There is a need for increased operator awareness when using temporary equipment on offshore platforms, federal officials said.
Some temporary equipment may be a potential ignition source and can range from small items such as portable welding sets to large skid-mounted packages (e.g., temporary generators, air compressors, hydraulic power packs, well-testing equipment, process equipment, etc.), said investigators at the Bureau of Safety and Environmental Enforcement.
Recent examples of unsafe (potential ignition sources) use of temporary equipment include:
- An incident of noncompliance (INC) was reported on a portable air compressor powered by a diesel engine not rated for a hazardous area. It was running in the Class 1, Division 2 area next to an in-line heater treater. The heater was in service and treating hydrocarbons. The air compressor had the potential to ignite the hydrocarbons if an incident (a leak) was to occur.
- A diesel engine-driven power pack (hydraulic supply) was used to operate the temporary power tongs. The power pack was in a hazardous classified area above the shakers and within 10 feet of the drilling fluid return flowline. The shale shakers and drilling fluid return flowline had the potential to contain and release flammable gases and vapors.
- A portable fan was not rated for use in the Class 1, Division 2 area. It was operating next to the sand trap tank located under the gas buster and adjacent to the mud tank. The fan was connected to a power source with a non-explosion- proof extension cord.
Temporary equipment should be held to the same standards as the permanent equipment it is replacing or supporting. When using temporary equipment, ensure ignition sources are identified and controlled using proper hazard analysis, ignition prevention devices and/or Emergency Shutdown System (ESD). To that end, BSEE recommends operators and contractors consider the following:
- Inspecting and reviewing maintenance records and certificates of temporary equipment before it arrives at the facility. Temporary equipment rated for use in hazardous classified areas may be unsafe if enclosures are damaged or wiring is exposed, damaged, or improperly modified.
- Requesting approval from BSEE for installation and use of temporary equipment on production platforms that handle hydrocarbons or other Class 1 gases or vapors. Seek further clarification from BSEE if any temporary equipment may affect BSEE-approved drawings in accordance with 30 CFR 250.867 “Temporary Quarters and Temporary Equipment.”
- Ensuring your Safety and Environmental Management System program addresses temporary equipment requirements and safely returns to normal operation following the removal of the temporary equipment.
- In accordance with 30 CFR 250.1917, conducting a Pre-Startup Safety Review before temporary equipment is implemented to prevent unforeseen hazards from causing a significant safety incident.
- In accordance with 30 CFR 250.1912, ensuring personnel follow the company’s Management of Change policy and procedures before installing and operating temporary equipment on the facility.
- Before introducing and installing temporary equipment to the facility, completing and documenting a risk assessment of all the equipment involved (permanent and temporary equipment). Implement mitigation of potential hazards resulting from the temporary equipment’s addition, use, failure, and removal.
- Establishing safety guidelines, procedures, and training addressing the temporary equipment (e.g., new gas detectors, updated alarm and ESD logic diagrams, additional means of firefighting, etc.)
Ensuring the potential impacts of the temporary equipment’s installation on existing safety systems and barriers are identified, publicized, and coordinated, and area classification drawings, egress routes, etc. are updated. - Updating existing engineering drawings and documents to reflect all operational changes and informing all appropriate personnel.
- Ensuring policies and procedures include requirements for installation, training, removal, testing, maintenance, and hazard control using the temporary equipment.
- Ensuring responsibilities are assigned to individuals with clearly defined lines of communication between various parties (e.g., operator and contractors).
Temporary equipment like this process skid should be held to the same standards as the permanent equipment it is replacing or supporting.
Source: BSEE