hazards. The risk analysis methodologies
required and the degree to which the risks need to be considered will vary. In some cases,
simply knowing what could go wrong (for example, hazard identification) may be sufficient
to make risk management decisions. In other cases, an understanding of the potential
consequences or frequency alone may be adequate to make risk management decisions.
Some cases require quantification of both consequence and frequency.
-
Evaluate each risk to determine if it is considered acceptable. There are two basic
approaches to evaluating risk tolerance. The more traditional approach is qualitative in
nature and typically involves making judgments based upon policies and standards derived
from collective experience. These policies and standards have evolved over time as a result
of historical performance. The second approach is quantitative in nature and involves
comparing the risk with numerical criteria. If the risk exceeds predefined and agreed upon
criteria established by Dow Chemical, this exceeding risk is addressed by: changing the
activity which generates risk to reduce it, discontinuing the activity creating the risk, or
reviewing the risk and the activity creating the risk with corporate management and
obtaining agreement on any necessary changes.
-
Once risk reduction steps are taken, hazard identification and risk assessment must be reevaluated to determine if any new risks have been introduced and to see if the risk is now
acceptable. If so, the risk assessment is complete. Management procedures are then
reviewed to ensure that appropriate and effective management systems are in place and that
the remaining or residual risk is being monitored and controlled. The risks are periodically
revisited or re-evaluated when significant process or engineering changes are contemplated.
-
Periodic re-review is required every 3-5 years to ensure that the latest risk processes have
been used to manage the potential risks associated with each project.
4. Tools and Documentation in Managing Process Risk
The specific steps, tools to be used for each step, required documentation, and approvals required
at each step for evaluating and managing process risk are indicated in the following items:
4.1 Process Hazard Analysis
Traditional Risk Review tools are used in this project phase with the objective to obtain
an initial screening and assessment of the hazard potential. They are:
-
Fire and Explosion Index (F&EI)
-
Chemical Exposure Index (CEI)
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Reactive Chemicals and Process Hazard Analysis (RC/PHA)
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Layers of Protection Analysis (LOPA) Consequence Estimation
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Application of Process Safety (PS) Most Effective Technology (MET) – Dow
Loss Prevention Principles (LPP)
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When applicable, Government regulations may require additional reviews
Once the processes of step 4.1 are completed, a multifunctional analysis involving
members of the MPP staff, the project team, the Process Safety Technology Center and
the local Reactive Chemicals committee evaluate the appropriate risk reduction
alternatives. After these activities are defined and implemented, the overall Process
Hazard Analysis must be revisited to ensure that any new hazards that may have been
introduced are identified and analyzed and to determine what impact the risk reduction
measures have had on the F&EI, CEI, and LOPA Consequence Estimation calculations. At
this point in the process, a decision is made if there is a need for advanced risk review.
4.2 Advanced Risk Review
This final step consists of more quantitative hazard identification and analysis than was
carried out in step 4.1. The Primary Tools utilized for fixed facilities for the Final Risk
Reviews include:
-
Explosion Impact evaluation for occupied buildings near potential explosion sites
-
Cause-Consequence Pair Identification - used to better develop/define scenarios for
LOPA
-
For technologies which are new to Dow, Hazard and Operability Study (HAZOP)
is recommended to identify scenarios before the LOPA analysis is performed.
-
Layer of Protection Analysis (LOPA) using scenarios identified during HAZOP
and RC/PHA
-
Fault Tree Analysis, Event Tree Analysis, Human Factors Analysis, and PHAST
(Dispersion Modeling) are other tools that may be used in this step as part of
additional analysis for special circumstances or to address those situations.
This step can be an excellent method for identifying additional risk reduction
alternatives. These alternatives are now evaluated and appropriate risk reduction
measures are implemented. However, any new hazards that may have been introduced
via the modifications or mitigation measures must also be identified and analyzed.
4.3 Manage Residual Risk
When the Process Hazard Analysis and Advanced Risk Review are complete,
management procedures must be reviewed to ensure that appropriate and effective process
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safety management systems are in place and the residual risk is being monitored and
controlled as planned. Management procedures to be reviewed include:
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Management of Change Guidelines
-
Job Procedures
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Personal Protective Equipment Guidelines
-
Training Programs
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Loss of Containment Procedures
-
Emergency Planning and Response Procedures
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Dow Chemical’s Loss Prevention Principles Implementation and Compliance
Residual risk management requires a continuous effort to review and emphasize process
safety management systems and to evaluate a process or activity for new hazards that
might have been created or discovered.
