Professional Documents
Culture Documents
-- --
XII
HSE
Health C Safety
Executive
Contents
Introduction 1
Action taken 1
Description of the sites 1
isolated
- Live
--W-- Openvalve
++ Shutvalve
Kodrurn Knock~ouldrurn
Photograph l Cross-over
valve area on 14 March.
Flare No 1 and knock-out
drum No 1 in background.
Courtesy of British
Petroleum
Photograph 2 Cross-over
valve V17. Courtesy of
British Petroleum
11 Pipelines slope down to knock-out 15 About March 1986, senior refinery
drums which collect the condensate for operations and engineering staff held
transfer to the refinery slops system for discussions to preplan a scheme for the
reclamation. At certain locations pipelines isolation of the flare system at V17. They
slope down in both directions, one such concentrated on the operational and
being at point A on Fig 1 which is 25 m safety requirements of the refinery and
to the north of V17. The 760 mm diameter the flare system. It was very important for
lines slope down towards No 1 knock-out safety reasons that the flare lines from
drum and down towards No 2 knock-out operational units should not be
drum, via V17 and V6. The directions of inadvertently isolated. A system for flare
slope are not marked and at gradients of alignment was drawn up. The procedures
1 in 400 are not obvious. At V17 the and safety precautions necessary for the
direction of liquid flow could only be removal of V17 were not considered. The
established by knowledge of the flare detail was left to those who would
system or by survey. eventually be responsible for the work.
12 Fig 2a shows a knock-out drum. As 16 In late January 1987 crude oil
incoming gases and entrained liquids distillation unit 3 (COD3) was shut down
pass over the vertical loop into the upper for routine overhaul. In early February the
part of the drum, the consequent loss of operations department staff who were to
velocity causes liquids to separate out. oversee the removal of V17 held a
Liquids already in the line by-pass the meeting to discuss and agree the flare
loop by means of a liquid take off. Gas is alignment outlined in Fig 1. Again the
taken from the top of the drum to flare actual work methods were not considered,
possibly via further knock-out drums, and these being left to the two process
the liquid which collects is pumped to the supervisors responsible for general work
slops system. activities on the flare system. About
22 February the catalytic cracker and
13 Most of the flare system valves, alkylation units were shut down. The flare
including V17 consist simply of a movable lines from each of these units were
wedge gate which can pass across the 'spaded' to provide effective isolation.
valve bore. An external gear wheel causes Preparatory to its overhaul the No 1 flare
a threaded spindle to push the wedge was also isolated and 'spaded'. 'Spading'
gate into a guide to create a seal across is a common refinery practice by which a
the internal diameter. (Fig 3). section of pipe is positively isolated by
the insertion of a blank flange. (Fig 4). On
Events leading to the incident 9 March COD3 was ready to be started.
14 Some 15 months earlier losses had Its line to flare No 1 was isolated by
been noted on the flare gas recovery closing gate valve V10 and the operators
system and gas from the alkylation unit had great difficulty turning the
normally routed to No 1 flare was passing handwheel. Once they could turn it no
to No 2. Tests showed that (although it further even using valve wheel keys with
appeared closed) V17 was not providing extension levers, they assumed it was
effective isolation and would require closed and isolated although 75 mm to
eventual removal for overhaul. It was 100 mm of valve spindle protruded.
decided that the loss of recoverable gas 17 Two process supervisors were
could be tolerated until a scheduled responsible for organising the work. Each
shutdown of the catalytic cracker, had a team of process operators working
alkylation unit and No 1 flare. Gases from to them in a double shift pattern. It was
remaining operating units could be re- their job to isolate the appropriate part of
routed to No 2 and No 3 flares matching the flare line system so that removal and
the maximum venting rates to the flaring repair of V17 could be carried out safely.
capacity. This flare alignment would allow The job of valve removal was put out to
for the pipelines at V17 to be isolated. contractors.
Fig 2a Flare knock-out
drum
Temporary raffold
acceu fa terf valve
Knock-out drum
monitors condition
not in scale-waled
flareline
Crescent shaped
opening
Screwed spindle
protruding
Valve spindle
\ ~calesettlestobottom
and compacts as valve
\ Valve body
\
isclosed
I
l
Notfully closed
d p e r e d guide
6
Wedge gatevalve
normal use
Valve in position
with spade in
place of spacer
MARK - REQUIRED X CHECKED4 YES NO ch.~ MARK - REQUIRED X CHECKED J YES NO cwtd
A. Has the equipment to be: -
1.Depressured- - - C. Has the prime mover been:
- 7 vm
,
2. Drained -
1. lsolated from mechanical motive power
3. Isolated by - Blanking? Blank List No. - %
and steam valves locked off? - - . L
- Disconnecting? - - 7
- Valving? - - 10- 2. lsolated from other power sources? -
4.Steamed7
5.Waterflushed
- -
-
- -
- 3-
3. Electrically isolated, locked and tagged? - /
6. Purged with inert gas? - - . % D. 1. Has power cable been disconnected? ,
?
