Safety Alert Addresses Hazards in Fired Vessels
BSEE's targeted inspections identified multiple facilities where the integrity of the flame arrestor and spark arrestor could not be easily inspected, the inspection frequency was not understood by facility personnel, or there was no documentation of inspections.
The Bureau of Safety and Environmental Enforcement issued Safety Alert No. 341, "Fired Vessel Hazards Identified by BSEE in Risk-Based Inspections," in October 2018 after conducting a review of recent compliance and incident data to identify safety trends in the Gulf of Mexico. Its analysis pointed to a potential risk associated with fired vessels. From January 2016 to May 2018, 17 fired vessel incidents were reported to BSEE by 12 unique operators, and BSEE issued 76 incidents of non-compliance (INCs) during the 29-month period that were related to fired vessels, which are hydrocarbon processing vessels with self-contained, natural or forced draft burners.
To reduce the likelihood of future incidents and compliance issues, BSEE developed a Performance Based Risk Inspection (PBRI) protocol and conducted targeted inspections of fired vessels on 27 production platforms in the Gulf of Mexico Region during a two-day period in July 2018.
While BSEE described the overall integrity of most fired vessels inspected during the PBRI as "commendable," the Safety Alert also said "there were noticeable gaps on a few platforms that warrant attention to prevent or mitigate uncontrolled releases of hydrocarbons, toxic substances, or other materials that may cause environmental or safety consequences."
The agency reviewed the inspections' results and conducted additional reviews of Safety and Environmental Management System specific items (e.g., fired vessel inspection records, operating procedures, competency of production operators, JSAs). Its findings included these items:
- BSEE found that fired vessel operating procedures were not available to all personnel involved in the equipment operations examined during the PBRI, and essential instructions for conducting safe and environmentally sound activities failed to include some normal and emergency operations of fired vessels.
- BSEE determined operators are not consistently inspecting gauge cock valves to make sure they are functioning properly and remaining in the correct status/position.
- BSEE concluded that a majority of the inspected operators do not perform documented inspections/reviews beyond regulatory safety device testing of the vessel, and most of the inspected facilities had no method to address, or failed to specify in their maintenance plans, when the fuel gas filters are changed on fired vessels.
- "The inspections suggest multiple operators are not in compliance 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," according to the alert, which says BSEE began enforcing this regulation on Sept. 7, 2018.
- BSEE identified 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 with applicable regulations; however, consideration should be given to the location of deluge systems and fire suppression equipment," it states.
- Facilities associated with the PBRI had minimal issues with excessive temperatures, and most observations made by inspectors indicated high-temperature areas were well insulated. BSEE determined temperature safety element coverage on offshore facilities associated with the PBRI were appropriate and in good condition.
The alert recommends that operators consider these actions:
- Review fired vessel operating procedures and verify they are accessible to all employees involved in the operations; review operating procedures at the conclusion of specified periods and as often as necessary to ensure they reflect current and actual practices, including any changes made to the operation; and ensure changes to the procedures are documented and communicated to responsible personnel.
- Review gauge cock valves to ensure they are equipped with an automatic ball check shutoff, in accordance with API RP 14J 3.3.2, to help prevent/mitigate rapid loss of fluid due to accidental glass breakage. Also, operators should ensure that personnel are familiar with and trained on the status/position of gauge cock valve assemblies.
- 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. Additionally, operators should periodically sample glycol and replace or filter it, as appropriate, especially when glycol is used as a heat transfer medium without circulation or filtering. Recommendations from the equipment and glycol vendors/manufactures should be incorporated into maintenance and testing procedures.
- Review fired vessel quality assurance/mechanical integrity procedures along with the vessel manufacturer's recommendations for fuel gas filter maintenance. If gaps are identified during the operator’s review, the operator should ensure that inspections and tests meet the manufacturers' recommendations.
- Inspect the integrity of fired vessels and correct any deficiencies associated with equipment and systems prior to further use.
- Review the difficulty of flame arrestor and spark arrestor inspections, and develop facility-specific protocols to ensure the integrity of the arrestors, create protocols to document all inspections, and ensure facility personnel are knowledgeable of the inspection frequencies.
- 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.