4.4 Periodic Review and Validation
It is expected that this full risk review process will be initiated as a result of each significant
change to the facility. However, the Process Hazard Analysis and Advanced Risk Reviews
described within this document are reviewed and re-validated every 3 to 5 years. If any new
scenarios or new conditions are identified which would present a higher risk than previously
documented, any previously performed reviews would also need to be updated and
revalidated with action items and related documentation included in the projects’ database.
5. Personnel Training and Development
Over the course of the MPP facilities growth, training has evolved to the following sequential steps:
-
General EHS Training
Operational Training
Field Awareness
Hands-on Training
Training Review Board
Ongoing Development
A detailed checklist is used to track the successful completion of the training plan for each
employee. The checklist is validated by the lead technician or run plant engineer and the production
or operations leader for the project. The training regime is similar for either a technician or an
engineer assigned to the project.
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It is important to note that the training and certification can be divided into separate training
packages. For example, an employee could proceed through the steps detailed below for a single
operation instead of the entire project’s operation. The separation of the training is especially
beneficial for tasks that are infrequently performed. It is also beneficial for a new employee as they
can be trained on lower hazard operations initially and then once experience is gained, have their
training extended to include more complex or hazardous operations.
5.1 General EHS Training
The first training step covers Dow’s environmental, health and safety training identified
for the employee’s specific role. Depending on the topic, the training is either self paced
computer or instructor led. Indoctrination to the MPP facility including review of specific
policies is also included during this phase.
5.2 Operational Training
The second training step covers process technology and procedure training which are both
instructor led. Process technology training details the chemistry, technology to be
practiced and the known chemical and process hazards associated with the new project.
Procedure training is a detailed review of the operating procedures for the project. This
step ensures the employee has a fundamental understanding of the operation and the
chemical and process hazards associated with the project before beginning field awareness
and hands-on training.
5.3 Field Awareness
The third training step ensures the employee obtains familiarity with the project and
facility. An experienced technician, lead technician or run plant engineer reviews the
facility and the project with the employee. Important safety features of the facility are
identified, such as location and operation of field alarm panels and switches, safety
showers and gas detectors, as well as normal emergency response actions in the event of
an emergency. The employee is provided a process flow diagram and copies of the
project’s piping and instrumentation diagrams (P&IDs). The employee is expected to
identify the physical location in the field for all equipment and instrumentation, and
routing of all lines.
5.4 Hands-on Training
The fourth training step is the first time the employee actually performs operating tasks.
Hands-on training is 100% supervised by the lead technician or run plant engineer for the
project. The employee must be trained and demonstrate proficiency for all operations
identified for their specific role. Before an employee is trained on the process automation
system (or sometimes called board), they are trained on the outside operations, which
includes identifying all process control loops. The employee must perform each
supervised task until their assigned trainer acknowledges acceptable proficiency.
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5.5 Training Review Board
The final training step is a Training Review Board (TRB). The TRB consists of three
parts: white board review, plant walkthrough and process control review. The TRB is an
oral evaluation of the employee’s knowledge and is attended by the operations or
production leader, run plant engineer and/or lead technician, and EHS delivery.
In preparation for the TRB, the run plant engineer and/or the lead technician develop a list
of detailed questions that cover all aspects of the operation from chemical and process
hazards to performing specific operations. This questionnaire defines the minimum
expectations and is reviewed and approved by the operations or production leader.
Participants in the TRB question the employee using the questionnaire or asking other
questions they identify during the review. All questions not currently included in the
questionnaire are captured for future TRBs.
The white board review takes place in a conference room and normally begins with the
employee sketching the pilot plant process on a white board. It is expected that the
employee will draw all major vessels, interconnecting process and utility lines, and
significant controls and valves that resemble the P&IDs for the project and describe the
actual chemistry during the unit operation overview. The employee is expected to explain
all process control loops and operational strategies, safety systems and interlocks, process
and safety hazards, and emergency responses for the project. Participants frequently
interrupt the employee during the sketching process to ask questions. This interruption is
actually beneficial as it replicates a normal day for the employee (i.e., interruptions occur
on a routine basis) and it ensures the employee thoroughly understands the process.
The project walkthrough validates the individual’s knowledge of the field equipment,
safety systems and operations. Again, questions are raised as the employee describes the
different sections of the pilot plant. During the plant walkthrough, emphasis is placed on
day to day tasks and the identification of safety equipment.
Lastly, the process control review confirms the employee’s familiarity with the operating
system. This part of the review requires the employee demonstrate proficiency in
operating the project, including: navigating through the process control system, accessing
parameters, accessing and responding to alarm screens, accessing process history, and
activating and manipulating control loops.
At the completion of the TRB, the review team subjectively determines if the individual
sufficiently demonstrated the identified competencies for the role. If the individual did not
pass, a detailed action plan is identified up to and including going through all the training a
second time. The individual is not allowed to operate independently until they successful
complete a TRB.