7. Ventilated by naturallmechanical means? 2. Has control cable been disconnected? -
8. Neutralised - - - - - X
SPECIAL INSTRUCTIONS:-
+ - Li*>
4 - I' &tc 4 9',2
..
-%
?
&& -
i p, ,S,:
-- - c-. - .;~d.a,~...
- -. \
Lp.>i....r
J,i,J.l(\cc.n~Lr
'X- ,
'CO 'COMBUSTIBLEITOXICIOXYGEN
GAS TEST RESULTS - ~S~lBLEITOXIClOX~N ----P-
Initial Check -
Re-check -
Re-check -
'DELETE when not ap~licable.
Site preparation is complete: - Permissionis granted for work to commence.
To be signed by Initial check I DateITime I Re-check I DatelTime I Re-check I Date=
OPERATING AUTHORITY I
I am aware that this work is in progress and that conditions are as above.
To be signed by Re-check DarelTime i Re-check I DatelTime
OPERATOR IN CHARGE 1 I
PERFORMING AUTHORITY INSTRUCTIONS:-
I understand the precautions to be taken and have Instructed the Person1Persons carrying our the work accordlnglv
I w ~ lnotlfv
l the Operat~ngAuthorl'y when work 1s complete
To be stgned by lntlal Check DateIT~me I Re check ( DatelT~me I Re-check I DateITlme
PERFORMING AUTHORITY I
Performing Authority
Work'completed at hrs on (Date) Signed
Electrical supply Electrical Sectlon
returned to equipment at hrs on
PERFORMING AUTHORITY
Fig 5 Cold work permit
Craneengine Crane
Operators
cab
Air compressor
Jib
Cross-over
valveV17
ToKOdrum1
andflare 1
To
alkylatim To V6
unit
m m p
6 - Flare line
b
Photograph 3
Hydrocracker area looking
east
surge
I Recycle
waxy
residue
1 Light products (LPG, spirit, kerosene, oils)
through other effects such as 52 With respect to (c) and (d), HSE were
vibration. alerted by the refinery management that
there had been alteration of some
(d) accidental overpressurisation.
instrument settings before security was
51 The investigation involved: fully established around the accident
location. The accounts given by some
(a) Recovery and metallurgical operators did not and still do not tally
examination of vessel fragments on with the physical evidence. It was not
which ballistic calculations were possible to establish unequivocally from
based. the operators' evidence the sequence of
(b) Recovery and examination of fire events which resulted in the explosion.
damaged components. The investigation therefore attempted to
reconstruct the physical conditions
(c) Examination of control room necessary to account for the incident.
instruments and records.
(d) Interviewing operating and 53 The normal operating pressure for
management staff. V306 was 9 bar (135 psig), its design
Fig 9 Refinery plan showing location of hydrocracker explosion and debris, and location of flare line incident
Photograph 5 Fragment
from LP separator; distance
340 metres
Photograph 6 LP separator
end section projected
75 metres over control room
building
pressure 10.7 bar (160 psig) and its test had grown rapidly from the origin in two
pressure 21.6 bar (324 psig). It had a opposite directions, in a predominantly
single pressure relief valve with an orifice brittle manner, consistent with fracture
area of 18 cm2 and a relief capacity to under high strain rate conditions at a
flare of 12.25 tonnelhour, sufficient to temperature near the impact transition
cater for overpressure from fire temperature of the material in this
engulfment. There was no evidence to thickness. On a plant of this type it is
suggest that this relief valve was not foreseeable that fluid transfer could set
operating effectively at its set pressure of up vibration effects giving rise to high
10.7 bar (160 psig). transient strain rates. At operating
temperatures well below normal a vessel
54 The fragments of V306 were located, subjected to these vibration effects could
weighed and their positions logged. The have failed.
