Page 74 - Occupational Health & Safety, June 2017

OIL & GAS
The Significance of API RP 2219 Recommendations in the BLSR Accident, Part II
Employers and workers need to pay special attention to minimum recommended safety requirements of approved standards and safe working procedures.
BY HAMED KHOSHNIAT
70 Occupational Health & Safety | JUNE 2017
www.ohsonline.com
CSB Recommendations Linked to the API Standard: For Nobel Energy:
1. Provide documentation of the potential flam- mability hazard of exploration and production (E&P) waste liquids—such as a material safety data sheet (MSDS)—to all employees, contract personnel, and haulers handling waste liquids generated at well sites. Emphasize that mixing condensate with basic sedi- ment and water (BS&W) during the removal process can significantly increase the flammability hazard. The mixture in the transport container should be treated as a flammable liquid absent positive identifi- cation to the contrary.
2. Review and revise company gauging and waste liquid removal protocols as necessary to minimize the inadvertent removal and subsequent disposal of hydrocarbon product when removing BS&W from product storage tanks.
For T&L:
1. Ensure that the written procedures for hazard identification require that all customers requesting loading and transportation of exploration and pro- duction (E&P) waste liquids provide written notifi- cation, such as a material safety data sheet (MSDS), listing the potential flammability hazard.
2. Ensure that the written procedures for safe op- eration of vacuum trucks incorporate applicable good practices, including techniques to minimize the pos- sibility of exposing the diesel engine to flammable vapor, as provided in API RP-2219, Guidelines for Commercial Exploration and Production Waste Man- agement Facilities.
3. Develop written operating procedures that in- corporate best practices for unloading storage tank waste liquids; such that drivers accurately measure the quantity of liquid removed from the storage tank and minimize removal of product, such as flammable condensate.
4. Ensure that written emergency procedures ad- dress the safe response to abnormal diesel engine op- eration due to a flammable vapor atmosphere. Explain that the normal engine shutoff method will not func- tion as long as flammable vapor continues to enter the intake system.
5. Conduct and document training for all personnel who handle waste liquids, using languages or formats that are clearly understood by all affected personnel.
■ Address the potential flammability hazard as- sociated with E&P waste liquids, emphasizing how the withdrawal procedure is likely to increase the flammability of the vacuum truck contents through unavoidable mixing of product and basic sediment and water (BS&W).
■ Describe operating and emergency response to diesel engine over speed caused by a flammable vapor atmosphere.
For BLSR:
1. Develop a written Waste Acceptance Plan as rec- ommended by API Order No. G00004, Guidelines for Commercial Exploration and Production Waste Man- agement Facilities.
■ Require the shipper or carrier to properly clas- sify the flammability hazard of exploration and pro- duction (E&P) waste liquids.
■ Require the hauler to provide information that identifies the flammability hazard of the material be- fore accepting the load, such as a material safety data sheet (MSDS).
2. Develop and implement written procedures and provide training to employees on the safe handling of all waste liquids delivered to the facility in accordance with API Order No. G00004, Guidelines for Com- mercial Exploration and Production Waste Manage- ment Facilities; and API RP-2219, Safe Operation of Vacuum Trucks in Petroleum Service.
■ Include requirements for proper grounding of trucks and eliminating other sources of ignition (e.g., facility electrical equipment and smoking in unload- ing areas).
■ Ensure that the material is presented in lan- guages or formats that are clearly understood by all affected personnel.
3. Develop written procedures and provide train- ing to employees on unloading all flammable or po- tentially flammable E&P waste liquids.
■ Avoid unloading flammable liquids onto an open work area, such as the mud disposal and washout pad.
■ Include alternative unloading method(s), such as using a closed piping system to minimize vapor generation.
■ Ensure material is presented in languages or formats clearly understood by all affected personnel.
4. Develop written emergency procedures and pro- vide training to employees on response to abnormal