Eliminating risk at source: SFAIRP demonstration, reliability trade-off, and the maintenance case for decommissioning
Project Summary
Sector
Energy | Power Generation
Location
Australia
Client
Confidential
Service
Risk Management
Capability
Risk Management | SFAIRP
The challenge
Peak power generation facilities must be capable of starting reliably - and rapidly - on demand, responding to grid signals, at the moment power is most needed. For the communities they serve, that reliability is not a preference; it is a requirement.
At a peaking power generation facility, startup capability was supported by three fuel sources: diesel, natural gas, and LPG. The multi-fuel design had been implemented to provide redundancy - ensuring startup could be achieved even if one fuel source was unavailable. On paper, the LPG system appeared to contribute to reliability. In practice, it introduced a material operational risk that the organisation needed to assess, quantify, and resolve.
LPG stored under pressure in bulk quantities presents significant hazards: credible release scenarios, flash fire, and explosion risk. The LPG system also carried a disproportionate ongoing maintenance and statutory inspection burden - obligations that continued regardless of how infrequently the system was actually called upon.
The question the organisation needed to answer was a genuine risk trade-off: was the safety risk and maintenance burden introduced by the LPG system justified by the reliability benefit it provided? If the facility could start reliably without LPG, the case for retaining it would be difficult to sustain.
This is precisely the type of question that rigorous risk management is designed to answer - and the type of conclusion the SFAIRP (So Far As Is Reasonably Practicable) principle requires organisations to reach proactively, not reactively.
What Winston Green Advisory did
We led the risk assessment programme, applying a structured SFAIRP analysis across three steps: establishing the baseline risk, evaluating the reliability trade-off, and building the evidential case for a confident, defensible decision.
Step 1: Startup reliability analysis
The first task was to establish, with confidence, whether diesel and natural gas alone could deliver the startup reliability the facility required. We led a systematic analysis of the startup sequence, fuel system availability, and historical startup performance data.
The analysis demonstrated that diesel and natural gas - independently and in combination - were sufficient to ensure reliable startup under all credible operating scenarios. The LPG system was not required to meet the facility's startup performance obligations. The redundancy it appeared to provide was theoretical rather than functional. Removing it would not degrade grid reliability or compromise the facility's obligations to the communities it served.
Step 2: Risk characterisation (before and after)
With the reliability finding established, the assessment turned to a systematic characterisation of what the LPG system added to the site's risk profile - and what decommissioning it would remove.
The LPG system represented the highest-risk fuel source on site. Its bulk storage, pressurised handling requirements, and the properties of LPG - heavier than air, wide flammable range - created hazard scenarios with the potential for serious harm to personnel that were lower risk from the diesel and natural gas systems.
Beyond the safety risk, the LPG system carried a disproportionate maintenance burden relative to its operational contribution. Pressure vessels, safety relief systems, and associated pipework required ongoing statutory inspection, testing, and certification. Retaining a system that was rarely used, but always expensive and hazardous to maintain, was a poor risk trade-off on every dimension.
Risk trade-off: LPG retained vs. decommissioned
| Dimension | Before: LPG system retained | After: LPG decommissioned |
|---|---|---|
| Personnel safety Risk | HIGH: bulk pressurised LPG on site; credible flash fire and explosion scenarios; personnel exposure during routine operations and emergency response | ELIMINATED: highest-risk fuel system removed at source; no residual LPG hazard scenarios |
| Startup reliability | Diesel + gas + LPG available: apparent redundancy; actual contribution of LPG unverified against startup demand | Diesel + gas retained: demonstrated sufficient for all credible startup scenarios; reliability obligations fully met |
| Maintenance burden | Three fuel systems to inspect, test, certify, and maintain; LPG pressure system subject to statutory inspection regime | Two fuel systems: maintenance scope reduced; LPG statutory obligations eliminated |
| Operational complexity | Three fuel systems in scope for procedures, training, competency, and emergency response planning | Simplified operations: reduced procedure set, leaner emergency response requirements |
| Regulatory position | Ongoing obligation to demonstrate LPG risk is SFAIRP; increasing scrutiny on bulk LPG on operating sites | Documented, evidence-based SFAIRP demonstration: risk eliminated, not managed; strongest defensible position |
Step 3 — SFAIRP demonstration
The combination of findings was unambiguous. The LPG system introduced material operational risk to personnel, an ongoing maintenance and statutory compliance burden, and unnecessary operational complexity - and it was not required for reliable facility operation.
Under the SFAIRP principle, if a risk can be eliminated without disproportionate cost or loss of function, it must be. The analysis provided the evidential basis for a clear, defensible recommendation: decommission the LPG system.
Fuel system risk and reliability summary
| Fuel source | Risk profile | Startup reliability finding |
|---|---|---|
| Diesel | LOW: established liquid fuel, standard handling | Confirmed reliable for startup across all credible scenarios |
| Natural gas | LOW: piped supply, low storage inventory on site | Confirmed reliable for startup across all credible scenarios |
| LPG | HIGH: bulk pressurised storage, heavier-than-air vapour, flash fire and explosion hazard | Not required: startup reliability fully maintained without LPG |
The outcome
The SFAIRP assessment delivered a clear and defensible outcome: the LPG fuel system could be decommissioned without any reduction in the facility's ability to start reliably and supply peak power to the grid. Every dimension of the original risk trade-off resolved in favour of decommissioning.
Risk → Zero
Highest-risk fuel system eliminated at source: no residual LPG hazard on site
3 → 2
Fuel systems in scope for maintenance, procedures, training, and emergency response
100% maintained
Peak power startup reliability: grid supply obligations met without compromise
The decision was supported by documented, evidence-based analysis - providing a strong regulatory position and enabling the organisation to act with confidence. Personnel safety could be improved, maintenance obligations reduced, and operational complexity simplified. Grid reliability would be unaffected.
The outcome illustrates a principle that is frequently misunderstood in operational risk management: more complexity does not always mean more reliability. In this case, simplifying the fuel system - removing the LPG rather than adding controls to manage it - was the safer, the more operationally sound, and the less costly long-term decision.
Winston Green Advisory capability demonstrated
The SFAIRP principle is not a compliance formality - it is a structured way of asking whether a risk needs to exist at all. This engagement demonstrated three dimensions of value that are often treated separately but are, in practice, inseparable:
Safety case: hazard eliminated at source - the strongest possible risk management outcome, not managed through additional controls
Reliability trade-off: the apparent redundancy of the LPG system was tested rigorously, not assumed: the analysis, not the assumption, was the foundation of the decision
Maintenance and operational dividend: statutory inspection obligations eliminated, maintenance scope reduced, procedures and emergency response simplified
Regulatory defensibility: documented SFAIRP demonstration providing an auditable evidence base for the decommissioning decision
Structured risk assessment and SFAIRP methodology across high-hazard energy and industrial facilities
Engagement delivered prior to the establishment of Winston Green Advisory. Details anonymised in accordance with client confidentiality obligations.
