North Star QRA Update - Chlorine and VCM plant (Rafnes) Report for: Wood - Direktoratet for samfunnssikkerhet og ...
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Working together for a safer world North Star QRA Update Chlorine and VCM plant (Rafnes) Report for: Wood Report no: PRJ11090011 Rev: Final Date: 11 January 2019
Document history Revision Date Description/changes Changes made by Draft 30.11.2018 First issue of report Andrea Risan / Ingebjørg Valkvæ / Stian Jensen Final 11.01.2019 Comments from client Andrea Risan / Ingebjørg Valkvæ incorporated Executive summary Lloyds Register (LR) has been engaged by Wood and INOVYN Norge to conduct an update of the quantitative risk assessment (QRA) of the Chlorine and VCM plant at the Rafnes Industrial Site (Grenland, Norway) to accommodate any changes in the risk picture due to the North Star project. The North Star project includes implementation of several modifications to the facility which will increase the total production capacity with around 10 %. The QRA update is conducted by using the existing risk model of the facility and adding the events potentially caused by the planned modifications. A similar approach as applied in the existing QRA is applied in the risk assessment of the North Star modifications. In that manner the risk level before and after the modification can be compared. The risk acceptance criteria proposed by DSB are applied in the study. Hence, the focus in the study is directed towards major accident events that may cause fatal exposure outside of the boundary of the facility. The main conclusion of the study is that the North Star project only contributes with a modest risk increase to third parties, and that the main risk drivers remain unchanged after the update. It is still toxic releases of chlorine and HCl that dominates the risk picture, in addition to BLEVE events in the VCM storage area. The calculated risk picture is shown in the below figure. Report no: PRJ11090011 Rev: Final Page ii Date: 11 January 2019 ©Lloyd’s Register 2019
Glossary/abbreviations ALARP As Low As Reasonably Practicable AT The Norwegian Labour Inspection Authority (Arbeidstilsynet). A governmental agency under the Ministry of Labour, focused on occupational safety and health BLEVE Boiling Liquid Expanding Vapour Explosion CFD Computational Fluid Dynamics DSB Norwegian Directorate for civil protection (Direktoratet for Samfunnssikkerhet og Beredskap) EDC Ethylene DiChloride, 1,2-dichloroethane ESD Emergency Shut Down EX Ex-equipment or explosive protected equipment, both electric and mechanical. FTM Forslag Til Modifikasjoner Hazardous substances Flammable, reactive, pressurised and explosive substances HAZID Hazard Identification Report no: PRJ11090011 Rev: Final Page iii Date: 11 January 2019 ©Lloyd’s Register 2019
HCl Hydrogen Chloride HTDC High Temperature Direct Chlorination IR Individual Risk LFL Lower Flammability Limit LNF Landbruk-, Natur- og Friluftsområde LOC Loss Of Containment OHCL Oxy HydroChlorination PSD Process Shut Down QRA Quantitative Risk Analysis RAC Risk Acceptance Criteria Safeti Safeti QRA software tool - A user-friendly, industry standard method for carrying out Quantitative Risk Assessments (QRA) of onshore process, chemical and petrochemical facilities. Developed by DNV-GL. Third party (3rd person) People outside the production plant that may be affected by its activities. (2nd person: People that are not directly related to the operation of the plant, but benefit from being close to the plant 1st person: People who are directly involved in the operations of the plant, i.e. the employees at the plant) VCM Vinyl Chloride Monomer Report no: PRJ11090011 Rev: Final Page iv Date: 11 January 2019 ©Lloyd’s Register 2019
Table of contents Page 1 Introduction 1 1.1 Background 1 1.2 Objective 1 1.3 Scope of work 1 1.4 Presumptions and limitations 1 1.4.1 Presumptions 1 1.4.2 Limitations 1 1.5 Regulations and standards 2 2 Framework 2 2.1 Methodology 2 2.2 Assumptions and input data 4 2.3 Acceptance criteria 4 3 System description 5 3.1 General description 5 3.2 Process description 5 3.2.1 Chlorine – INOVYN scope 5 3.2.2 VCM – Wood scope 6 3.3 North Star project 7 3.3.1 VCM plant modifications 7 3.3.2 Safety measures for the new HTDC module 8 3.3.3 Water curtain in the HTDC module 8 3.3.4 Chlorine plant modifications 9 3.4 Safety measures 9 3.4.1 Pressure monitoring and shutdown 9 3.4.2 Chlorine absorption system 9 3.4.3 Gas detection and emergency shutdown 9 3.4.4 Fire proofing of storage spheres 9 3.4.5 Emergency preparedness 9 4 Selection of hazardous events 9 4.1 Existing QRA 9 4.2 Scenarios for the new HTDC module 11 4.3 Scenarios for the new OHCL reactor 12 4.4 Risk screening of other North Star modifications 12 5 Frequency analysis 14 6 Consequence analysis 15 6.1 Event tree 15 6.2 Fatality criteria 16 6.3 Consequence modelling 16 7 Risk picture and risk evaluation 18 7.1 Total risk picture 18 Report no: PRJ11090011 Rev: Final Page v Date: 11 January 2019 ©Lloyd’s Register 2019
7.2 Risk from the chlorine plant 19 7.3 Risk from the VCM plant 21 7.4 Individual risk at nearest resident 24 8 Uncertainties 26 9 Potential conservatism in the QRA 26 9.1 Release durations and transient effects 26 9.2 Terrain effects 27 9.3 Release modelling 27 9.4 Event frequencies 27 9.5 BLEVE 27 9.6 Flash fire envelope 27 10 Conclusion and recommendations 28 10.1 Recommendations 28 10.2 Conclusions 28 11 References 29 Appendix A – Assumptions and input data Appendix B – Risk screening workshop – VCM plants Appendix C – Risk screening workshop – Chlorine plant Report no: PRJ11090011 Rev: Final Page vi Date: 11 January 2019 ©Lloyd’s Register 2019
1 Introduction 1.1 Background Lloyd’s Register (LR) has been engaged by Wood and INOVYN Norge to carry out an update of the quantitative risk assessment (QRA) for INOVYN’ s Chlorine and Vinyl Chloride Monomer (VCM) plant at the Rafnes Industrial Site (Rafnes) conducted in 2015 (Ref. /1/). The North Star project introduces several modifications to the Chlorine and VCM plant in order to increase the production capacity of the plant. The modifications include: • Installation of a new High Temperature Direct Chlorination (HTDC) module • Replacing the existing Oxy HydroChlorination (OHCL) reactor with a new one • Several other modifications to process vessels and equipment in the VCM plant to allow for the increased capacity • Installation of a new electrolyser in the chlorine plant • Replacement of the hydrogen compressor, chlorine compressor and chlorine cooler. INOVYN Norge is classified as a so called major accident facility according to “Storulykkeforskriften” (Ref. /9/). Hence, the facility is required by regulations to minimize the risk for major accidents. The QRA can be seen as part of the effort to reach this objective. 1.2 Objective The objective of the QRA update is to investigate the impact of the North Star project on the existing risk picture at INOVYN’s facility at Rafnes. The modifications will be assessed and included in the existing QRA of the facility. Potential risk drivers will be identified, and it will be evaluated if the project introduces significant change in the risk for third parties. The proposed risk acceptance criteria by DSB (Ref. /2/) are applied in the risk assessment. 