5.6 Ongoing Development
It is common to make frequent changes within a pilot plant, such as process modifications to
investigate an alternate approach or new idea. Dow’s Management of Change (MOC) work
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process ensures that changes are properly reviewed and implemented, which include
identification and documentation of training. Dow also requires the review of operating and
emergency procedures at specified intervals even if changes have not occurred. These processes
ensure that training remains current for all employees supporting a project. This MOC requires
at least the acknowledgement of all employees allowed to operate independently in MPP, so no
one is surprised with a change.
6. Environmental, Safety and Health Performance
All Process Safety events (Incidents or Near Misses) are thoroughly investigated using Root
Cause Analysis methodology, where appropriate. Corrective and Preventive Actions are
established. Investigation sessions are facilitated by the MPP Facility Leader with participation
of representatives from the affected project and Subject Matter Experts.
A Process Safety Incident is identified, reported and investigated if it meets all four components
of the following criteria:
1. Chemical / Process Involvement: A chemical or chemical process must have been
directly involved in the damage caused where the term “process” is used broadly to
include the equipment and technology needed for chemical production;
2. Reporting Threshold: An incident must meet at least one of the following reporting
thresholds:
a. Fire/Explosion: There is either a fire or explosion that causes direct costs
exceeding $25,000 (USD). The term “explosion” includes both detonations and
overpressures,
OR
b. Chemical release: There is an acute release of flammable, combustible, or toxic
chemicals from the primary containment (i.e., vessel or pipe) greater than the
chemical release threshold quantities described in the Center for Chemical
Process Safety (CCPS) Process Safety Metrics, excluding releases to a properly
designed and operating control device specifically designed for that event
3. Injury / Fatality:
a. There is a fire, explosion or chemical release that does not trigger the thresholds
above, but involves one or more fatalities or Days Away of Work Cases (DAWC)
involving employee or contractor or that involves overnight hospitalization for nonemployees.
OR
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b. There is one or more serious injury (DAWC) or fatality of an employee or
contractor that directly results from the release of energy or material from a process,
including chemical storage, even while the process is not in normal operation. This
includes operations such as pressure testing, cleaning and maintenance.
4. Location: The incident occurs at a fixed facility in production, distribution, storage,
utilities, or large/small pilot plant areas. This includes tank farms, ancillary support areas
(e.g., boiler houses and waste water treatment plants), and piping within the site.
Process Safety Near Misses are identified, reported and investigated as per Dow’s work process
which establishes the following criteria:
1. Fire or Explosion: Any fire, explosion, or ignition of flammable or combustible
materials involving a chemical process, or electrical arcing that does not meet global
process safety incident criteria.
2. Unplanned Mixing: Any contamination or unplanned mixing materials with potential for
uncontrolled/unexpected reaction
3. Uncontrolled reaction: A chemical reaction resulting in an unplanned consequence
4. Relief Device Failure or Activation: By definition, a relief device opening is an
unplanned event. The fact that the system reached the relief device set point is of
concern.
5. Actual Chemical Release: A loss of containment
6. Potential Chemical Release: The potential for a significant release due to mechanical
integrity deficiency.
7. Failure of a Layer of Protection: An incident where protection afforded by a layer of
protection (hardware, software, procedural, or human) fails to operate as intended. Layers
of protection can be defined by several methods including LOPA, RC/PHA, historical
design, LPPs, etc.
8. Personnel Exposure: Personnel exposure to toxic or hazardous chemicals with potential
for DAWC.
9. Uncontrolled Mobile Equipment: Incidents where large mechanical equipment (fork
trucks, backhoes, railcars, lifts, etc.) are in an uncontrolled state and have the potential to
breach the mechanical integrity of process containing equipment. The process containing
equipment could be either the transport vessel itself or equipment in a nearby process
plant.
10. Violation of Process Safety Rules: A violation of a facility's process safety rules.
11. SIS Activation: The activation of an identified safety instrumented system
12. Miscellaneous: Additional business, site or facility identified criteria
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7. Conclusion
After almost 15 years of continuous operation, the Multifunctional Pilot Plant has
demonstrated its operational capabilities meet all Process Safety requirements, with
outstanding results. This is especially true when considering the number of personnel and
variety of operations at the facility. We can attribute this successful case to the components
of its overall Safety program:
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Detailed and multi discipline risk assessment during design, construction and start up of
projects
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Permanent post start up verification of operations to assure compliance with safety
requirements, experimental design objectives and personnel safety performance
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Management of Changes with involvement of external SMEs
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Reporting, investigation and correction of root causes associated to Process Safety
Incident and Near Misses
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Clear set of personal safety performance expectations related to safety and operational
training