How personal can process safety be?

Noyan Ercan.

Noyan Ercan.

Arrow Energy Asset Integrity and Process Safety Management (AIPSM) Lead Noyan Ercan looks at asset integrity and process safety in the coal seam gas industry.

For most of the commanders-in-chief of today’s armed forces and their troops, one of the key challenges is to keep themselves battle ready, both physically and mentally, under peace conditions! In a world where the possibility of a full blown, large scale, land-based battle is very, very low in most developed countries (though the risk still exists), defence policies and resources tend to focus on other possibilities of helping society, other than just providing a threat-repelling shield of security against the big event.

Operating in an upstream coal seam gas (CSG) industry presents somewhat similar challenges. The one-in-ten year large scale process safety event – fire, explosion with catastrophic consequences – can happen, and companies have to treat this with respect and apply industry best practices to safeguard lives and assets. However, the likelihood of such events occurring is much less compared to conventional oil and gas operations. This is due to lower operating pressures, remoteness and minimally manned facilities. However, the potential hazard impact (number of fatalities) is nowhere comparable to notable offshore disasters such as Piper Alpha and Macondo, where hundreds of lives were lost. So the question that comes to mind is: how far do we go with adopting conventional oil and gas practices when it comes to process safety in design and during operation?

The answer has been a key challenge for the juvenile CSG industry of Queensland in its early years, during which new facilities are being built rapidly with a view to reach production capacities rivalling Western Australia and other regional LNG hubs. In a low-margin economic climate, applying conventional process safety design principles and standards could result in overdesigning of some of the assets and could derail the business case in terms of capital and operating expenditures. On the other hand, designing just as per the generic local or industrial standards, and not adopting more stringent oil and gas code of practices which are derived from critical lessons from many of the infamous process safety incidents, could lead to oversight and blind spots and down the track, thus resulting in unwanted process safety incidents and supply interruptions.

The process safety risk profile of CSG upstream wells and gathering assets means they typically do not possess major accident hazards:

  • CSG is approximately 97–99 per cent methane, with the remaining 1–3 per cent mostly nitrogen and a little carbon dioxide;
  • There is no ethane, propane or hydrocarbon liquid, nor very rare H2S, etc.;
  • The flowing wellhead pressure is low – from 100 kPa to 200 kPa (1–2 Bar);
  • There are no large hydro-carbon storage facilities and within the last 10 or so years in the Queensland CSG industry, no catastrophic process safety incident has been reported;
  • Most facilities are unmanned, and operators conduct weekly well-site rounds; and,
  • The nodal compressor stations are largely unmanned and operators typically do not spend more than an hour per facility per work day.

Most Queensland upstream CSG facilities do not qualify as major hazard facilities, due to no or minimal on-site hydrocarbon storage, and also do not pose considerable major accident risks. In this context, Arrow reviewed its overall upstream process safety risks and identified that CSG processing plants do indeed possess major accident risks due to their potential for loss of primary containment of high pressure gas. Although these gas processing facilities do not qualify as major hazard facilities (as per legislative definition), there is potential for a very low likelihood but high impact process safety incident. Consequently Arrow’s leadership decided to apply the AIPSM framework to mitigate and manage relevant major accident risks for its operations.

Arrow has also adopted a risk-based approach to the design and operations of its assets. Arrow firstly conducted a thorough review of the internal design engineering standards of its shareholder companies, Shell and PetroChina. These standards were prepared for conventional oil and gas projects such as offshore platforms, petro-chemicals, high pressure and toxicity processes. Arrow assembled a team of technical authorities to critically review them and prepare its own engineering design and operations standards based on its risk profile. This review process took more than one year and resulted in the elimination of irrelevant or overly conservative conventional design requirements, while maintaining the process safety-related key requirements which were originally embedded in these standards as mandatory statements. Ultimately designing its future facilities as per these new standards, that are fit for purpose for the future unconventional gas production facilities, will help Arrow achieve an acceptable operational risk profile. For example, facilities will be inherently ALARP (as low as reasonably practical by design), where further risk reduction would be grossly disproportionate to the benefits.

HOW PERSONAL IS YOUR PROCESS SAFETY?

Another challenge that faces the growing Queensland CSG industry is the availability of an experienced, local workforce. Since it is not possible to exclusively use experienced workers from other states or overseas, Queensland’s young CSG industry has had to retrain local workers from diverse backgrounds such as mining, light industries and agriculture.

Like the rest of the CSG players, Arrow’s first challenge was to improve its personal safety performance among its peers within CSG and the industry. Over the years, significant focus and effort were put in this area and this has helped improve and sustain personal safety performance within a relatively short period of time. However, when it came to process safety, it was observed that staff awareness around the key process safety concepts were limited due to the forementioned reasons.