1.3 Scope of work The scope of work involves using the risk model developed in the existing QRA of INOVYN’s facility at Rafnes as a starting point. The risk model is implemented using the Safeti software. Events introduced by the North Star project will be handled in a similar manner as in the existing QRA by using, e.g., the same event frequency references, fatality criteria and overall assumptions as a basis. The focus in the QRA is to address major accidental events that may influence the extent of risk zones (“hensynssoner” in Norwegian) around the facility. 1.4 Presumptions and limitations 1.4.1 Presumptions The following presumptions apply to the study: 1. Normal operation including regular shut down and maintenance and start up activities are the base of the QRA. 2. If risk reducing measures are disengaged during operation, it is a prerequisite that compensating measures are implemented so that the barrier’s function is kept. If compensating measures are not taken, the QRA is not valid. 1.4.2 Limitations The following limitations apply to the study: 1. Events while ship is at sea or mooring are not included 2. The ships on-board systems (tanks, pumps, piping) are not included Report no: PRJ11090011 Rev: Final Page 1 Date: 11 January 2019 ©Lloyd’s Register 2019
3. The tunnel with export pipelines to Herøya is not included. A separate risk assessment for the tunnel has been conducted, Ref. /3/ 4. Escalation effects have not been quantified. An escalation is defined as an initial event on the site, e.g. a fire that impairs other equipment containing flammable or toxic material on the same site. Thereby leading to a larger fire or more severe toxic effects. One exception is the inclusion of Boiling Liquid Expanding Vapour Explosion (BLEVE) events in the QRA. A BLEVE can be considered as an escalated event, since a prerequisite for such a scenario to occur is long exposure time to relatively high heat loads, i.e. fire exposure. 5. Domino effects, e.g. events where fire and explosion triggers new release scenarios (or other effects) from equipment in adjacent facilities, have not been calculated specifically. Domino effects are discussed in the risk analysis from 1991 and 1998 (Ref. /4/ and /5/) and in the report "Vurdering av dominoeffekter mellom fabrikkanleggene på Borealis AS, Noretyl AS og Hydro Polymers AS i forbindelse oppdatering av Sikkerhetsrapporten for Hydro Polymers og Noretyl", Ref. /6/. 1.5 Regulations and standards The most central regulations related to health, safety and the environment (HSE) for the onshore chemical process industry which come under the supervisory authority of the DSB and AT are found in the HSE regulations and the working environment regulations. The following relevant regulations apply for INOVYN Norge and set the premise for the current risk assessment: • DSB: "Forskrift om håndtering av brannfarlig, reaksjonsfarlig og trykksatt stoff samt utstyr og anlegg som benyttes ved håndteringen (forskrift om håndtering av farlig stoff) ", FOR-2009-06-08- 602, 8. juni 2009, Ref. /7/. • DSB Temaveileder ”Sikkerheten rundt anlegg som håndterer brannfarlige, reaksjonsfarlige, trykksatte og eksplosjonsfarlige stoffer: Kriterier for akseptabel risiko”, May 2013, Ref. /8/. • Storulykkeforskriften FOR-2005-06-17-672, Council Directive 96/82/EC of 9 December 1996 on the control of major-accident hazards involving dangerous substances, Ref. /9/. Also note, that since the QRA was established, DSB has introduced a new guideline for conducting QRAs, i.e. “Retningslinjer for kvantitative risikovurderinger for anlegg som håndterer farlig stoff” (Ref. /10/). Those new guidelines are not adopted at the present stage. 2 Framework 2.1 Methodology The overall methodology used in the QRA is illustrated in Figure 2.1. Report no: PRJ11090011 Rev: Final Page 2 Date: 11 January 2019 ©Lloyd’s Register 2019
Figure 2.1 - QRA methodology The building blocks of the study are briefly discussed below. 1. Risk acceptance criteria The acceptance criteria are used to evaluate the risk and aid in decisions regarding need for risk reducing measures. The acceptance criteria applicable for this project are presented in Chapter 2.3. 2. System definition A presentation of the system included in the scope of the QRA and its limitations are presented in Chapter 3. 3. Hazard identification A hazard identification (HAZID) workshop was performed at Rafnes during the previous QRA update in 2015 and was used to define relevant scenarios for the QRA. A risk screening workshop identifying the possible hazards related to the modifications of the North Star project was performed at Rafnes in October 2018. The results from the risk screening workshop are summarized in Chapter 4 and documented in Appendix B and C. 4. Frequency analysis The frequency analysis is performed to select and define a set of scenarios that represent the risk posed by the Chlorine and VCM plant. The frequency analysis is described in Chapter 5. 5. Consequence analysis The possible consequences from each scenario from the frequency analysis are simulated using the software Safeti. The consequence analysis is described in Chapter 6. 6. QRA results – Risk picture and risk evaluation The risk picture is the result of the frequency analysis and the consequence analysis. The resulting risk picture for the Chlorine and VCM plant is presented in Chapter 7. The risk is evaluated by comparing the resulting risk picture with the applied RAC. 7. Risk-reducing measures Risk-reducing measures are recommended in order to meet the acceptance criteria or to further reduce the risk in line with ALARP. Recommendations are given in Chapter 10. Report no: PRJ11090011 Rev: Final Page 3 Date: 11 January 2019 ©Lloyd’s Register 2019
2.2 Assumptions and input data All assumptions made in the study are presented in the assumption sheets in Appendix A together with any data used for the study including wind data, population data and vulnerabilities. 2.3 Acceptance criteria This study applies the Risk Acceptance Criteria (RAC) proposed by Norwegian authority DSB (Ref. /8/) in their guidance document regarding RAC for facilities storing and handling hazardous substances. The RAC are based on the individual risk contours calculated for the facility, and defines a number of zones for special consideration. The RAC are presented in Table 2-1 and Figure 2.2. Table 2-1 - Acceptance criteria, defined zones for consideration Zone for Acceptance criteria Provisions for the zone (accepted consideration object and activities in the zone) Inner zone IR is higher than 1E-5 per Primarily within the facility’s property year limits, extension into LNF-areas may be allowed. Intermediate zone IR is in between 1E-5 and Public roads, railway, quays are accepted 1E-6 per year and also industries and offices. No permanent housing is permitted, though some scattered housing may be permissible under certain circumstances Outer zone IR is in between 1E-6 and Housing, public facilities, shops, smaller 1E-7 per year overnight accommodations and other usage for the general public accepted Outside outer zone IR is lower than 1E-7 per Schools, hospitals, shopping centres, year hotels, large venues etc. should be outside the outer zone Figure 2.2 - Illustration of safety zones around a plant with marked iso-contours that defines the zones (Ref. /8/) Report no: PRJ11090011 Rev: Final Page 4 Date: 11 January 2019 ©Lloyd’s Register 2019
