12/06/2020
Safe Operating Limits
    Why, What, How ?
    Michael Godfrey FIChemE
      Presentation Overview
   Safety Moment
   Why we need SOL
   SOL Definitions
   Equipment and parameter identification
   Operator response and Process Safety Time
   Links to SCE, IOW and further
   References and further sources of information
                                                            1
                                                                                       12/06/2020
    SOL in the air
   17th January 2008 London Heathrow Airport
   Flight BA38 from Beijing. Loss of power to both engines on final
    approach
   Crew retract flaps and manage to extend glide over A30
   Crash Lands just inside the airfield security
    fence
   Investigation - the flight exceeded safe
    operating limits.
    BA38 : Investigation & SOL
   Fuel was in specification for water                  Air temperature
   Low air temperatures during the flight.                 recording
    Fuel flow to engines also reduced at
    times
   Analysis of 175,000 flights identified
    that the accident flight was unique
    among 35,000 Rolls-Royce powered
    flights
   Low Temp and low Flow led to
    formation of ice
                                                    Ice deposition on tube sheet
   Ice blocked the fuel oil heat exchanger              during simulation
   Loss of power to engines . . . . . the
    rest is history
   Initial recommendations
   Use of additive to prevent freezing
   Review design of the fuel delivery
    system
                                                                                               2
                                                                                                  12/06/2020
        Introduction
        Concept of defining safe operating limits is not new . . . . .
        OSHA clean Air Act Amendment, 1990 (Pre PSM)
    o    6.Develop and implement written operating
         procedures for the chemical processes,
         including procedures for each operating
         phase, operating limitations, and safety
         and health considerations
        UK HSE: Pipeline Safety regs, 1996
    o    PSR Regulation 11 states the pipeline
         operator shall ensure that no fluid is
         conveyed in a pipeline unless the SOLs of              Becoming
         the pipeline have been established and                   this
         that a pipeline is not operated beyond its
         SOLs.
    o    Schedule 5 of PSR specifies as a notifiable
         event, changes in the SOLs                  Stop this
        Intent of SOL ?
                          API754: PS Indicator pyramid
         Safe Operating Limits: Definition
Industry Practice
       API RP 754 uses a 4 tier reporting system where Tier 1 & 2 process safety
        events are Loss of Primary Containment (LoPC) events providing ‘lagging’
        metrics. The reporting of these metrics is currently shared across the
        industry.
       Reporting SOL and SDL excursion events (Tier 3 events) are an indication,
        of the performance of the layers of protection, before an incident escalates
        to a possible LOPC event. Hence a ‘leading’ indicator.
Definition - CCPS
       Safe Operating Limits - Limits established for critical process parameters,
        such as temperature, pressure, level, flow, or concentration, based on a
        combination of equipment design limits and the dynamics of the process.
https://www.aiche.org/ccps/resources/glossary/process-safety-glossary/safe-operating-limits
                                                                                              6
                                                                                                          3
                                                                                                                                     12/06/2020
        ‘Normal’, ‘Safe’, ‘Design’
       NOL (Normal Operating Limit) is the high or low
        value of a parameter which defines the                              Design margin /
                                                                            known unsafe /
        boundaries of the normal operating envelope.                        uncertain                                 Upper safe
                                                                                                                      design limit
        Troubleshooting actions are required when a                                                 Buffer
        parameter reaches the normal operating limit                                                zone           Upper safe
                                                                                                                  operating limit
                                                                                                  Trouble
                                                           Envelope
       SOL (Safe Operating Limit) is the high (or low)                                           shooting
                                                                                                  zone
        value of an operating parameter that defines the
                                                                      Safe Operating Envelope
                                                                                                                  Upper normal
                                                                                                                  operating limit
        boundaries of the safe operating envelope.                                              Normal
                                                                                                Operating
                                                           DesIgn
        ◦ SOLs should be set such that a trip set within                                        Envelope
          the safe operating envelope will trigger an                                                             Lower normal
                                                                                                                  operating limit
          immediate, pre-determined action                                                        Trouble
                                                                                                  shooting
                                                           Safe
                                                                                                  zone
       SDL (Safe Design Limit) is the high or low value                                                           Lower safe
                                                                                                                  operating limit
        of a parameter that if exceeded, may                                                        Buffer
                                                                                                    zone
        compromise equipment integrity. For example,                                                                  Lower safe
                                                                                                                      design limit
                                                                            Design margin /
        the Maximum Allowable Working Pressure of a                         known unsafe /
                                                                            uncertain
        vessel is the upper Safe Design Limit.
                                                                                                                             7
        SOL Example
                                                                                                             Upper
                                                                                                             NOL &
                                                                                                             Alarm
                                                                                                             Lower
                                                                                                             NOL &
                                                                                                             Alarm
                                                                                                             Lower
                                                                                                             SOL &
                                                                                                               Trip
BP KOC template                                                                                                              8
                                                                                                                                             4
                                                                                       12/06/2020
     Identifying Systems: Bow tie diagram
 Generic hazard – release of flammable process fluid (HC gas/liquid).
