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www.RMPCorp.com
RMP/PSM WEBINAR SERIES
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CCPS GUIDELINES FOR INITIATING EVENTS AND INDEPENDENT PROTECTION LAYERS IN LAYER OF PROTECTION ANALYSIS
AN OVERVIEWPART 3
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IPL DEFINITION AND ATTRIBUTES
ACTIVE/PASSIVE IPL CHARACTERISTICS
PRESSURE REDUCING REGULATORS
CONTINUOUS PILOTS
CHECK VALVES
CAPTIVE KEY/LOCK SYSTEMS
EXAMPLES OF IPL APPLICATIONS
AGENDA
SCOPE
IPLS (DATA TABLES 5.32-5.35) FROM THE CCPS GUIDELINES FOR INITIATING EVENTS AND INDEPENDENT PROTECTION LAYERS IN LAYER OF PROTECTION ANALYSIS
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INDEPENDENT PROTECTION LAYERS (IPLS)
A device, system, or action capable of PREVENTINGa scenario from proceeding to an undesired consequence regardless of the initiating event or the action of any other protection layer associated with the scenario
IPL CORE ATTRIBUTES
INDEPENDENCE
FUNCTIONALITY
INTEGRITY
RELIABILITY
AUDITABILITY
ACCESS SECURITY
MANAGEMENT OF CHANGE (MOC)
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ALL IPLS ARE SAFEGUARDS, BUT NOT ALL SAFEGUARDS ARE IPLS
ACTIVE IPLS - DEFINITION
ACTIVE IPL
An IPL that requires an action to be taken in order to achieve its function aimed at reducing risk.
This action may be mechanical-only in nature or may use a combination of instruments, humans, and mechanical devices.
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PASSIVE IPLS - DEFINITION
PASSIVE IPL
An IPL that does NOT require an action to be taken in order to achieve its function aimed at reducing risk.
IPL List
Pressure Reducing RegulatorsContinuous PilotsCheck ValvesCaptive Key/Lock Systems
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PRESSURE REDUCING REGULATORS
PFD = 0.1OoM = 1
Photo courtesy of Cleaning Technologies Group.
PRESSURE REDUCING REGULATORS
VALIDATION CRITERIA
• Pressure regulator is sized adequately
• Spring tension device is manually adjusted to proper setpoint
• Must be in clean service
• Operates in low-demand mode
• Undergoes adequate ITPM
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PRESSURE REDUCING REGULATORS
EXCEPTION
1. If there are two pressure regulators in series, where the first pressure regulator is being used as the control element, the second pressure regulator can be taken as an IPL
2. If the pressure regulator is operated in high demand mode (challenged >1x/year), the failure of the pressure regulator would be an IE instead
EXAMPLES
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PRESSURE REGULATOR - EXAMPLE A
250 psig 250 psig
Overpressure = 250 psig/125 psig = 200%
PRESSURE REGULATOR - EXAMPLE B
Overpressure = 250 psig/125 psig = 200%
250 psig 250 psig
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CONTINUOUS PILOT
PFD = 0.1OoM = 1
Burner photo courtesy of Zeeco USA, LLC.
CONTINUOUS PILOT
VALIDATION CRITERIA
• Provided with an independent, good quality fuel source
• Performance of pilot is validated by monitoring pilot flame by an independent means
• Adequate ITPM is conducted, as necessary (if instrumentation is used)
• Upon loss of pilot, repairs are initiated
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EXAMPLE
CONTINUOUS PILOT - EXAMPLE
Flameout. Upon reestablishment of fuel gas flow, accumulation of HCvapors/combustible mixture. Fire/explosion hazard in firebox.
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CHECK VALVE
PFD = 0.1OoM = 1
Disc Check Valve Photo courtesy of Spirax Sacro
CHECK VALVE
VALIDATION CRITERIA
• Operates in low demand mode (challenged <1x/year)
• Operates in clean service
• Metallurgy is corrosion-resistant or no fouling or corrosion is expected for the type of service
• Undergoes adequate ITPM (Critical Check Valve List)
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CHECK VALVE
EXCEPTIONS
1. If the Check Valve is operated in high demand mode (challenged >1x/year), the failure of the Check Valves would be an IE instead
DUAL CHECK VALVE (SERIES) + RELIEF VALVE
PFD = 0.01OoM = 2
Dual Check Valve Photo courtesy of Watts
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BEST PRACTICE
• Dual Critical Check Valve in series (PFD = 0.1)
• Dual Critical Check Valve of dissimilar types (PFD = 0.1)
• Dual Critical Check Valve with a nominally sized Relief Valve(s) (PFD = 0.01)
DUAL CHECK VALVE (SERIES) + RELIEF VALVE
EXAMPLES
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REVERSE FLOW – EXAMPLE A
Flash Drum
Recycle H2 Compressor
Scenario:
Charge Pump Failure
Operating Pressure = 50 psig
MAWP = 150 psig
Overpressure = 1400 psig/150 psig = 933%
Discharge / System Pressure = 1400 psig
1400 psig
REVERSE FLOW – EXAMPLE A
Scenario:
Charge Pump Failure
Discharge / System Pressure = 1400 psigOperating Pressure = 50 psig
MAWP = 150 psig
Overpressure = 1400 psig/150 psig = 933%
1400 psig
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REVERSE FLOW – EXAMPLE B
Increased Pressure and Overflow
through Atmospheric Relief Valves
REVERSE FLOW – WHAT’S WRONG HERE?
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CAPTIVE KEY/LOCK SYSTEM
PFD = 0.01OoM = 2
Valve InterlockPhoto courtesy of Haake-Technik
CAPTIVE KEY/LOCK SYSTEMValve InterlockPhoto courtesy of Haake-Technik
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2
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CAPTIVE KEY/LOCK SYSTEM
VALIDATION CRITERIA
• Locking is mechanically robust
• Key is released from another mechanical device
• Released key do not have uncontrolled duplicates
• Incorrect position or improper operation is easily detectable by a visual check
EXAMPLE
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CAPTIVE KEY/LOCK SYSTEM – EXAMPLE
LOLO
LCLC
Increased Pressure and Overflow
through Atmospheric Relief Valves
UPCOMING WEBINARS / CONFERENCESWebinarFeb. 9, 2017
• “Overview of January 13, 2017 U.S. EPA Amendments to the RMP Rule” presented by Steve Maher and Aleks Metulev
WebinarFebruary 21, 2017• “IIAR Standards and how they Apply to RAGAGEP – Part 3” presented by Stephanie Smith, PE
WebinarMarch 7, 2017• “Using HAZOP/LOPA to Create an Effective Mechanical Integrity Program” presented by Steve
Maher, PE and David Childs
WebinarMarch 21, 2017• “PSM/RMP Modernization Program in California – New 2016 Developments and Correlation to
Evolution at the Federal Level” presented by Steve Maher, PE and Aleks Metulev
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QUESTIONS/COMMENTS?
MICHAEL SAURASENIOR ENGINEER/LOPA FACILITATORRISK MANAGEMENT PROFESSIONALS
(949) 282-0123 EXT. [email protected]
TIMOTHY LEESENIOR ENGINEER
RISK MANAGEMENT PROFESSIONALS(949) 282-0123 EXT. [email protected]