3 System description 3.1 General description The INOVYN Norge production plant for vinyl chloride monomer, VCM, is located at Rafnes industry facility in Bamble community in Norway. Figure 3.1 show an overview of the Rafnes industrial site and the surrounding areas of the Chlorine and VCM plants. The closest residential area, Herre, is located west of the chlorine plant. The closest house is approximately 400 m from the fence around the chlorine plant. Highway 353 marks the property boundary towards west. The road is at a higher elevation than the plant and there is also a ridge between the plant and the road. There is also a smaller road that goes alongside the plant fence before it connects to the highway again. This road is public, but can be blocked in case of an emergency. Figure 3.1 – Overview of the Chlorine/VCM plant and the surrounding areas Located southeast on the Rafnes industrial site and neighbouring the VCM plant is Noretyl AS ethylene plant. A polyethylene plant owned by INOVYN Bamble AS lies further to the southeast, at the Rønningen industrial site (not shown in Figure 3.1). This report presents the risk introduced from the North Star project associated with the Chlorine and VCM plant. 3.2 Process description 3.2.1 Chlorine – INOVYN scope There are two almost identical production lines (Chlorine 1 and 2) with membrane electrolysers for production of chlorine. Chlorine is produced on the anode side and hydrogen and caustic soda on cathode side. The moist chlorine gas is cooled, filtered and dried with sulphuric acid before being compressed to approx. 5.5 bar(g) and sent to the VCM plant. The chlorine gas from both line 1 and 2 is delivered in a single 250 mm header. Report no: PRJ11090011 Rev: Final Page 5 Date: 11 January 2019 ©Lloyd’s Register 2019
The hydrogen gas is cooled, filtered, dried and compressed and sent to the VCM plant and to the neighbouring industry Noretyl to be used as raw material or fuel gas. The caustic soda is concentrated to 50 % using evaporation and then stored. The caustic soda is exported by trucks and shipped by boats to several customers. The chlorine plant is divided into the following areas: • Water purification • Brine • Cell room • Caustic soda • Hydrogen • Lean brine dechlorination • Emergency scrubber/recovery chlorine • Chlorine. 3.2.2 VCM – Wood scope VCM is produced from the intermediate substance Ethylene DiChloride (EDC). EDC is produced in two separate processes in the VCM plant. The first process is by direct chlorination, using ethylene gas from Noretyl and chlorine gas from the chlorine plant. The second is by oxychlorination, using hydrogen chloride, hydrogen gas, ethylene gas and air. The EDC from the direct chlorination and oxychlorination is purified (distilled to remove light and heavy bi products) and intermediately stored before being sent to the cracking furnaces. VCM is produced by cracking EDC to VCM and Hydrogen Chloride (HCl) at a temperature of approx. 500 °C and 20 bar(g) pressure. The gas out of the cracking furnaces still holds a large amount of EDC and a number of steps are needed to separate VCM, HCl and EDC from the raw gas. The EDC is condensed by cooling and HCl stripped off by reducing the pressure. Finally a distillation process removes the last traces of HCl and EDC and by-products from VCM. The pure VCM is stored as liquid in pressurized spherical tanks before being offloaded by ship or pumped through piping under the Frierfjord to INOVYN Norge PVC plant at Herøya. Utility systems include steam and condensate system, cooling water system, waste water treatment, incinerators for vented gases and fuel gas system. The VCM plant is divided into process area, tank farm, control centre, flare and quay. Production, as well as sewage treatment and combustion of bi-products, takes place in the process area. The process area is further divided into a number of plant areas as listed below: • 1100 - Oxychlorination • 1200 - EDC-recovery • 1300 - EDC purification • 1400 - Cracking • 1500 - VCM-purification • 1600 - Direct chlorination • 1700 - HCl-unit • 1800-1900 - Waste water treatment • 1800 - Incinerator • 2700 - EDC/VCM/by-product storage • 3000 - Jetty 2. Report no: PRJ11090011 Rev: Final Page 6 Date: 11 January 2019 ©Lloyd’s Register 2019
3.3 North Star project The North Star project introduces several modifications to increase the capacity of the Chlorine and VCM plant. The modifications are designed to increase the overall production rate of the plant with around 10 %. 3.3.1 VCM plant modifications The main modifications to the VCM plant are installation of a new HTDC module and an OHCL reactor: • The HTDC module is a new module at INOVYN and will operate in parallel to the existing LTDC module. It is expected to have a footprint of approximately 28 m x 8 m with three levels. The module is relatively congested with process equipment and reactors. A process flow diagram of the new HTDC module located in the VCM plant is shown in Figure 3.2 • The OHCL reactor will replace an existing reactor. The flow throughput and the volume of the reactor will be increased. The existing reactor will be put out of operation and work as a spare reactor. In addition, several minor modifications, or FTMs (“Forslag Til Modifikasjoner”), will be made to allow for the increased production capacity. Details of the scope of these modifications can be found in Appendix B. Figure 3-3 illustrates the locations of the North Star modifications in the VCM plant. Figure 3.2 – Process flow diagram (PFD) of HTDC module Report no: PRJ11090011 Rev: Final Page 7 Date: 11 January 2019 ©Lloyd’s Register 2019
Figure 3-3 – VCM plant – Location of FTMs. The yellow box (left) is the location of the new HTDC module, and the orange box (right) is the location of the OHCl reactor 3.3.2 Safety measures for the new HTDC module The North Star modifications include installation of gas detection systems in the new HTDC module. The following gas detection systems will be installed: • EX detectors for explosive gas detection • Chlorine gas detectors (point detectors) • Sniffing detectors for detection of toxic gas releases (low concentrations). Further, there will be replacement of the existing flame arrestor and fire water monitor for the HTDC module. Fire water monitor X1032/12 shall be replaced by a new remotely controlled fire water monitor (X1032/16). Fire water monitor X1032/10 will be moved to ensure better coverage of the HTDC area in addition to the originally covered process areas. 3.3.3 Water curtain in the HTDC module There is a discussion in the North Star project regarding the possible implementation of a water curtain between the HTDC module and the vessels in area 1600. The main purpose of such a water curtain would be to reduce the likelihood of escalation from an accidental event in the HTDC module to the wash tanks in area 1600. In general, water curtains are used to protect personnel from high heat radiation levels during, e.g. escape or other special events such as an ignited flare during a blow down situation. For protection of vessel containing hazardous substances, it is probably more optimal to apply a deluge system. Fire water can then be applied over the tanks to enhance the cooling effect. The HTDC module is already covered be two remotely controlled fire monitors. One of which has a direct line of sight to the abovementioned vessels. This is likely to be sufficient. However, to further quantify the benefit of a deluge system, in addition to fire monitor, one could establish: • The consequence of vessel ruptures. • The probability, or frequency, of fires that may lead to loss of containment of hazardous substances in the 1600 area. Report no: PRJ11090011 Rev: Final Page 8 Date: 11 January 2019 ©Lloyd’s Register 2019