explosive forces were calculated using
ballistic techniques based on fragment 57 However the other evidence strongly
trajectories which confirmed that rupture suggested that there had been a
was caused by over-pressurisation. The breakthrough of high pressure gas from
results correlated well with the calculated V305 to V306 leading to
theoretical burst pressure of 50 bar overpressurisation of the vessel. The
(750 psig). Blast damage established that liquid in V305 had drained away through
the force of the explosion was equivalent an output flow control valve when the
to approximately 90 kg of TNT. hydrocracker was being held on standby
operation with no product passing,
55 The overwhelming weight of evidence thereby allowing high pressure gas to
from blast damage, ballistics and break through. Fig 10 shows a single
metallurgical examination pointed towards 300 mm diameter outlet pipe from the
internal overpressure of V306 applied in a bottom of V305 which split into two
single event. Nevertheless other parallel streams each with a separate
possibilities of vessel failure, as set out flow control valve. The valve nearest V305
in para 50, were also considered by was the right-angled, air-diaphragm-
detailed examination of the plant, plant operated valve LIC 3-22 which could be
records and eye witness accounts. There operated from the control room either in
was no indication of an external initiating automatic or manual mode. Some
event such as sabotage. An internal distance from V305 was the air-
explosion or ignition occurring within diaphragm-operated, straight-through flow
V306 was considered. This would have control valve HIC 3-22, which could only
required the presence in the vessel be operated via a manually applied
system of both oxygen and a source of control signal from the control room.
ignition, and the possibility was
eliminated not only by detailed 58 Fig 11 shows the LIC 3-22 and HIC
consideration of the process conditions 3-22 valve control system. A pneumatic
and controls, but also by evidence from diaphragm assembly opened each valve.
vessel fragments. On removal of air pressure the valve was
closed by a spring. Its position was
56 The possibility of mechanical failure selected by a control unit from which an
for reasons other than simple electrical signal passed to an IIP
overpressure was considered. The (electrical currentlair pressure) converter.
metallurgical evidence established that A pneumatic signal was then sent to a
the origin of the failure was in the heat positioner unit at the valve. By this means
affected zone of a saddle weld on the air pressure was applied to the
underside of the vessel at the east end diaphragm. Two hand-wheel-operated
near the support plinth. There was no valves (SP25) in series provided a manual
indication of pre-existing defects nor of a by-pass to the control valves. One was
progressive mode of failure on any part of found open but the other was shut and
the fracture surface examined. Cracks found to be gas tight. Gas breakthrough,
Recycle hydrogen
to C301 compressor
Gas
A -& Uc3-22
r------l
l
I
I
I
!l 1L I To Amtne plant
Bypass Pressure control l
Plc 3-73
Nucleon~c
SP25 SP25
!I rl Float
gauge
LP separator V306 -1
I
I
l
Ltqutd
II
1r 1r r---------- J
II la
4- FIC 3-21
h f,ct10nator
F--'
Sour water
- d
'\
&
0 ,,c322
controller
lip
converter Pos~t~oner Dump
solenold
0
-
fi
d
Low alarm
for
W ~LIC
d~sconnected
r l n 3-22
g
t o s o valve
l e n o ~was
dd u m p
Audlble Vlsual
Relay unit
Extra low
alarm
Audible Visual
30
%
chart 20
indication
10
40
B,
30
V
LP Separator (V3061liquid level
%
Chart 20
indication
10
float gauge
1
f Zero offset
80
%
Chart O'
indication
HP Separator (V3051Pressure
60
-
,h I I I I
l a s breakthrough -O6OohrS -0500hrs -0400hrs -0300hrs
Explosion
t
Shift changeover
Time
Approx 1 hr
m
0 'h l
Fig 12 Diagrammatic representation of charts (traces enhanced and time corrected for clarity)
float gauge trace, assuming instead that had no previous experience of it.
the nucleonic chart reading which
appeared steady at 1O0/0 reflected the 80 The following factors may account
actual level in V305 Unknown to him the for LIC 3-22 being opened, and liquid level
pen had been offset so that a zero in V305 falling during standby operation:
reading was shown on the chart as 10%.
(a) In cold weather and on standby with
He was thus unaware of the actual level no flow, wax could solidify in the
in V305 and of the imminent danger. unlagged and unheated HIC 3-22 and
78 Liquid level in V306 was similarly LIC 3-22 lines. To prevent blockages
measured by float and nucleonic gauges. the valves were opened on manual to
The charts indicated that liquid flowed pass warm liquid through. Flow was
from V306 to the fractionator some hours verified by noting changes in V305
prior to the incident and the gauges went and V306 levels and in V306 pressure
off-scale. The evidence indicated that which rises as gas escapes from the
V306 then emptied requiring 17 000 litres liquid. Alternatively V305 was drained
to bring its float gauge on-scale. Fig 12B1 of liquid allowing gas to
shows liquid surges in V306 breakthrough and blow the lines
corresponding to falls in the level of V305. clear of wax. Gas entering V306 was
The level also appears to rise in the again verified by a pressure increase.
