LOSS OF PRIMARY

CONTAINMENT

Open Abdul Razak Abu Bakar

PSM 10052019
 Process Safety Incidents

Pasadena Fires and Tank Farm Fire in

Texas Refinery Thailand
Explosion
Explosion Dec 1999
Oct 1989
March 2005 7 workers dead and 18
23 workers dead and
15 workers dead and injured.
314 injured.
170 injured. Gas leak from tank got
Wrongly open valve of
Open Raffinate Splitter ignited and exploded.
polyethylene reactors.
tower over-filled.
 Process Safety Incidents

Oxygen Fire at Petronas OPU

Oct 2015
No casualties
Improper bolt tensioning of bonnet end flange during turnaround
4 days delay startup and reduced capacity to 43% more than 1 month.

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 LOPC Definition

An unplanned or uncontrolled release of any

material from primary containment, including
non-toxic and non- flammable materials.

(e.g. steam, hot condensate, nitrogen,

compressed CO2 or compressed air)

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 PRIMARY CONTAINMENTS

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 SECONDARY PRIMARY
CONTAINMENT CONTAINMENT

TERTIARY
CONTAINMENT

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 Containments
• Storage Vessels
• Pipeworks
Primary • Valves
• Pumps
Containment • Associated Management and Control Systems
• High level alarm linked to shutdown system.

Secondary • Concrete or clay bunds around storage tanks

Containment

Tertiary • Site drainage and sumps

• Diversion tanks
Containment • Impervious lines and/or flexible booms

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 PRESSURE RELIEVE STEAM TRAPS TO DRAIN
DEVICE

ED
D
LU
C
EX
FLARE, STEAM VENTILATION AND HEATER
STACKS
ED
D
LU
C
EX

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 LOPC | The Groups
LOPC GROUP
Group A Group B Group C

Chemical/Material 1. All Toxic Chemicals 1. Steam and condensate 1. Any chemical to

2. All Hydrocarbons (all grades - pressure environmental
3. All types of Oil/wax and temperature) receptors
4. Water contaminated 2. Water • Solid (dust,
with toxic chemical or • Cooling water particles, LDPE
hydrocarbon(as per • Potable water etc)
Item 1 and 2) • Industrial water • Other chemical
5. Nitrogen • Boiler feed water than Group A and
6. Waste water • Demin water B
• Fire water
*Note : Refer to UNDG • Sewer
chemical list (Total 2292 3. Utilities
chemicals) • Plant Air
• Instrument Air

MAJOR or MINOR Above Threshold : MINOR LOPC MINOR LOPC

LOPC Category MAJOR
Below Threshold :
MINOR
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 LOPC | Categorization

Above Tier 1 Below Tier 2

Tier 1 Tier 2
Material Material
Release Release
Threshold Threshold
Quantity Quantity

Major Minor Slight

Based on API 754: Process Safety Performance Indicators for the Refining
and Petrochemical Industries
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 LOPC | Tolerable limits
N
Prescription Tier 1 Tier 2 Remark
o
• Technical Paper presentation on
‘Understanding and using sealles rotary
Liquid leak rate at pump pump’ in US on 29th October 1998. the
1 mechanical seal and - < 20 drops / min permitted leak is <20 drops/min
packing
• More than this is to report and record
accordingly.

2 CH3OH Leak 1000 kg 100 kg • Limit is according to API 754 Tier 1 & 2 table

3 Lube oil 2000 kg 1000 kg • Limit is according to API 754 Tier 1 & 2 table

4 Sulphuric Acid 2000 kg 1000 kg • Limit is according to API 754 Tier 1 & 2 table

5 Sodium Hydroxide 2000 kg 1000 kg • Limit is according to API 754 Tier 1 & 2 table

6 CO Leak 500 kg 50 kg • Limit is according to API 754 Tier 1 & 2 table

7 CH4 leak 500 kg 50 kg • Limit is according to API 754 Tier 1 & 2 table

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 LOPC | Tolerable limits

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 LOPC | Tolerable limits

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 MAJOR LOPC: METHANOL PIPE BURST AT P1 JETTY
YR 2010

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 MAJOR LOPC AT P1: CHLORINE SCRUBBER BASE
TANK LEAK YR 2011

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 How to prevent LOPC?

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 1. Build-up knowledge and experience through lesson learnt.

2. Eliminate LOPC by reporting and follow-up on closure.

3. Investigate major and minor LOPC and identify root cause.

4. Identify potential LOPC through observation, checklist and audit.

5. Operate the equipment within safe operating limit (SOL).

6. Operate the equipment according to procedure, guideline and work

instructions.

7. Comply with inspection and testing schedule.

8. Develop ERS and SERP (Mechanical Integrity).

9. Perform PASR and PHA (Hazop, RA).

10. Barriers Management.

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 1. Establish LOPC Database to record and track LOPC

E
PL
M
SA

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 2. Perform LOPC analysis

Summary of Tripod Basic Risk Factor

Highest
13% 19%

Procedure

E
Design
25%
PL 13% Training
Error Enforcing Condition
M
Communication
Maintenance Management
SA

Defences
6% 19%
6%

Highest
Highest

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 BRF: Maintenance Management (MM)

 No replacement program for regulator in view of the

material used (plastic) which has a short life span.
(SDV-2980 30 barg fuel gas export to Plant 2 instrument

E
gas regulator leaking)

PL
 No specific PM check as this is maintenance free
fittings. (F-104 level gauge drain line tubing dislodge
M
cause LOPC at Unit 300, Plant 1)
SA

 Failure to make defect equipment safe. (Sulphuric Acid

splashed onto Mechanical Technician due to F-508 Tank
loss of Primary Containment resulting in Medical
Treatment Case)

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 2. Develop Action Item and Tracking

No. Action Items Responsible Accountable Dateline Status

E
1 Develop ERS and Maintenance Head of 3rd
replacement Planner Maintenance Qtr ,2019

PL
program

M
2 To review PM Maintenance Head of June,
SA Planner Maintenance 2019

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 Develop KPI

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 LOPC KPI FY2012

NO COMMON KPI WHO BASE STRETCH YIELD

CEO,
HOD,
1 Process Safety Incident 0 NA NA
HOS,
Exec

E
CEO,
HOD,

PL
2 Major LOPC 0 NA NA
HOS,
Exec

M HOD,
SA
3 Reportable Minor LOPC HOS, 8 4 2
exec

HOS,
4 Recordable Minor LOPC (Base = 4 x Q1) -5% -20% -50%
exec

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 LOPC | Reporting
LOPC REPORTING
INTERNAL PCG DOD iHSE

All Group A, B & C

All Group A All Group A All Group A
Recording All Major and
Major and Minor Major and Minor Major and Minor
Minor

Frequency Weekly Monthly Monthly Monthly

Area Operation
Engineer/ HSE with HSE with HSE with
Focal Person Shift Executives
input from PSM input from PSM input from PSM
through SAP

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 HOW?

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 THANK YOU…..

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