If INOVYN has a criteria for an unacceptable escalation this can be applied in the decision making, when the consequence and likelihood of vessel rupture (escalation) has been established. If the consequence of a vessel rupture is low, i.e., if it does not significantly increase the severity of the event, a deluge system is unlikely to be in the ALARP range of measures. A similar argument can be made if the frequency of fires that may cause an escalation is low. The above discussion assumes that there is no BLEVE potential in area 1600. The matter should be assessed in more detail if that is not the case. 3.3.4 Chlorine plant modifications The modifications to the chlorine plant are: • Installation of a new electrolyser • Increased capacity of the chlorine compressor, hydrogen compressor and chlorine cooler. Details of the scope of these modifications can be found in Appendix C. 3.4 Safety measures 3.4.1 Pressure monitoring and shutdown The pressure is monitored in the chlorine header and many other places in the process. Detected very low pressures, e.g. in case of a larger leak, lead to automatic shutdown. 3.4.2 Chlorine absorption system In an event of leak or failure in the chlorine plant the production in the cells are stopped and the emergency absorption system is started. The chlorine gas is absorbed in sodium chloride, producing sodium hypochlorite. A low pressure is created with ejectors and the produced chlorine gas is sucked through the absorption system. 3.4.3 Gas detection and emergency shutdown Chlorine gas detectors are located both indoors in the chlorine plant and outdoors in the chlorine and VCM plant. There is no automatic shutdown but an operator will directly suit up in gas protection gear and look for the leak. There is also VCM gas detectors located in the process area and around pumps in the storage area. The detectors are very sensitive and detect at ppm level. No automatic shutdown and procedures are the same as for chlorine. 3.4.4 Fire proofing of storage spheres The VCM storage spheres are fitted with fire detection and deluge in order to minimize risk of escalation and possible BLEVE event in the storage area. 3.4.5 Emergency preparedness At Rafnes and Rønningen there is a common emergency preparedness plan and organisation. Norward is a company providing services within industrial emergency preparedness and they are localized in the fire station at Rafnes. They provide their services to the plants on Rafnes and Rønningen. 4 Selection of hazardous events This section selects the units or process segments that may cause hazardous events that can influence the risk picture around the facility. 4.1 Existing QRA The events included in the present study are based on evaluations made in the previous QRA update in 2015, Ref. /1/. The general assumptions regarding each subsystem are presented in Table 4.1. Report no: PRJ11090011 Rev: Final Page 9 Date: 11 January 2019 ©Lloyd’s Register 2019
Table 4.1 – General assumptions regarding scenario selection, ref. /1/ Part of plant Scenarios included in General assumption the QRA Chlorine plant Water purification No scenarios No (or limited) hazardous substances Brine No scenarios No (or limited) hazardous substances Cell room Cl2 header in the cell Leaks from individual cells and anolyte/ room is considered catolyte solutions are not considered to pose a threat outside the cell room Leak of H2 is assumed to give fire in the cell room with only local effects. Domino effects towards Cl2 system is considered negligible Caustic soda No scenarios Leaks of NaOH solution is assumed to give only local effects Hydrogen H2 header to VCM is Leaks of H2 from compressors etc. are considered assumed to give only local effects. Domino effects towards Cl2 system is considered negligible Lean brine No scenarios Small amounts of Cl2, low pressures vacuum- dechlorination 0.2 bar(g) and leaks are assumed to give only local effects. Leaks of anolyte solution is assumed to give only local effects Emergency If pumps P3704, P3706 Pumps are connected to emergency power. scrubber/recovery stops while production Small amounts of Cl2, low pressures vacuum- chlorine trips 0.2 bar(g) and leaks are assumed to give only local effects Chlorine All leak points of Cl2 Leak of H2SO4 is assumed to give only local gas are considered effects. No liquid Cl2 at any point assumed VCM plant 1100 Leaks of C2H4 is Leak of EDC (C2H4Cl2) is assumed to give only oxychlorination considered local effects and no scenarios for EDC (incl. Leaks of HCl is reactor V1101/V1106 (OHCL)) are included in considered the calculations Leaks of H2 is considered NH3-tank considered 1200 EDC-recovery No scenarios Leak of EDC and by-products are assumed to give only local effects 1300 EDC No scenarios Leak of EDC and by-products are assumed to purification give only local effects Report no: PRJ11090011 Rev: Final Page 10 Date: 11 January 2019 ©Lloyd’s Register 2019
Part of plant Scenarios included in General assumption the QRA 1400 cracking Fuel gas considered Release from crackers will be above auto No scenarios for ignition and a jet flame with local effects is EDC/VCM/HCl assumed for all releases. according to comments Gaseous release from top system with HCl, VCM and EDC assumed to only give local effects. EDC is the main component in bottom system and refluxes and the same consequences as 100 % EDC (only local effects) are assumed 1500 VCM- All liquid leaks Leaks of EDC are assumed to only give local purification considered (except for effects. liquid in C1502 and Gaseous releases of HCl/VCM/EDC mixtures EDC return) are assumed to give only local effects Gaseous releases of pure HCl are considered 1600 direct Leaks of C2H4 is Leaks of EDC are assumed to only give local chlorination considered effects and no scenarios for EDC (incl. Leaks of Cl2 is reactors V1601A/B (LTDC) and V1651 considered (HTDC)) are included in the calculations 1700 HCl-unit Fuel gas considered Leaks of chlorinated waste, fuel gas, HCl and NaOH solutions are assumed to give only local effects 1800-1900 waste No scenarios No (or limited) hazardous