Regulations in the Gas and Oil Industry

Ever since the catastrophic Piper Alpha tragedy in 1988, when 167 people died in the fire resulting from an explosion in the rig, significant improvements in health and safety regulations have been enacted (Lloyd, 2007). Despite these developments, 20,000 people employed in the oil and gas industry are still at the risk of being injured or perishing in a fire, explosion or infrastructure failure – risks associated with activities in the industry. Governments and organizations directly related to oil and gas operations have issued regulations that would make these operations safer to the general public.There are many risks associated with the oil and gas industry because of its vulnerability to explosion and fire. Safety regulations being issued focus on, among other things, the prevention of accidents resulting to explosion and fire.

Fire Prevention and Protection A) Storage of Combustible Materials Fire can be prevented when combustible gases are stored, handled and transported properly. The Occupational Safety and Health Administration [OSHA] (1998) have released regulations regarding the safe storage of combustible materials. According to the said guideline, flammable or combustible materials should not be stored in areas used for exit, stairways or those that are normally used for the safe passage of people. This is to ensure that in the event of a fire or explosion, all exits can be safely used and not consumed by fire first.

Furthermore, no more than 25 gallons of flammable or combustible liquids shall be stored inside a room but outside an approved storage cabinet. A storage cabinet is usually wooden with the construction specifications identified by OSHA. Metal storage cabinets are acceptable once approved by OSHA. Materials that are used to construct storage tanks for flammable liquids must be non-combustible. Underground storage tanks must be made of either fiberglass or reinforced Safety Regulations 3 plastic.

Alternatively, cathodically protected steel (steel protected against corrosion that could result from contact of steel and soil) could also be used, as well as steel clad with fiberglass reinforce plastic (NYS Department of Environmental Conservation, 2007).Above-ground storage tanks on the other hand must be constructed of steel. If the tank’s bottom rests on the ground, it should have cathodic protection. The tank bottom must be made of an impermeable material, so that material from the ground cannot seep through and combine with the material inside the tank. Tanks other than steel may be used but shall be designed to specifications embodying principles recognized as good engineering design for the material used (OSHA, 1998).

Unlined concrete tanks, for example, may be used for storing flammable and combustible liquids that have a specific gravity of 40 deg. API or heavier.Lined concrete tanks may also be used depending on the substance stored, for as long as it follows good engineering design. Not only the material used in storage tanks, is vital in avoiding accidents resulting to fire. The quantity of the substance stored is also an important factor.

Only as many as 60 gallons of flammable liquids and 120 gallons of combustible fluids shall be stored in any one storage cabinet. Not more than three cabinets shall be stored in a single storage area. Quantities in excess of those mentioned shall be stored in an inside storage area. Such regulations ensure that when an explosion or fire occurs, the damage will at least be limited because the quantity of flammable and combustible in a single area is also restricted.

Storage areas that contain flammable liquids should be properly vented to the outside air (Colorado Oil and Gas Conservation Commission, 2003). Furthermore, any storage area in excess of 500 square feet must contain at least two unobstructed exits leading from the building in different directions.Storage areas must also be kept free of other combustible materials such as weeds and debris, which are not necessary to the storage (OSHA, 1998). Safety Regulations 4 Furthermore, areas that contain combustible materials must not contain along with it, materials that react with water and can create a fire hazard. Storage cabinets and areas must be properly identified as a hazard and labeled accordingly (Colorado Oil and Gas Conservation Commission, 2003).

These areas must be labeled in conspicuous lettering, “Contains Flammable Material - Keep Fire Away.” Flammable and combustible liquids must not also be stored within fifty feet of the wellbore except when the fluids are to be used as fuel for the operating equipment or supply for injection pumps (Colorado Oil and Gas Conservation Commission, 2003).When terrain and the location of the well prevent this distance to be maintained, safety measures should be taken. Liquefied petroleum gas (LPG) tanks larger than two hundred fifty (250 gallons and used for heating purposes should also be kept as far away from the oil or gas well as possible. Presumably one of the most important rules in oil and gas operations and perhaps one that is most easily violated, smoking is prohibited except inside closed buildings or vehicles (Bureau of Land Management [BLM], 2002). Posters bearing the message “No Smoking” or “Open Flame” should be placed conspicuously in locations constituting a fire hazard (Colorado Oil and Gas Conservation Commission, 2003).

Where smoking is prohibited, no source of ignition should also be brought. BLM (2002) discourages the use of machinery that can cause ignition such as equipment used for welding, pipefitting, metal grinding, rock striking and explosives. In cases where they really have to be used, these conditions must also be followed: • An extra person whose responsibility is to carry the shovel and the fire extinguisher must be present at all times. • Extra water must be present to support welding and grinding.Safety Regulations 5 • Prior to welding and grinding, a ten-foot diameter area should be cleared of all surface vegetation, scraped until only the mineral soil shows, and wetted with water.

• Litter should be removed and cut vegetation should be scattered outside the operation area and not piled. Piled (especially dried) cut vegetation is very susceptible to catching flame. • A watch person should patrol the area for two hours following the cessation of welding operations. • Operations should be stopped once the winds pick up sufficiently to carry sparks. Other sources of ignition not mentioned above such as open fires and transformers shall only be allowed in designated areas located at safe distances from wellheads and flammable liquid storage areas (Colorado Oil and Gas Conservation Commission, 2003).