minutes before the explosion. HSE With the reactors under standby
calculated from this that V306 contained conditions liquid transferred from
about 20 000 litres confirmed by V305 was not replaced. The duty
calculating the amount of liquid boardman had not practised the
transferred from V305 following closure of above techniques nor had they been
the outlet valve from V306 to the explained to him. However, he had
fractionator (para 80(b) refers). been in the control room the previous
day when a senior technician had
79 That morning the hydrocracker was blown gas through the lines in
on standby following the TCO trip with preparation for start-up. Another
feedstock from V308 (Fig 7) stopped. operator remembered that 2 years
However, residual liquid from the reactors earlier there was an occasion when
(V301 - V304) continued to pass into V305 gas was heard surging into V306 and
by the action of the recycling gas, its pressure relief valve operated.
although diminishing over a period of Almost certainly this was gas
hours. V305 level was controlled during breakthrough. However an incident
routine steady operation by having a fixed was avoided by the boardman
flow through HIC 3-22 on manual and closing the flow control valve. This
with flow variations controlled by LIC 3-22 near miss was not reported to either
on automatic. On standby, however, flow supervisors or management and there
was erratic and LIC 3-22 on automatic was no investigation.
would be too slow to cope with sudden
increases. Because it responded more (b) The fractionator feed valve (FIC 3-21)
quickly on manual, this was the preferred passed liquid significantly when
method of operation, but in this mode the closed using its control room
maintenance of safe levels required strict controller, and V306 emptied.
operator control. After about 0600 hours However before start up V306
liquid flow had almost ceased and the required sufficient liquid in it to
boardman said he had HIC 3-22 and ensure that gas breakthrough to the
LIC 3-22 shut on manual. He was mainly fractionator would not occur. To
concerned with the unexplained TCO, the ensure sufficient liquid it was
vibration on C301 and conditions on the therefore necessary for FIC 3-21 to
amine and downstream plants rather than be tightened (hand jacked shut)
the level in V305. However because manually on plant and this was done.
prolonged standby operation was rare he To get sufficient liquid level into
V306 for its float gauge to register, 82 Tests were carried out by HSE to
LIC 3-22 would then be opened on establish the gas and liquid flow
manual control. characteristics of the flow control valves.
Water flow rates at comparatively low
(c) Although unlikely, the array of similar pressure were used to calculate the flow
controllers could have resulted in an of hydrocarbon liquid which would have
operator turning the LIC 3-22 thumb been expected in service at the 155 bar
wheel in error. He may then not have pressure drop between V305 and V306.
noticed the level drop in V305. The results for LIC 3-22, the valve which
(d) The operator believed the V305 was opened are shown in Table 3. The
nucleonic gauge chart recorder variation between the HSE figures and
reading with its zero offset. In the manufacturer's data at mid-range is
addition he was not aware of the attributable to the effects of in-service
extent to which the liquid level in conditions and valve seat wear. Despite
V306 was below that which would there being no means on plant for
show a reading on its float gauge. measuring flow between V305 and V306,
Thus if LIC 3-22 was opened in an operators estimated flow rates against
attempt to establish a level of liquid percentage valve openings. Their
in V306 and no instrument changes estimates correlated closely with the
resulted, it could be concluded that calculated figures.
LIC 3-22 had not opened. The valve
may then have been opened further Table 3 Liquid flow characteristics of LIC 3-22 valve
or for a longer period to get the
levels to respond, whilst in reality LIC 3-22
levels were falling rapidly.
81 Opening LIC 3-22 on manual control Manufacturers
HSE values
% Open data
to pass warm liquid or gas through the
lines was permitted by supervisors. This
litreslmin litreslmin
necessitated bypassing the safety trips.
Because the danger was recognised this
was only supposed to be done under
carefully controlled conditions and with
extreme care. Operators were required to
pay close attention to instruments! The
shift instructions log book entry on 17
October 1986 stated:
"once all wax appears to have been
removed, block in and leave for 2 hours, 83 Gas flow characteristics of LIC 3-22
then check by opening LIC 3-22 carefully were obtained from the manufacturer and
to avoid over-pressurising the confirmed by calculation based upon the
LP separator. Repeat every 2 hours" liquid flow test results (Table 3). A
computer programme was then used to
and again on 13 March, 1987 stated: predict the expected pressures in V306,
"with caution and care, sweep hydrogen assuming hydrogen passing into it at
from the HP through the LP and the 155 bar, as a function of percentage open
multilocks to the fractionator to try to of LIC 3-22. Flow through its pressure
remove as much wax from the lines as relief valve (PRV) and its estimated liquid
possible". content (para 78) were taken into account.