substances water treatment 1800 incinerator Fuel gas considered Pressure in vents etc. is assumed to be ~ atmospheric and leaks are assumed to give only local effects 2700 EDC/VCM/by- VCM storage Leak of EDC and by-products are assumed to product storage considered (liquid give only local effects releases) 3000 Jetty 2 Loading/unloading of The total annual time of operation for VCM VCM considered (liquid loading arms are 115 hour per year releases) 4.2 Scenarios for the new HTDC module All streams downstream the HTDC reactor consists of mainly EDC and some nitrogen. As stated in Table 4.1, leaks of EDC in area 1600 (Direct chlorination) are assumed to only give local effects and no scenarios for EDC are included in the risk evaluation. Neither is Nitrogen a hazardous substance in the context of the QRA. Hence, only leak from the feed lines of ethylene and chlorine, upstream the HTDC reactor (including process tie-ins), are evaluated as additional hazardous events in the update of the risk analysis for the VCM plant. Report no: PRJ11090011 Rev: Final Page 11 Date: 11 January 2019 ©Lloyd’s Register 2019
4.3 Scenarios for the new OHCL reactor The existing OHCL reactor (V1101) will be replaced by a new reactor (V1106) to allow for increased capacity. As stated in Table 4.1, leaks of EDC in area 1100 (Oxychlorination) are assumed to only give local effects and no scenarios for EDC, including the OHCL reactor V1101/V1106, are included in the calculations. Hence, replacement of the reactor itself does not cause any additional hazardous events. The ethylene and chlorine streams towards the existing OHCL reactor are already included in the risk model, however, process tie-ins to the new reactor will create additional leak potential and are therefore also evaluated in the update of the risk analysis for the VCM plant. 4.4 Risk screening of other North Star modifications A risk screening workshop was held at Rafnes to evaluate the potential risk contribution of each FTM in the context of the QRA. Representatives from Wood, INOVYN and LR were present at the workshop. In addition, two representatives from Bilfinger participated in the site walk through of the chlorine plant. The workshop participants are listed in Table 4.2. Table 4.2 – Participant list for the risk screening workshop Name Company Kjetil Kristoffersen Wood Roger M. Pettersen INOVYN Øystein Palmgren INOVYN Stian Jensen LR Andrea Risan LR Ingebjørg Valkvæ LR Table 4.3 summarises the FTMs and their relevance to the QRA. A detailed evaluation of the FTMs and their risk contributions is documented in Appendix B and C. Table 4.3 – Summary of risk evaluation of FTMs for the Chlorine and VCM plant FTM Area Scope description Medium Inclusion in No. QRA? VCM plant FTM 01 1100 Replacement of line 400-RP 1069 to EDC gas No DN500 FTM 02 1100 V1105 modifications HCl gas Yes FTM 03 1100 H1104 replacement HCl gas, Yes condensate and steam FTM 04 1100 Increase oxygen feed to OHCL with Condensate, No new heat exchanger H1151 steam, N2, enriched air and LOX FTM 05 1100 OHCL reactor cooling loop Boiler feed No water FTM 06 1000, 51 New IPS line to Chlorine plant Steam No FTM 07 1300 P1305A/B/S replacement EDC gas No Report no: PRJ11090011 Rev: Final Page 12 Date: 11 January 2019 ©Lloyd’s Register 2019
FTM Area Scope description Medium Inclusion in No. QRA? FTM 08 Several Replacement of several control Fuel gas, No valves NaOH, Ethylene, Crude EDC liquid, EDC liquid, EDC/VCM/HCl condensate, VCM liquid FTM 09 1100 V1102 Modification of demister Steam No FTM 11 1400 Replacement of RP4015, RP4057 EDC gas, No and RP4124 VCM, HCl FTM 12 1400 New P1404S EDC liquid No FTM 13 1400 New H1405C and new V1407 (new EDC/VCM/HCl No balcony on str. 6) condensate and cooling water FTM 14 1400 Replacement of H1403 EDC/VCM/HCl No gas FTM 16 2700 Replacement of RP5081 EDC liquid No FTM 17 1500 Replacement of valves on C1501 EDC/VCM No liquid, EDC/VCM gas, steam, condensate FTM 18 1500 DBB on C1502 EDC/VCM gas Yes and liquid FTM 19 1500 New H1541 with access platform EDC/VCM 2- Yes phase FTM 20 1500 Replacement of H1551 and increase EDC, EDC No diameter on RP5056 and RP5190 liquid FTM 21 1500 Install by-pass of H1512 EDC liquid No FTM 22 1500 Replacement of H1510 Cooling Yes water, VCM liquid FTM 23 2700 Existing FTM (M50913-06) EDC No Replacement of P2752 FTM 29 2700,1300 New impeller P1507 EDC No FTM 31 Utility tie-ins Various Yes FTM 32 Process tie-ins Various Yes FTM 33 1800 Vent gas scrubber ANH Nitrogen No FTM 34 1650 Analyser house modifications N/A No FTM 35 Underground piping H2O No Report no: PRJ11090011 Rev: Final Page 13 Date: 11 January 2019 ©Lloyd’s Register 2019
FTM Area Scope description Medium Inclusion in No. QRA? FTM 36 1600 Pipe rack HTDC bridge N/A No FTM 37 Fire and gas N/A Yes FTM 38 1600,1800 New flame arrestor for HTDC Nitrogen, No oxygen, ethylene FTM 39 Fire water New fire water monitor H2O Yes system FTM 40 1100 Tie-in of new OHCL reactor and HCl, C2H4, Yes required modifications due to EDC, Air preservation of existing reactor FTM 41 New HPN vessel for emergency Nitrogen No purging Chlorine plant FTM 262 Cell room Installation of new electrolyser Brine, H2, Cl2, Yes NaOH FTM 361 Chlorine Increased capacity on chlorine cooler Cl2 gas Yes FTM 366 Chlorine Increased capacity on chlorine Cl2 gas Yes compressor FTM 421 Hydrogen Increased capacity on hydrogen H2 Yes compressor 5 Frequency analysis Three leak scenarios (small leak, major leak and rupture) are typically defined for each segment, vessel, specific equipment and transport pipe. Table 5.1 below presents the method to calculate leak frequencies and representative equipment hole sizes for the different parts of the plant. Note that calculated leak frequencies are presented in Appendix A. The different areas where the selected hazardous events are located are presented in Figure 5.1. Table 5.1 – Method for calculating leak frequencies Part of plant Method Reference Chlorine plant – Leak frequencies and representative hole sizes ULF (Ref. /11/) process are calculated using the LRC spreadsheet tool Offshore QRA – segments ULF (Utregning av Lekkasje Frekvenser). Standardised The frequencies are based on Offshore statistics Hydrocarbon Leak Frequencies (Ref. /12/) Chlorine plant – The scenarios and frequencies are calculated HES-HB-002 (Ref. /13/) Vessels and using the Hydro Handbook specific equipment VCM plant – Leak frequencies and representative hole sizes ULF (Ref. /11/) process are calculated using the LRC spreadsheet tool Offshore QRA – segments ULF (Utregning av Lekkasje Frekvenser). Standardised The frequencies are based on Offshore statistics Hydrocarbon Leak Frequencies (Ref. /12/) Report no: PRJ11090011 Rev: Final Page 14 Date: 11 January 2019 ©Lloyd’s Register 2019
