US Bureau of Safety and Environmental Enforcement (BSEE) issued a safety alert summarizing its findings and recommendations from a recent risk-based Inspection. BSEE’s team of inspectors and engineers developed several recommendations from inspection findings to reduce risks associated with fired vessels; hydrocarbon processing vessels on offshore oil and gas facilities with self-contained, natural or forced draft burners.
Between July 17 and July 20, BSEE inspectors visited 27 platforms operated by 14 unique operators to focus on personnel competency, mechanical integrity of fired vessels, managements systems, and maintenance of fire suppression systems.
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BSEE inspectors also tested the effectiveness of operators’ Safety and Environmental Management Systems (SEMS) by witnessing the application of safety management principles and processes.
BSEE found the following:
- Fired vessel operating procedures were not available to all personnel involved in the equipment operations;
- Operators are not consistently inspecting gauge cock valves to make sure they are functioning properly and remaining in the correct status/position;
- A majority of the inspected operators do not perform documented inspections/reviews beyond regulatory safety device testing of the vessel – specifically, monitoring glycol sample analysis;
- Multiple operators are complying with 30 CFR 250.876, which requires operators to have a qualified third-party remove and inspect, and repair or replace, as needed, the fire tube for tube-type heaters that are equipped with either automatically controlled natural or forced draft burners installed in either atmospheric or pressure vessels that heat hydrocarbons and/or glycol;
- Multiple facilities where the integrity of the flame arrestor and spark arrestor could not be easily inspected, the frequency of inspections was not understood by facility personnel, or there was no documentation of inspections;
- Operators’ inspections and maintenance of fire suppression/fighting systems were overwhelmingly in compliance. However, consideration should be given to the location of deluge systems and fire suppression equipment;
- The facilities associated with the PBRI had minimal issues with excessive temperatures;
- Temperature safety element (TSE) coverage on offshore facilities associated with the PBRI were appropriate and in good condition.
To mitigate the problems, BSSE recommends:
- Review fired vessel operating procedures and verify they are accessible;
- Review gauge cock valves to ensure they are equipped with an automatic ball check shutoff;
- Develop and implement written operating procedures that define the process for sampling pH and include the frequency of that sampling and the documentation of each inspection/sampling;
- Review fired vessel quality assurance/mechanical integrity procedures along with the vessel manufacturer’s recommendations for fuel gas filter maintenance;
- Verify compliance with 30 CFR 250.876;
- Review the difficulty of flame arrestor and spark arrestor inspections, and develop facility-specific protocols;
- Review the layout of the facility and fired vessels and determine if the required number and type of portable and semi-portable fire extinguishers and/or deluge systems are available and in compliance with 33 CFR 145, 30 CFR 250.859(a) and/or 30 CFR 250.860;
- Review the location and condition of temperature hazards signs and ensure paints on high temperature vessels are appropriate;
- Operators should further evaluate the appropriateness of TSE installations below vessels or skids.
See more details in the PDF below