The results are shown in Table 4
This was clearly a dangerous practice the (columns 1 and 2). The time taken for
potential consequences of which were not V306 to reach its calculated burst
fully understood. pressure of 50 bar is shown in Table 4
(columns 1 and 3). The times shown time of 108 seconds to reach its burst
commence once V305 is drained of liquid. pressure (Table 4) this would give a total
It can be seen that if LIC 3-22 was time to the explosion of about 6 minutes.
opened less than 40% the maximum The precise timing of the opening of LIC
pressure in V306 would be less than 3-22 beyond the 40% position may never
50 bar and it would therefore not rupture be known but the calculations
but would vent via its PRV. With LIC 3-22 demonstrate clearly the potential to over-
open more than 40% the PRV was not of pressurise V306.
sufficient capacity to prevent rupture.
These calculations therefore established 85 An indication of events in the
that for V306 to explode LIC 3-22 must minutes before the explosion is provided
have been opened beyond 40%. by the chart (Fig 12B2) showing V305
pressure. It shows a drop in pressure of
Table 4 Relationship between position of LIC 3-22 18 bar (270 psig) over 4 minutes and then
and pressure rise in V306 and time taken to reach a rapid drop as V306 ruptured. Although
burst pressure of 50 bar the complexity of the high pressure
system precluded using pressure drop
information to determine LIC 3-22
'10 Opening of Pressure Time to 50 bar (based position, close examination of the chart
LIC 3-22 bar (psig) on the models used) shows the rate of pressure drop increased
within that 4 minute period confirming
14 (200) Will not reach 50 bar that LIC 3-22 opened further. The volume
21 (300) Will not reach 50 bar of gas represented by the pressure drop
28 (400) Will not reach 50 bar was calculated as being sufficient for
35 (500) Will not reach 50 bar V306 to reach its burst pressure.
41 (600) Will not reach 50 bar
48 (700) Will not reach 50 bar 86 When the control room was entered
53 (800) 108 seconds after the explosion, a supervisor reported
35 seconds that the LIC 3-22 controller was on
25 seconds manual and 100% open. Later, when seen
22 seconds by HSE Inspectors it was found fully shut
and other controls were also in different
positions from those first reported. The
84 The chart recording of V305 level supervisor's report was correct, two
(Fig 12A) ceased some time before the operators who altered the controls
incident (para 73). The time taken after confirmed it several months later.
this for the incident to occur is the sum However no explanation for LIC 3-22
of the time to empty V305 of liquid and being fully open has been given. The
the time to raise V306 to its rupture reasons described in para 80 could
pressure. The LIC 3-22 liquid flow account for it being opened on manual
characteristics (Table 3) were used to during standby. The hydrocracker controls
estimate its percentage open when levels were typical of the late 1960s and the
in V305 were dropping prior to the following features could have led to
explosion and to calculate the time for it operator error:
to empty. The downward steps in the
float gauge trace (Fig 12A) show that (a) Errors could be made when
LIC 3-22 was open less than 5%. The final assessing the volume or depth of
downward trend no more than 20 minutes liquid in V305 and V306 as their
before the explosion starts at 6% on the measuring devices related to different
float gauge trace when 13 200 litres of indicated lengths, not to each other
liquid remained in V305 and in order to nor to the content of the vessels.
empty this amount in that time LIC 3-22 (b) False assumptions could be made
must have been opened much more. If it about the time to discharge the
was for example 40% open V305 would liquid in V305 since there was no
empty in 4 mins and when added to the means of measuring flow other than
Photograph 7 LIC 3-22 and
HIC 3-22 controllers
manway covers and one of the three roof equipment were transferred to T807 where
manway covers were removed. The tank work commenced on 2 June. For this
was then allowed to ventilate naturally. there were eight contract employees
including a working supervisor on site, all
93 On 20 May the terminal engineer met but three of whom had worked on T809.
representatives of several specialist
cleaning companies to inform them of the 94 The contractor was well known in the
nature and extent of the proposed work. field of tank cleaning operations. They
On 28 May, a contract was awarded to had successfully completed contracts on
the company which was already on site this and other sites. BP were satisfied of
cleaning out ballast tank T809. After their competence when they awarded the
completing this work, the men and contract. Procedures for tank cleaning
and sludge removal were decided by the of fire surrounding the three men inside.