Part of plant Method Reference VCM plant - The scenarios and frequencies are calculated HES-HB-002 (Ref. /13/) Vessels and using the Hydro Handbook. specific Loading arm frequencies are adjusted for equipment estimated annual time of operation Transport piping The scenarios and frequencies are calculated HES-HB-002 (Ref. /13/) using the Hydro Handbook Figure 5.1 – Illustration of location of hazardous events in QRA 6 Consequence analysis Consequence modelling and risk calculations are performed using the software Safeti 8.11. 6.1 Event tree The event tree in Figure 6.1 illustrates the different outcomes a release of a hazardous substance may lead to. The outcome is a set of end events such as, e.g., fireball, jet fire or dispersion of toxic gases. Parameters and assumptions for the probability for each branch in the event tree are documented in Appendix A. A BLEVE is an escalated event caused by an initial jet- or pool fire. If a pressurized vessel with liquefied gas is exposed to heat radiation it can lead to a BLEVE event with consequence of both a large fireball and explosion pressure from the expanding vapour. A BLEVE event may occur in the storage area for VCM if the deluge system fails on demand and no other cooling is applied during a severe fire in the area. Report no: PRJ11090011 Rev: Final Page 15 Date: 11 January 2019 ©Lloyd’s Register 2019
For INOVYN’s facility, the dimensioning events for the risk zones (cf. Figure 2.2) are dispersion of toxic gases (such as chlorine, ammonia and HCl) and fire exposure of VCM storage tanks leading to a BLEVE. This is further detailed in the subsequent section. Figure 6.1 – Event tree 6.2 Fatality criteria The TNO probit functions are used as fatality criteria. These are inherent in the Safeti software. The process involves several toxic chemicals, where the most severe are listed in Table 6.1. The table offers acute exposure guideline levels (AEGL) for life threatening health effects or death, as proposed by US EPA (https://www.epa.gov/aegl). It can be seen that fairly low concentrations may cause fatal consequences. Table 6.1 – AEGL for airborne chemicals used in INOVYN’s process at Rafnes Chemical AEGL 3 (10 min AEGL 3 (30 min AEGL 3 (60 min exposure limit) [ppm] exposure limit) [ppm] exposure limit) [ppm] Chlorine (Cl2) 50 28 20 Hydrogen 620 210 100 chloride (HCl) Ammonia (NH3) 2700 1600 1100 6.3 Consequence modelling Consequences for the outcomes in the event tree are calculated with Safeti. Two examples of consequence computations are given below. The first example addresses a toxic release event and the second example is a consequence computation of a BLEVE event. Figure 6.2 shows downwind distances to different levels of toxic lethality given a rupture of the piping/process equipment on the high pressure side of chlorine compressor #1 for wind conditions 2 m/s wind and Pasquille stability class F. The chlorine gas cloud with concentration corresponding to a toxic lethality of 1 extends approximately 180 m downwind of the rupture location. A toxic lethality of 0.001 may occur up to 1.2 km downwind of the rupture. Report no: PRJ11090011 Rev: Final Page 16 Date: 11 January 2019 ©Lloyd’s Register 2019
Figure 6.3 shows ellipses of lethality levels for a BLEVE event in the VCM storage area for wind conditions 2 m/s wind and Pasquille stability class F. Note that the consequence of BLEVE event is not sensitive to the wind speed. A lethality of 1 (100 % probability of fatality) occurs in a circle around the BLEVE event with a radius of approximately 400 m. The lethality is reduced to 0.01 in a circle with a radius of approximately 1.1 km. Figure 6.2 – Toxic lethality footprint for a rupture of the piping/process equipment on the high pressure side of chlorine compressor 1 for wind conditions 2 m/s wind and Pasquille stability class F Figure 6.3 – Lethality ellipses for a BLEVE fireball event in the VCM storage area for wind conditions 2 m/s wind and Pasquille stability class F Report no: PRJ11090011 Rev: Final Page 17 Date: 11 January 2019 ©Lloyd’s Register 2019
7 Risk picture and risk evaluation The results from the QRA are presented as Location Specific Individual Risk (LSIR) contours, or simply risk contours, which allow comparison with the risk zones stipulated by DSB in "Tema 13" (Ref. /8/) as shown in Section 2.3. The definition of LSIR is expressed as the frequency at which an individual may be expected to sustain a given level of harm from the realization of specific hazards. It is usually taken to be the risk of fatality, and normally expressed as risk per year. Individual risk is the risk experienced by a single individual in a given time period and reflects the severity of hazards and the amount of time the individual is exposed. When calculating the risk, it is assumed that an individual is present at a particular location 24 hours per day, and 365 days per year. Vulnerability of humans regarding exposure to toxic releases and from impact of heat loads are used to calculate the lethality from each branch in the event tree. To calculate the individual risk, all the resulting consequences are added for a given point and constitute the combined effect of the frequencies for loss of containment, atmospheric conditions, wind direction, and ignition probability. The resulting risk contours for the facility including the North Star contribution are shown in the subsections below. 7.1 Total risk picture The combined risk contours for the chlorine and VCM plant are shown in Figure 7.1. The black lines represent each contour when the North Star modifications are included. An immediate observation is that the North Star project does not increase the risk for third parties considerably. A few observations can be made when comparing the calculated risk to the RAC: 1. The RAC suggests that only the facility itself should be exposed to a risk of 1E-5 per year, with a possible exception for LNF areas. As seen in the figure, Noretyl’s premises and a part of what is denoted other industry lie within the contour of 1E-05 per year. One could argue that Noretyl and INOVYN is the same company with an integrated production. Then it would probably be acceptable that the 1E-5 per year contour expands into the Noretyl area. It is also noted that a public road is located within the risk contour of 1E-05 per year. DSB’s RAC suggests that public roads should be exposed to a risk below 1E-5 per year 2. Parts of the nearest residential area are located within the contour of 1E-06 per year. Permanent housing should primarily be located in the outer risk zone, but scattered houses may be acceptable under certain circumstances 3. The nearest vulnerable object, a school, is located outside the 1E-07 per year risk contour. The North Star modifications do not cause any changes to the risk picture with respect to the acceptance criteria. Report no: PRJ11090011 Rev: Final Page 18 Date: 11 January 2019 ©Lloyd’s Register 2019
Figure 7.1 – Combined risk contours for the VCM and chlorine plant. The black lines represent each contour when the North Star modifications are included. The grey areas in the figure mainly indicate LNF areas 7.2 Risk from the chlorine plant The risk contribution from events in the chlorine plant, including transport piping of chlorine and hydrogen to the VCM plant, is shown in Figure 7.2. The main contributors to the risk from the chlorine plant are leaks from piping/process equipment on the high-pressure side of chlorine compressor 1 and 2 (KLOR1-003 and KLOR2-003). The consequences of these events are larger than for leaks from low-pressure piping/equipment. These segments also have higher leak frequencies than e.g. the chlorine transport pipe to the VCM plant. The contributions from one of the segments are visualized in Figure 7.3. The chlorine plant modifications have been included in the risk model by assuming an overall increased mass flow rate of 10 %. This increase is the cause of the delta risk due to the North Star modifications. However, the delta risk is close to negligible. Report no: PRJ11090011 Rev: Final Page 19 Date: 11 January 2019 ©Lloyd’s Register 2019
