The LG Polymers Incident: A Case Study in the Perils of Process Safety Management Lapses

The tragic gas leak at the LG Polymers plant in Visakhapatnam, India, on May 7, 2020, stands as a stark and painful reminder of the critical importance of robust Process Safety Management (PSM). While official investigation reports delve into the intricate details, the incident quickly became a prominent case study, analyzed by organizations like the Center for Chemical Process Safety (CCPS), to distill vital lessons for the global chemical industry.

The Catastrophe Unfolds

In the early hours of May 7, 2020, styrene monomer vapor began leaking from a storage tank at the LG Polymers facility. The plant, which produces polystyrene and expandable polystyrene, had been shut down due to the COVID-19 lockdown. Initial reports indicated that the styrene, left unattended in the tank, underwent uncontrolled polymerization due to a rise in temperature, leading to a runaway reaction and the subsequent vaporization and release of the highly toxic gas.

The dense vapor cloud spread rapidly over nearby residential areas, affecting thousands of people in five villages. The immediate impact was devastating: 12 fatalities, hundreds hospitalized with severe respiratory and neurological symptoms, and widespread evacuation. The long-term health and environmental consequences are still being assessed.

Key Learnings from the incident:

While CCPS does not release specific detailed incident investigation reports in the same manner as government agencies, their frameworks and published case studies (such as those found in "More Incidents that Define Process Safety") consistently highlight common underlying causes that resonate with the LG Polymers incident. Analyzing the publicly available information on the LG Polymers leak through a CCPS lens reveals several critical areas of PSM failure:

Management of Change (MOC) Deficiencies:

• Post-Lockdown Startup: A significant change occurred when the plant was shut down for an extended period due to the lockdown and then restarted. Any such change, especially after a prolonged idle period, requires a thorough MOC review to assess potential hazards, ensure equipment integrity, update procedures, and verify safety systems.
• Tank Conditions: Reports indicated that the styrene tank's cooling system might have been switched off or malfunctioned, and there were concerns about the design and age of the tank itself. If changes were made to operating conditions or equipment without proper MOC, it could have contributed to the incident.
• Inhibitor Management: Styrene is a highly reactive monomer that requires inhibitors (like TBC) to prevent polymerization. The effectiveness of these inhibitors is temperature-dependent and they deplete over time. Reports suggested issues with inhibitor addition and monitoring. Any deviation from inhibitor management protocols should have been subjected to MOC.

Operating Procedures and Training Lapses:

• Adherence to Procedures: Investigations suggested that critical operating procedures for managing styrene storage, especially during extended shutdowns and restarts, were either not in place, not adequately followed, or not fully understood by operators.
• Operator Competency: There were questions raised about the training and competency of the personnel on duty regarding the specific hazards of styrene, runaway polymerization, and emergency response. Effective procedures are useless without competent personnel to execute them.

Process Hazard Analysis (PHA) and Risk Assessment Gaps:

• Runaway Reaction Potential: While styrene's reactivity is well-known, the PHA process should thoroughly identify and evaluate all potential scenarios for runaway reactions, including those related to loss of cooling, inhibitor depletion, and extended storage at elevated temperatures.
• Consequence Analysis: The impact of a styrene release on the surrounding densely populated community should have been rigorously assessed, leading to robust emergency planning and community notification systems.

Mechanical Integrity Failures:

• Cooling System Malfunction: A primary factor cited was the failure of the cooling system designed to keep the styrene at a safe temperature. This points to potential lapses in maintenance, inspection, and testing of critical safety-related equipment.
• Tank Integrity: The age and design of the tank were also subjects of scrutiny. A robust mechanical integrity program would ensure regular inspections, testing, and fitness-for-service assessments for all critical equipment, especially those storing hazardous materials.

Emergency Preparedness and Response:

• Delayed Detection and Notification: Reports indicated a delay in detecting the leak and subsequently notifying the community. Effective gas detection systems, alarm management, and clear emergency communication protocols are vital.
• Community Awareness: The scale of the impact highlighted a lack of community awareness regarding the hazards of the plant and appropriate actions to take during an emergency.
• Safety Culture: The sum of these individual failures often points to a broader issue with the organization's safety culture. A strong safety culture emphasizes continuous improvement, encourages reporting of near misses, fosters open communication, and prioritizes safety over production. The LG Polymers incident, like many others, underscores how a weak safety culture can permeate all aspects of PSM, leading to systemic vulnerabilities.

The Broader Implications

The LG Polymers incident served as a potent reminder for the chemical industry, particularly in India, to reassess their PSM frameworks. It highlighted:

• The critical need for rigorous pre-startup safety reviews (PSSRs), especially after extended shutdowns.
• The importance of inherently safer design and considering alternative technologies or storage conditions for highly reactive chemicals.
• The absolute necessity of a proactive and preventative approach to PSM, moving beyond mere compliance to fostering a true culture of safety.
• The responsibility of companies to not only manage risks within their fence-line but also to effectively communicate hazards and engage with the surrounding communities in their emergency preparedness plans.

The LG Polymers incident, analyzed through the comprehensive lens of CCPS PSM elements, reinforces the universal truth that process safety is not an add-on; it is an integral and continuous effort requiring unwavering commitment from leadership, competent personnel, robust systems, and a vigilant safety culture. Learning from such tragedies is the only way to prevent their recurrence.

LG Polymer incident

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