contractor, although they were discussed As they ran to escape the flames one
with site management. man fell but managed to struggle to his
feet and escaped with a second man. The
95 The tank and its bund area remained third who had been driving the vehicle ran
under site control and a permit to work in the opposite direction and did not
was required to be issued before work escape. He died from the effects of
could be started. T807 was not 'gas-free', asphyxiation and burns. The fire
ie not free from all flammable and other escalated rapidly with flames and smoke
vapours. The evolution of flammable coming out of the open manways.
vapour with the risk of forming an
explosive atmosphere was not considered 98 After a crew change the terminal fire
sufficient to merit either mechanical tender was arriving at T807 to take up
ventilation or rigorous monitoring of the station after a brief absence. The terminal
vapour concentrations inside the tank. safety services operator and others took
However, as a precaution against fire hoses from the tender and connected
potentially toxic effects, the contractor's them to a nearby hydrant. Fire hoses had
employees working inside T807 were not been laid in position because on
required to wear airline breathing previous occasions they had been
apparatus supplied from a compressor accidentally damaged. The fire was
located outside the bund. A hydraulically extinguished within about 10 minutes by
powered screw pump was located in the the terminal fire crew. Lothian & Borders
tank and the men used hand tools to Fire Brigade arrived on the site at
pass sludge to its inlet hose. Sludge was 1330 hours and for the remainder of the
then pumped through a 100 mm diameter day were deployed in pumping foam
flexible hose assembly, which passed through manways into the tank to keep
through a tank manway, into the supply the contents cool and to prevent re-
pipeline to T808 via a non-return valve. ignition. The tank was allowed to cool
The diesel engined hydraulic power units and the body of the deceased, still
were positioned immediately outside T807. wearing the remnants of breathing
The location of equipment was agreed apparatus, was recovered on 12 June at
with the terminal engineer. 2100 hours.
96 On 4 June a hydraulically powered
99 HSE Inspectors were quickly on site
tracked vehicle fitted with a rubber edged
and co-operated with the emergency
wooden scraper was introduced to speed
services throughout the recovery phase of
up the work. It was taken into T807 in the incident.
pieces and assembled. The contractors
continued working on the north bank of
sludge. There were two teams of four Investigation by HSE
which alternated every two hours. Three
men worked inside and on duty outside 100 Crude oil is a complex mixture of
was a fourth man and a BP safety hydrocarbons and a typical analysis of
services operator. the crude in T807 is shown in Table 5. A
sample of sludge from the outlet hose,
identical to that in the tank prior to the
The incident
fire, was tested to establish its flashpoint
97 On 11 June the contractors started (the temperature at which it gives off
work inside T807 at 0630 hours, after their vapour sufficient to cause a flammable
supervisor had checked on the re- issue concentration in air). It was found to be
of the permit to work with the terminal less than OC. The upper and lower
engineer. The team changeover which flammable limits in air (the flammable
preceded the incident took place at 1230 range) of hydrocarbon vapour are typically
hours. At 1320 hours the outside man 1.5% and 6%. The vapour is heavier than
looked in and shouted as he saw a ring air.
Photograph 8 T807 at
Dalmeny tank farm looking
north
Photograph 9 Diesel
engined unit near to T807
manway
Table 5 Typical analysis of stabilised crude oil some men brought smoking materials on
to site and into T807. It is not known
when smoking inside tanks first started,
% by but it appears that the practice was
Constituent commonplace amongst certain
weight
contractor's employees who had smoked
Stabilised gasoline in T809 and had been smoking in T807
Benzine since work started. The contractor's
Naphtha foreman, in charge of the job was
Kerosene
Gas Oils
satisfied his men knew that smoking was
Heavy Oils and Tars
allowed only in the designated safe areas.
He never saw them smoking other than in
these areas and had he done so he would
have taken disciplinary action.
101 Many possible sources of ignition
were considered including pyrophoric Undoubtedly, the men all knew that
smoking outside designated areas was
scale, static electricity, machinery
forbidden and that they would face
malfunction, stray currents from the
disciplinary action if they were caught.
cathodic corrosion protection system, the
location and maintenance of diesel 104 The men inside T807 were required
engined equipment nearby, matches and to wear respiratory protective equipment
smoking. Enquiries had commenced into (breathing apparatus or BA) to protect
these possibilities when a man admitted from the potentially toxic fumes. Vapour
to smoking, stating that the fire started concentrations inside such tanks may
when he dropped his lit cigarette end. typically approach 25% of the Lower
Explosive Limit (LEL) and Table 6
102 A BP booklet entitled A Guide to illustrates the extent to which this
the Refinery Safety Regulations, set out exceeds the recommended exposure
rules to be observed. Rule 5 stated that limits. Vapour concentration is not evenly
smoking was not permitted except in distributed and depends on ventilation,
specified areas, and Rule 6 that matches ambient temperature, and the extent to
and lighters were not allowed in the which sludge is disturbed. Mechanical
premises and must be deposited at ventilation was not provided and thus the
thegatehouse. This booklet was not natural ventilation rate depended on wind
issued to all the contractor's personnel speed and direction, and the passage of
involved in T807. The temporary site entry air through the open ports.