Figure 7.2 – Risk contribution from the chlorine plant Figure 7.3 – Risk contribution from the segment after the chlorine compressor #1, Klor1-003. Report no: PRJ11090011 Rev: Final Page 20 Date: 11 January 2019 ©Lloyd’s Register 2019
7.3 Risk from the VCM plant The risk contribution from events in the VCM plant is shown in Figure 7.4. Here, as in the figures above, the black risk contours elucidate the increase in risk due to the North Star project. Again, the North Star contribution is modest. There are several events that contribute to the risk picture of the VCM plant. However, the main contributors to the risk are: • BLEVE in the VCM storage area (the risk contribution is shown in Figure 7.5) • Leaks from the HCl column V1501containing liquid HCl (the risk contribution is shown in Figure 7.6) • Leaks from piping/process equipment with Cl and HCl, e.g.: o The chlorine feed to the LTDC and HTDC modules (1600-Cl-017, 1600-Cl-HTDC). The risk is shown in Figure 7.7. o The HCl feed to C1501 (1500-HCL-011). The risk is shown in Figure 7.8. By comparing the below figures, it can be seen that BLEVE events has the longest reach in terms of exposure of adjacent land areas. As was calculated in the consequence section above (Section 6.3) the analysed BLEVE can cause a fatal exposure up to 1.1 km away from the VCM vessels. Except for BLEVE events, toxic releases dominate the risk picture for the VCM plant. Releases of VCM, ethylene and EDC that ignites and leads to pool-, jet- or flash fires are less critical to the risk for third parties. As an example of events that are not dimensioning for the risk zones, the risk associated with the vessel containing liquid ammonia (NH3), vessel V1012, is shown in Figure 7.9. The main driver of the delta risk is the 10 % increase in overall mass flow rate. The additional feed lines of ethylene and chlorine to the new HTDC module and the additional leak points on existing segments do not contribute significantly to an increase in the overall risk. Figure 7.4 – Risk contribution from the VCM plant Report no: PRJ11090011 Rev: Final Page 21 Date: 11 January 2019 ©Lloyd’s Register 2019
Figure 7.5 – Risk contribution from BLEVE events in the VCM storage area Figure 7.6 – Risk contribution from major releases from the HCl column V1501. Release of liquid HCl Report no: PRJ11090011 Rev: Final Page 22 Date: 11 January 2019 ©Lloyd’s Register 2019
Figure 7.7 – Risk posed by the chlorine feed to the LTDC and HTDC modules Figure 7.8 – Risk posed by the HCl feed line to the LTDC and HTDC modules. Release of HCl in liquid phase Report no: PRJ11090011 Rev: Final Page 23 Date: 11 January 2019 ©Lloyd’s Register 2019
Figure 7.9 – Risk contribution from the liquid ammonia vessel V1012 7.4 Individual risk at nearest resident To further substantiate the discussion above, individual risk due to both the VCM and chlorine plants is measured at two points located at the nearest residential houses as shown in Figure 7.10. Figure 7.10 – Locations of the nearest residential houses Report no: PRJ11090011 Rev: Final Page 24 Date: 11 January 2019 ©Lloyd’s Register 2019
The total individual risk at the northernmost of the two locations is 2.88E-06 per year with the North Star project modifications included. The total risk before including the North Star modifications was 2.58E-06. Hence, the North Star modifications cause an increase in the total risk at this point of approximately 12 %. Table 7.1 present the largest contributors to the risk at this point before and after including the North Star modifications. The main risk drivers in this point are the chlorine piping segments. The modifications do not change the main risk drivers. Table 7.1 – Risk contribution at resident location#1 before and after the North Star modifications are included Model name Description Risk Risk contribution contribution before after North North Star Star Chlorine KLOR1-003 Rupture of piping/process equipment on 36 % 35 % RU high-pressure side of chlorine compressor 1 Chlorine KLOR2-003 Rupture of piping/process equipment on 36 % 35 % RU high-pressure side of chlorine compressor 2 Chlorine KLOR1-001 Rupture of piping/process equipment on 6% 7% RU chlorine header from cell room 1 Chlorine KLOR1-002 Rupture of piping/process equipment 6% 6% RU between chlorine dryer and compressor 1 Chlorine KLOR2-001 Rupture of piping/process equipment on 4% 4% RU chlorine header from cell room 2 Chlorine KLOR2-002 Rupture of piping/process equipment 3% 4% RU between chlorine dryer and compressor 2 The total individual risk at resident location #2 is 7.09E10-7 per year with the North Star project modifications included. The total risk before including the North Star modifications was 6.87E-07. Hence, the North Star modifications cause an increase in the total risk at this point of approximately 3 %. Table 7.2 present the largest contributors to the risk at nearest resident 2 before and after including the North Star modifications. The main risk driver in this point is a BLEVE event in the VCM storage area. When the mass flow rate in the piping/process equipment segments is increased due to the North Star modifications, the contribution to the total risk from the HCl column (V1501) becomes negligible compared to other segments. Table 7.2 – Risk contribution at resident location #2 before and after the North Star modifications are included Model name Description Risk Risk contribution contribution before after North North Star Star BLEVE fireball VCM BLEVE in the VCM storage area 70 % 68 % Chlorine KLOR1-003 Rupture of piping/process equipment on 7% 8% RU high-pressure side of chlorine compressor 1 Chlorine KLOR2-003 Rupture of piping/process equipment on 7% 8% RU high-pressure side of chlorine compressor 2 Report no: PRJ11090011 Rev: Final Page 25 Date: 11 January 2019 ©Lloyd’s Register 2019