Materials that are used for cleaning should be non-combustible and as much as possible should have a flash point of not less than 100°F. B) Dispensing Combustible Liquids Fluids in the oil and gas industry are also susceptible to catching fire when they are dispensed or transferred. Great care should be taken so as to avert any accident that could result to a fire or explosion. As a rule, OSHA (1998) directed that areas wherein flammable or combustible materials are being transferred, in quantities greater than 5 gallons, have to be separated from other operations by at least a 25-feet distance. Spills must be controlled and adequate natural or mechanical ventilation must be provided so as to maintain the concentration of flammable vapor at or below 10 percent of the lower flammable limit.Flammable or combustible liquids should be drawn from or transferred to closed vessels only inside a building or if done outside, should be through a closed piping system.

The container containing the combustible liquid and that which the liquid will be transferred to should be in Safety Regulations 6 close contact with each other. The containers must also be continuously electrically bonded throughout the entire transfer process in order to prevent accumulation of static electric charge (“Part 23 Oil and Gas”, 2007). In order for the containers to remain electrically bonded and grounded, a well head may be used for dissipating static electricity. Transferring of liquids could also be done by gravity or pump through an approved self-closing valve. Transferring by means of air pressure on the container or portable tanks is prohibited (OSHA, 1998).

Equipment, machineries and units used in dispensing and transferring liquids should be protected from collision damage. In cases wherein spills should occur, these should be disposed of promptly and safely. Lethal both in stored and transferred combustible liquids, smoking will always be prohibited a certain distance from flammable liquids. Likewise, open flames are prohibited in areas used for fueling, servicing fuel systems for internal combustion engines, and transferring or dispensing combustible liquids.

Just like in storing these liquids, signs warning workers and the general public about the flammability of the substances and the prohibition of smoking must be conspicuously posted (OSHA, 1998). C) Other Sources of Ignition Most refineries have experienced spontaneous ignition of iron sulfide either on the ground or inside equipment (Sahdev, 2004). Solid iron sulfide scales is usually found in refinery units and are formed when iron oxide is converted into iron sulfide in an oxygen-free environment where hydrogen sulfide is present.Oil and gas refinery units provide such an environment.

When ignition of iron sulfide occurs inside tanks, storage equipment and reaction vessels, the results can be catastrophic. Such ignitions and fires usually occur during shutdowns and inspections when the vessels and piping are open. Safety Regulations 7 In order to avoid iron sulfide ignition, the iron sulfide, when removed, must be kept wetted down until safely disposed of. Likewise, other equipment and supplies contaminated with iron sulfide must also be kept wetted or kept in an inert atmosphere until cleaned (“Part 23 Oil and Gas”, 2007). Flaring is discouraged in an oil and gas operation area.

However, in cases where flaring has to be used, written safe work procedures must be implemented to ensure the safety of workers operating a flare line, flare tip or flare stack (“Part 23 Oil and Gas”, 2007). A flare line operated near a well or within the confines of an oil and gas drilling operation must be isolated. Furthermore, contaminants in the flare pit area must be less than 20% of the lower explosive limit.The location of the flare pit or stack must also not interfere with safe access to the work area. If possible, there should be a continuous ignition source before flow to a flare pit or stack occurs. D) Fire Protection Equipment and Supplies Fire protection supplies such as fire extinguishers are a must in every oil and gas operation.

In Colorado, the BLM required that a pump, hose, nozzle and water supply be present at all work locations. The pump is expected to deliver at least 20 gallons per minute when pumping through 50 feet of hose with a 3-inch nozzle. A minimum of 500 gallons of water must be present during the entire operation. At least one fire extinguisher must also be present outside, but not more than 10 feet from the door of a room containing more than 60 gallons of flammable or combustible liquids (OSHA, 1998).When the storage area is located outside the building, the fire extinguisher must be located not less than 25 feet, but not more than 75 feet from the storage area.

At least one fire extinguisher must also be provided on all trucks and other vehicles used to transport or dispense combustible liquids. In Colorado, the BLM (2002) required that all Safety Regulations 8 vehicles used in the operation will carry at least one shovel per person and five gallons of water. Structures involved in the operation must also be designed as to avert possible explosions; blast walls may be constructed based on an assessment of likely explosion characteristics (“Environmental, Health and Safety Guidelines”, 2007).Design of load-bearing structures must also take into account explosion load. Automatic and manual fire alarms that can be heard across the facility should be in place and working.

There should be active fire protection systems strategically located so as to enable rapid and effective response. Apart from fire extinguishers mentioned earlier, other types of fire suppression system ( such as fixed foam system, fixed water system, CO2 extinguishing system, and specialized vehicles) may be used depending on the fire impact assessment (“Environmental, Health and Safety Guidelines”, 2007).Fire systems must be located in a safe area, protected from fire by distance or by walls. If the fire protection system is located in a fire hazard area, it should be passive fire protected or fail safe.

Areas must always be protected from explosion – potential explosive atmospheres should be made inert. Accommodation areas must likewise be protected from fire either by distance or walls. The ventilation air intakes must prevent smoke from entering accommodation areas (“Environmental, Health and Safety Guidelines”, 2007).All personnel must be familiar with the location of fire control equipment such as drilling fluid guns, water hoses and fire extinguishers and must be duly trained to use these equipment (Colorado Oil and Gas Conservation Commission, 2003). They must also be aware of where the alarms are located as well as all the fire systems.

Indeed, a fire safety training has to be incorporated in the workforce health and safety induction/ training.