passes for visitors and contractors had a
condition that matches and other sources Table 6 Typical volatile constituents of crude oil
of ignition should be surrendered before
entering the site. Such passes were not
issued to the contractor's employees Lower
explosive Concentration Recommended
involved in cleaning T807.
constituent limit at 25% LEL exposure limit
@pm) (PP~)
103 Notices were posted at the main @EL)
entrance to the terminal stating "no
smoking within the installation" and "no Pentane 1.4 3 500 600
Hexane 1.2 3 000 500
smoking: all lighters and matches must n-Hexane 1.2 3 000 100
be surrendered to security personnel at Heptane 1.1 2 750 400
the gate". However, the entrance was
unmanned and the gate was operated
remotely from the control room using 105 Some men did not appreciate the
video camera surveillance and intercom. toxic hazards; neither did they realise the
Terminal staff carried out no checks to extent to which vapour concentrations
ensure that contractor's employees would increase towards the floor of the
complied with the rules. Unchallenged, tank. Some discovered that they could
see better in the dark, unlit conditions if becoming entangled on a support pillar.
they removed their BA face pieces or He may also have slipped or tripped over
visors and they quickly became hoses or other equipment. Means of
accustomed to the smell. As they felt no escape from the tank in case of an
apparent ill-effects they concluded it was emergency, particularly in the event of
safe both to leave off their BA and to fire, had not been considered and
smoke. The deceased was a non-smoker emergency escape exercises had not
and so far as is known, wore his BA at been practiced by the contractor. The
all times. Although experienced outside man had no clear instructions
employees had received formal training about the action to take in the event of
some men were new to tank cleaning an emergency.
work and had received no such training.
Basic training in the use of breathing 108 Although this incident resulted in a
apparatus was given by the contractor's surface fire, there was the potential for an
supervisor. For some this involved only a explosion had there been a sufficient
short demonstration of how to fit the volume of vapour at a concentration
facepiece, operate the air regulator and between the lower and upper flammable
deal with snagged air hoses or air supply limits. Precautions to prevent this include
failure. ventilation and routine monitoring of
vapour concentrations. Mechanical
106 The team involved mostly worked ventilation would not only have reduced
unsupervised and on the occasions when the overall concentration of vapours in
their supervisor, a member of the other the tank but also minimised the extent to
squad, came in, they could return to which local concentrations could have
wearing BA before he came close enough been in the flammable range. However
to see them. Although the supervisor was the senior site engineer considered that
not aware of smoking and would not have such ventilation and vapour concentration
condoned it, he had on occasions monitoring were not necessary. He
removed his breathing apparatus whilst thought that concentrations would be
inside the tank, in order to give verbal above the upper flammable limit and that
instructions to the men. From the outside workmen wearing breathing apparatus
of the tank it was impossible to see what were adequately protected. A terminal
was going on inside and the terminal safety services operator undertook some
safety services operator was unaware of monitoring on his own initiative although
these malpractices. The men ensured that not fully aware of the instrument
they were wearing the correct equipment limitations. On the day before the
when entering and leaving to give the accident he obtained a reading in T807 of
impression that it was worn at all times, 25% of the LEL. He did not know how to
and it thus appears that they deliberately assess the significance of this reading
deceived both their own supervisor and which is in fact the limit at which
the terminal staff. consideration should have been given to
stopping work. He took vapour level
107 The survivors could not remember readings external to T807 daily and
their exact position in the tank, other recorded these on the permit to work.
