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I’ve encountered a case currently, and I’d like to discuss it with fellow industry professionals: The current situation is as follows – there are two separate units, A and B, which produce products A and B respectively; among them, unit A has two reactors that are not in use. Owner’s idea: Utilize the idle reactor of Unit A to revitalize existing assets. Specifically, the idle reactor of Unit A is used to produce Product B; the crude Product B obtained is sent to Unit B for further processing such as distillation, thereby achieving the goal of expanding the production capacity of Product B. Question: After the modification, Unit A has two production lines simultaneously (for producing products A and B). Although they share the same raw material, there are two separate production lines. It does not conform to the definition of a \"device\" given in GB50160: \"2.0.12 Device: A process plant, which is a combination of one or more interrelated process units.\" ”It also does not meet the definition of a combined plant as stated in \"2.0.11 Multiple process plants: These are systems in which two or more separate units are arranged together in a compact manner, with direct feeding between them; there are no intermediate material storage tanks for maintenance purposes, and the start-up or shutdown for maintenance is carried out simultaneously, with such systems being considered as one single unit. ” I would like to ask the experts: Is such an approach in line with regulatory requirements? Are there any potential risks related to safety or other aspects?
There are many cases that fall into this gray area; in my opinion, they must be strictly separated, with safety coming first.