Personal safety and process safety are quite different when it comes to risk appreciation by staff. If we consider a person from early child hood to adulthood, we can imagine the number of falls and slips he goes through, sports injuries, sometimes broken bones he had to suffer, a few driving infringements or near misses with the L-plated car etc. Most of these personal experiences equip us with a basic level of appreciation of personal safety issues and we can associate these with workplace personal safety hazards. On the other hand, our appreciation of process safety is limited by our cognitive ability (how well we learn things) and heuristics (experience-derived from past). This reality makes teaching and training the workforce extremely challenging when trying to establish a process safety culture and awareness in the work place.

Main difficulties around educating and upskilling workforce on process safety are:

  • Topics can be complex (process relief cases, quantitate risk assessments, advanced maintenance performance indicators etc.); and,
  • The rarity of real process safety incidents, which prevents most people witnessing or going through a real process safety incident during their career (consequently they do not develop a feeling for it).

Because of these reasons, relying just on dry classroom trainings of key concepts or rolling out hearts and minds type intense communication campaigns do not necessarily deliver success when trying to establish a process safety culture.

Arrow’s experience showed that there are three key ingredients for success:

  • Top down visible leadership;
  • Procedural control; and,
  • Measured compliance.

In 2013, Arrow developed and rolled out its new asset integrity and process safety management (AIPSM) program. The program operationalised the above listed key success factors by:

Establishing an AIPSM steering committee which included senior leadership team members;
Developing a mandatory process safety requirements framework; and,
Inclusion of AIPSM implementation program progress into company’s score card.

ESTABLISHING THE PROCESS SAFETY CULTURE BY STORY TELLING

Lessons from the major oil and gas disasters showed that lack of understanding of the scope of process safety among leaders was one of the root causes of these incidents. Similarly, since there are not many simple and stand-alone rules to follow as in the personal safety case, staff may not necessarily develop a good appreciation of the latent risks associated with process safety.

In the Queensland CSG industry’s case, this situation was exacerbated further with companies having to recruit staff members with no or limited exposure to working in hazardous work environments. To deal with this situation, Arrow introduced 21 process safety requirements, which established the AIPSM framework. The framework included seven key work streams for delivery purposes:

  • Process safety leadership and culture;
  • Risk and ALARP;
  • HSE competencies and fitness for work;
  • Maintenance and integrity execution;
  • Operating integrity;
  • Design and construction integrity; and,
  • Well integrity.

This initiative was rolled out top down with limited optionality given to operating unit terms of implementation, however, supported with a continuous training and communication campaign.

These 21 requirements were based on the US Bakers report’s key findings and harnessed with key recommendations from the UK offshore HSE guidelines and put together as key recommendations to the industry. In Arrow’s case, they were set and forced top down and compliance was tightly monitored.

Arrow developed and implemented an intensive process safety training package as part of its AIPSM program. To support the cultural change management process, Arrow’s process safety engineers incorporated stories into their training packages. These were based on previous industry incidents that shaped the oil and gas industry. The objective was not just to present these 21 hard process safety requirements as a dry slide package and expect obedience from staff, but to use an effective adult education technique –
story telling.

The purpose was to create a richer learning experience and engage staff as much as possible. In 2014, some 800 Arrow workforce went through different levels of process safety training. This training included listening stories about some of the industry’s worst catastrophic incidents and going through some visuals, followed by group discussions around collective learnings and their application as part of Arrow’s new AIPSM framework.

Since it would be impractical to train everyone in a live-process safety training simulator, such as the ones fire-fighters and front-line operational personnel attend, establishing a base layer process safety culture can be most practically and efficiently achieved by going through the historical industry incidents and sharing the relevant lessons learned with staff. This enables them to visualise the pre-incident circumstances and systemic flaws in these cases and understand the errors made and link them with the process safety basic requirements that they need to implement or comply with in their day-to-day work.

In summary, CSG and LNG infrastructure are typically designed for a 20–30 year lifecycle. The risk profile of the upstream CSG facilities is different to mid-stream pipelines and LNG facilities and design considerations should be risk-based. Since the design considerations define inherent safety and operability, the simpler the design, the more the upstream CSG assets will rely on the soft procedural barriers, (such as management of change and permit to work at the operational phase to keep risks and ALARP level). On the process safety culture front, it is essential that Queensland’s CSG companies establish and sustain an aligned process safety culture for the local industry.

In Arrow, so far the company has clarified the differences between personal and process safety among staff. Arrow’s current key challenge is to complete its AIPSM program implementation in 2015 and ensure all process safety related big-rules and related business processes are understood by the workforce, and visibly led by the senior leadership team. AIPSM improvement is not just a once-off or temporary improvement project; it is the new way of doing things in Arrow. Arrow’s challenge for the coming years will be to sustain improved performance and gradually improve it over the years.

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