than they were working at the northern
bank of sludge, and so the distance they 109 There were no detailed written
were required to travel when the fire procedures specifying the precautions to
occurred is not known accurately. When be taken during the cleaning of T807. The
the fire started flame is estimated to have contract only made reference to general
moved across the surface at about 2 mls standards which were expected and
and the fire may have spread to cut off stated inter alia that the contractor
the means of escape for the deceased. should ensure that his work methods "are
He alone was wearing his BA the hose of as safe as is reasonably practicable and
which may have impeded his escape by that any danger to life and limb and the
environment is minimised". The contract ventilation. This should be sufficient to
also stated that "all work will require the reduce the overall flammable vapour
issue of permits by the employer (BP) but concentration, to avoid vapour pockets
the employer reserves the right to and to minimise the extent to which the
suspend the permit at any time should he vapour above the sludge surfaces may be
consider the area becomes unsafe." in the flammable range. The effective
control of ignition sources is of equal
110 Rigorous inspection of equipment importance but in view of the ever
used by the contractors was not carried present risk of fire, precautions for tank
out. Despite a BP requirement for internal cleaning must also include provision for
combustion engines to be fitted with safe means of escape. Tank designers
sparklflame arresters, a diesel engined should give due consideration to the
hydraulic power generator located about hazards of cleaning operations and the
two metres from an open T807 manway need for access and ventilation.
was found with a cracked exhaust Companies who carry out tank cleaning
manifold. There were no formal operations should produce a detailed
procedures for checking the equipment method statement setting out clearly the
being taken into the tank. safety precautions they intend to take.
111 In 1985 following similar tank 114 "The preparation and operation of
cleaning operations, the terminal had contracts in the Petroleum Industry:
received advice from HSE which Health and Safety Guidelines" a
recommended that consideration be given publication produced by the Oil Industry
to the means of escape from inside tanks Advisory Committee (Reference 3) refers
for persons wearing airline breathing to the care which should be taken in
apparatus because of the risk of air hose selecting and assessing contractors
entanglement around roof support pillars. referring to, inter alia, management
attitude, safety performance assessment,
Conclusions safety policy etc. Reference is made to
the need to control contractors on site.
112 The fire was started because an Although the legal duties of employers
employee of the cleaning contractor described in section 2 of the Health and
deliberately disregarded a basic safety Safety at Work etc Act 1974 cannot be
rule. He smoked in the tank which delegated, every employer is, as a general
contained highly flammable vapours. He principle, responsible for those areas over
was not alone in this; two other men had which he can exert control. Site occupiers
also smoked in the tank. In his written should recognise their special
judgement following the Fatal Accident responsibilities relating to the overall
Inquiry the Sheriff stated "They knew that control of their sites and should make
it was dangerous. They wilfully shut their provision for possible shortfalls on the
eyes to the fact that by doing so they part of any contractor (and his
risked causing a fire". While good site employees).
security and supervision may reduce the
likelihood of smoking the Sheriff doubted 115 Site occupiers are advised to make
whether such precautions would be it a condition of contract that they may:
adequate "against the perversity of (a) Inspect and approve where necessary
workmen who choose to break all the any materials, substances and
rules" However, companies undertaking equipment provided by the contractor
such potentially hazardous work must be and specify any necessary conditions
rigorous in their staff selection under which the materials or
procedures. equipment may be used;
113 An important safeguard during tank (b) require the contractor to provide
cleaning operations involving flammable information on the health and safety
residues is the provision of adequate aspects of the materials, substances
and equipment to ensure that they statute or, additionally, by the owner-
conform to national specified operator's own accepted practices;
standards;
(f) require the contractor to stop work or
(c) require evidence from the contractor prohibit a particular practice when he
that his personnel are trained and considers his activities may be
experienced enough to do the job prejudicial to health or safety.
competently and safely;
116 The circumstances of the accident
(d) require the contractor to demonstrate demonstrate clearly the need to follow
that his employees are at all times the advice set out in the HSE publication
adequately trained and instructed in Dangerous Maintenance - a study of
the potential hazards associated with maintenance accidents in the chemical
the owner-operator's operations or, industry and how to prevent them (Ref 1)
as necessary, review the adequacy of especially at paras 88 to 92. The report
the training, instruction and highlights key points on contractors.
information given to contractor's
employees to identify areas for (a) Is the competence of contractors
improvements; properly evaluated?
(e) at any time - when a contractor is (b) Are contractors on site instructed in
working within an area under the the possible risks?
control of the owner-operator - (c) Do contractors receive full
inspect and audit the contractor's information on the job to be done?
workplace and working methods and
examine any record required by (d) Are contractors properly supervised?
applied in the UK Petroleum Industry. The
Oil lndustry Advisory Committee of the
Bibliography Health and Safety Commission. HMSO
ISBN 0 11 883885 7.
1 Dangerous Maintenance: A study of
3 The preparation and operation of
maintenance accidents in the Chemical
contracts in the Petroleum lndustry
Industry and how prevent Health and Safety Guidelines. The Oil
ISBN 0 883957 8.
lndustrv Advisorv Committee of the
2 A guide to the principles and Health 'and safety Commission. HMSO
operation of permit-to-work procedures as ISBN 0 11 883903 9.
44
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