Model name Description Risk Risk contribution contribution before after North North Star Star 1500-HCl-011 RU Rupture of HCl feed to C1501 5% 7% V1501 RU Rupture of HCl column V1501 4% ~0 % 1600-Cl-017 RU Rupture of the chlorine feed to the LTDC 2% 4% module 8 Uncertainties When performing a QRA of a complex industry facility, such as the chlorine and VCM plant at Rafnes, a number of uncertainties need to be handled. Three categories of uncertainties are discussed to present the major uncertainties of this study: 1. Uncertainties in parameters and data used as input and modelling assessments, e.g. duration of process leaks. 2. Uncertainties in modelling tools 3. Uncertainties related to hazards that are not included in the QRA – this could be hazards deliberately excluded or hazards that are not identified. There is uncertainty in the use of generic leak scenarios and frequencies. The QRA cannot predict events that will happen in the plant. The uncertainties are controlled by using a large statistical basis for the generic data. The applied modelling tool is a semi-empirical tool, and uses simplified mathematical equations representing experience of natural phenomena. The modelling tool is verified against large scale tests of releases of chemical substances. One example of uncertainty is that topography cannot be specifically modelled. Leaks from EDC and mixtures with EDC as the main medium are excluded due to the assumption that release and possible ignition will only give local effects, i.e. within the plant boundary. A few test releases of EDC have been modelled, albeit not reported, and the gas dispersion distances have been found minimal. There is, however, a significant uncertainty regarding escalation and if a local fire in an EDC release can cause equipment failure and release of e.g. HCl or VCM. 9 Potential conservatism in the QRA This section addresses potential conservatism embedded in the QRA. Note, however, that there are factors that may not be conservative, such as the exclusion of events with EDC. 9.1 Release durations and transient effects In general, for process leaks the durations are fixed to either 3 min or 10 min depending on the event. Also, the release rate is fixed for the duration of the event. For ruptures and large leaks, this can potentially be conservative. It is typically such events that contribute to the risk contours defining the risk zones. Hence, it could be worthwhile to investigate if transient effects introduce conservatism. In order to do so, additional information (or assessment) is needed regarding process segmentation volumes, flow rates, detection time, initiation of emergency or process shutdown, isolation of segments, time for closing ESD/PSD valves etc. Report no: PRJ11090011 Rev: Final Page 26 Date: 11 January 2019 ©Lloyd’s Register 2019
9.2 Terrain effects Terrain effects, other than surface roughness, are not captured by the study. The terrain could potentially provide shielding for some adjacent areas for some of the accidental events (see Figure 9-1). Chlorine, for example, is a relatively heavy gas compared to air. Hence, it could be expected to follow the terrain in dispersion scenarios. On the other hand, chlorine is toxic at low concentrations (~50 ppm) and the terrain may not be that influential once the chlorine is diluted in air. Terrain effects can be addressed by, e.g., executing CFD simulations of a selected set of scenarios. In addition, the parameter value for surface roughness applied in the risk model is probably set in a conservative manner. Figure 9.1 – Risk contours plotted on the terrain around INOVYN’s facility to illustrate the topography in the area 9.3 Release modelling The jet direction follows the wind direction in Safeti. This implies that the probability of jet to face the wind is not included. A jet facing headwind is likely to result in shorter hazard distances. In addition, all releases are modelled as free, i.e., as non-obstructed jets. In reality, some jets will be pointed downwards or into process equipment or other obstacles. This will reduce the momentum of the jet, leading to shorter hazard distances. 9.4 Event frequencies One could consider adapting the event frequencies for the facility, if INOVYN has historic data over accidental events. 9.5 BLEVE A major risk driver for the VCM plant is BLEVE events with the VCM storage tanks; cf. Figure 7.5 in Section 7.3. The BLEVE frequency is based on the fire frequency in the relevant area and a probability of failure on demand of the deluge system (see Appendix A). However, fire water can also be supplied by fire trucks and other means, which has not been credited. Also, the durations of the initial fires may be too short to cause a BLEVE. Hence, the BLEVE event frequency might be conservative, and could be investigated further in subsequent studies. 9.6 Flash fire envelope The main risk drivers are not flash fires. Still, there is some conservatism in the model with respect to how flash fire risks are modelled. The lethality range of a flash fire is linked to the extent of the 50%LFL cloud size. With the new QRA guidelines (Ref. /10/), this would typically be reduced to 100%LFL. Report no: PRJ11090011 Rev: Final Page 27 Date: 11 January 2019 ©Lloyd’s Register 2019
10 Conclusion and recommendations 10.1 Recommendations It is recommended to address potential conservatism in the risk model in the next revision of the QRA. Section 9 above lists some aspects to investigate in that respect. Following such an update one can look into potential risk reducing measures. For example, avoiding a BLEVE event is obviously important, and if there is a potential to reduce the risk of such an event, this could be addressed in the update. Risk reducing measures regarding toxic releases could also be discussed. One new process module, the HTDC module, is installed as part of the North Star project. A measure to potentially reduce the probability of escalation from an accident in this module has been briefly discussed in this report, i.e. the cooling effect of fire water. If INOVYN is uncomfortable with this assessment, more detail studies can be executed to quantify the escalation potential. For completeness, the recommendations from the existing QRA are included. These are: • It is recommended to further develop and maintain systems and procedures to ensure fast detection and minimisation of duration of a release in case of an accidental scenario involving chlorine gas • Emergency preparedness and quick notification (alarm) to the public to move indoors and close all doors and windows are essential to avoid severe 3rd party injuries, in case of a large toxic release • INOVYN needs to make sure that the risk from the Chlorine and VCM plant are ALARP, As Low As Reasonably Practicable. 10.2 Conclusions Overall, the North Star project does not contribute with a significant risk increase compared to the existing risk picture at INOVYN’s facility at Rafnes. The main risk drivers remain unchanged from the existing QRA. Hence, toxic releases and BLEVE events in the VCM storage area dominate the risk picture and are dimensioning for the risk contours that will define the risk zones around the facility. When comparing the calculated total risk picture for the chlorine and VCM plant at Rafnes against the DSB suggested RAC (Ref. /8/), the following are noted: • Public roads and neighbouring industries are within the 1E-5 per year risk contour • Parts of the neighbouring residential area are within the 1E-6 per year risk contour. However, scattered houses may be permitted within the 1E-6 per year risk curve under certain circumstances. The North Star modifications do not cause any changes to the risk picture with respect to the suggested RAC. Report no: PRJ11090011 Rev: Final Page 28 Date: 11 January 2019 ©Lloyd’s Register 2019
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