                                         HC: Fire or
                                         explosion
           Mechanical                                                    Harm to
            Impact                                                       people
                                          LOPC of
           Exceeding                     flammable
                                                                          Asset
             SOL                            fluid                        damage
                                                                       Environment
           Corrosion /                                                   impact
            Erosion
    Focus is on control, alarm and safety instrumented systems preventing
    SOL exceedance
     ‘Safe Operating Envelopes – Identification ’
     One approach bases parameter identification on severity i.e. 1 fatality +
     Refer to your HAZOP study (or HAZID)
                   Low            Likelihood                High
                    A    B         C        D          E      F
High        VI                                                      10+ Fatalities
            V                                                       2 - 9 Fatalities
Severity
           IV                                                       Single Fatality
            III
            II
  Low
            I
                                                                                               5
                                                                                                           12/06/2020
   Parameter identification
        Using Bow Ties and HAZOP report it should be possible to develop
         guidance for key parameters
        Company may have procedures – if not develop a philosophy or similar
                           Pressure vessel (generic) – key parameters
               Scenarios          Parameters                  SDL                         SOL
     Overpressure leading       Process Pressure   Maximum design                Set point of high high
     to loss of containment                        pressure                      pressure trip
     Overfill leading to loss   Liquid Level       If the span of the            Set point of high high
     of containment                                transmitter covers the full   level trip
                                                   height of the vessel, SDL
                                                   is the height of the tank.
                                                   Otherwise, SDL is the
                                                   highest level measurable
                                                   by the transmitter.
     High temperature           Process            Maximum design                Set point of high high
     leading to loss of         Temperature        Temperature                   temperature trip (2)
     containment
     Low temperature            Process            Minimum design                Set point of low low
     leading to brittle         Temperature        Temperature                   temperature trip, or PT
     failure and loss of                                                         limits trip
     containment
               Process Safety Time (PST)
                                                                            Process
                                                                            Safety
                                                                            time
                                                         Operator
Vessel Level
                                                         troubleshooting
                                                         time
                                           Alarm: LAH                       Trip: LSHH
                                  Blocked outlet
                                  e.g. ESDV FC
                                                                                 Time
• Estimate Safety Instrumented Function response time (e.g. Loop
  response, valve closure time) and compare to PST. SIF response time
  should less than PST in order to bring the process to a safe state.
• Design set SIF response to 50% of PST
                                                                                                     12
                                                                                                                   6
                                                                                12/06/2020
SOL – Suggested Approach for existing facilities
   Develop a philosophy
   Identify relevant systems / equipment
   Identify parameters
   Determine design limits
   Determine / verify PS time and trip settings i.e. safe operating limit(s)
   Determine / verify alarm settings and operator response time i.e. normal
    operating limit
   Make recommendations
   Summarise results
SOE and SCE - linkage
Commonality
   Identification: Both can be based on the Bow-Tie and consequence
    severity
    ◦ PSV on potable water isn’t necessarily SCE
   Process Safety Time
    ◦ Existing operations – SOE assessing effectiveness of alarm & trips
    ◦ Projects – Used to define SIF response time i.e. Performance Standards
   Key leading Process Safety
    indicators
    ◦ SCE maintenance overdues;
      SOE process excursions
Differences
   Identification: SCE can include
    broader barriers
                                                                                        7
                                                                                    12/06/2020
SOE – Broader Linkage
   Understanding of SOL enables or supports other PS practices and
    activities.
                   Safe
                                                                Alarm & trip
                 operating
                                                                  register
                Procedures
                                          Safe
                                        Operating
                                         Limits
                                                                  Management
                    SCE
                                                                   of Change
                Performance
                 Standards
                                        HAZOP &
                                       LOPA study
Integrity Operating Windows (IOW)
   SOE: Focus is on parameters such as Pressure, Temperature, Level.
   Deviation can lead to LOPC, possibly within seconds or minutes
   What about other parameters e.g. pH, Chloride, Oxygen, Flow (Erosion) ?
    ◦ Deviations can also lead to LOPC, albeit over a longer time frame
   Integrity operating windows can be used to assess, define and track
    ◦ API standard 584
                                                                               16
                                                                                            8
                                                                            12/06/2020
    IOW, SOE and beyond
   Establishment, implementation and maintenance of IOW
   Effective transfer of knowledge to affected personnel
   An effective MoC program to identify changes
    ◦ ‘Creeping change very relevant here’
   SOE shouldn’t just be limited to
    processing plant
   Upstream well and gathering systems
   Reservoir and downhole equipment
                                                                       17
    Summary – Know your limits
Understanding & implementing safe operating limits can lead to
   Safer and more reliable operations
   Enable deviations to be identified and hence investigated
   Reduce the number of Tier 1 and Tier 2 Process Safety Events
   Support other Process Safety requirements and programs
    ◦ HAZOP / LOPA studies, SCE performance standards, etc.
   Provide a foundation for broader or further application e.g. IOW
   Support a culture of continuous improvement
                                                                       18
                                                                                    9
                                                          12/06/2020
References & Sources of information
   API 754: Process Safety Indicators
   API 584: Integrity Operating Windows
   IOGP 456: PS Recommended practice on
    Key Performance Indicators
   IChemE leading KPI’s
https://www.icheme.org/media/1092/safety-centre-
metrics.pdf
   BA38 incident – short
https://en.wikipedia.org/wiki/British_Airways_Flight_38
   BA38 incident – long
https://www.gov.uk/aaib-reports/1-2010-boeing-777-
236er-g-ymmm-17-january-2008
                                                                 10