Process Safety Evaluation of a Refrigerated LPG Facility
For the Commonwealth of Pennsylvania, this expert headed an independent, third-party review of the public and environmental safety of a refrigerated liquefied propane gas (LPG) facility. The facility is located in Schaefferstown, near Harrisburg, Pennsylvania. The review became necessary when local citizens expressed serious concerns about a large addition to the existing facility.
The original facility contained 21 tanks, each of 30,000 gallon capacity. These tanks are used to store liquid propane at ambient temperature and pressures up to 250 psig. The addition consists of a large refrigerated facility that stores liquefied propane at -44ºF, but at atmospheric pressure. It includes two ten-million gallon above-ground storage tanks and the necessary pumps, compressors, condensers, piping, valves and other ancillary equipment.
Construction in compliance with API 2510 and NFPA 58, Chapter 8 was prescribed by the Commonwealth in granting the client permission to add to its existing facility. Many other codes and standards are referenced by these two documents. The most significant ones are API 620, including Appendix R, Low Pressure Storage Tanks for Refrigerated Products; ANSI?ASME B31.3 for piping design and construction; and API 2510A for guidance on fire protection.
In performing the review, the client’s design and construction of the facility addition were addressed, plus its planned management of process hazards during plant startup, operation, inspection, maintenance, and future modification. The plant is tightly integrated into the existing facility, so the entire facility was considered when fire safety and management of process hazards were reviewed. Public and environmental safety were also addressed from the standpoints of system reliability, mechanical integrity, the reliability of the flare system, the reliability of the compression-refrigeration system (including its supply of electric power), and the behavior of propane vapor-clouds. In the particular area of fire protection, it was recommended, and the client agreed to make very significant improvements.
Management of process hazards was evaluated using the OSHA regulation entitled, Process Safety Management of Highly Hazardous Chemicals, (29 CFR 1910.119). This regulation became law after the construction of the addition to the Schaefferstown facility was begun. Therefore its use was not originally required by the Commonwealth. Nevertheless, it is an excellent tool for evaluating plant safety, and this expert recommended that it be applied to the project. This OSHA regulation addresses, in part, procedures for operation, training, maintenance, management of design change, and otheraspects of plant safety not addressed merely by adequate original design and construction.
This expert testified as to the safety of the modified facility at three separate hearings in Commonwealth Court, presided over by the then President Judge, David Craig. Ultimately, the Court permitted construction of the facility to be completed, and operation to begin.
To see the resume of the expert associated with this case study, see the link below.