More Reasons Why Some Operating Sites "Just Don't Get It"

By John Reynolds, Principal Consultant at Intertek. September 23, 2013
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These posts came about because, from time to time, I’m asked why some operating sites don’t seem to pay adequate attention to the need to protect and preserve pressure equipment integrity (PEI). Too often a few sites don’t seem to “get it” until they have a major process safety event associated with a failure of pressure equipment. When that happens, they are suddenly on board with PEI needs and don’t seem to be able to apply their available resources fast enough. Fortunately, I see less and less of this type behavior as time passes and the word spreads throughout the industry about PEI catastrophes and how to avoid them.

In today’s post, I will continue with my discussion on the Top 7 reasons why some operating sites “just don’t get it.” Reference the previous post for reasons #1 and #2. And for examples of all of the management systems for a sustainable PEI program of excellence, read my series, The 101 Essential Elements of Pressure Equipment Integrity Management for the Hydrocarbon Process Industry. To continue, let’s start with Reason #3:

Reason No. 3 – Lack of budgeting for PEI issues by management that would rather apply their available resouces on projects or other competing interests.

As I mentioned in the introduction, a lot of these reasons are intertwined. And this one is a bit of a corollary on reasons no. 1 & 2 above, but may also be somewhat independent of them. If managers don’t understand or really appreciate the magnitude of risks they are carrying by having under-resourced PEI programs, then they are not likely to budget enough resources to improve them. On the other hand, there are some managers that “just don’t think that something bad is going to happen at their site” or that they will be held responsible for “an act of God” after a serious PEI failure. You know the old “ostrich approach” to handling the PEI challenge. Managers come from many different backgrounds and experiences before they get put in charge of PEI. Those different experiences can lead them to favor spending their resources on other issues like process improvements, new projects, fancy- dancy electronic IT systems, etc. Some just don’t understand the real value achieved of applying the necessary resources to maintain existing assets and would rather spend their resources on building new assets. As I mentioned before, solving problems no. 1 & 2 above, usually solves this one too.

Reason No. 4 – Lack of application of an effective PEI technical review process.

One of the most effective methods that I know of to enlighten managers about the quality of their existing program (or lack thereof) is to conduct an independent technical review of the PEI program. Shell Global Solutions has one such program, which they conduct at all of their refining and petrochemical operating sites worldwide. It’s called a FAIR+MS, which stands for Focused Asset Integrity Review of the PEI Management Systems (i.e. the 101 Essential Elements of Pressure Equipment Integrity Management). Numerous senior managers have said to me that the Shell GS FAIR is one of the most valuable technical reviews i.e. audits that they have experienced because:

    • It is conducted by very experienced PEI professionals that have conducted numerous FAIR’s at numerous sites;
    • It reports and risk ranks the necessary improvements needed;
    • It scores the site on the quality of it’s PEI program based on 1,000 points of excellence, which allows benchmarking with other sites that have been reviewed;
    • It contains a gap analysis conducted with key PEI folks from the site to build agreement on what needs to be improved; and • It includes an interactive report out session with plant management at the conclusion of the review.

In many cases, these candid, straight-shooting, eye-opening reports have resulted in rapid deployment of the necessary resources to begin climbing the ladder of PEI excellence.

Reason No. 5 – Lack of understanding that an effective PEI program must also include very effective MOC, SIM and IOW programs.

An effective inspection program alone is not sufficient to protect and preserve pressure equipment and achieve excellence in pressure equipment integrity. An effective inspection program must be accompanied by at least three other effective programs at the site in order to achieve PEI excellence. They are:

    • Management of Change (MOC),
    • Shared Integrity Management (SIM),
    • and Integrity Operating Windows (IOW).

It’s always interesting to me, when I attend the API OPS twice a year, how many process safety incidents could have been avoided by a more effective MOC program applied to PEI. An effective site MOC program needs to assure that any change in the hydrocarbon process variables or change in the process hardware is reviewed and approved by an experienced, competent subject matter expert (SME) in pressure equipment integrity. Very often that SME includes review by a materials/corrosion specialist. If that occurs, then inspection programs can be adjusted to monitor changes in deterioration in pressure equipment and many potential PEI incidents can be avoided.

Sometimes a site has a fairly effective MOC process for hardware changes, but there is a misconception by some process technologists/engineers/operators that no matter what process changes they make, that the inspectors will determine how corrosion and deterioration of the equipment is changing, simply with routine scheduled inspections. I sometimes wonder if these good folks think we are the equivalent of monkeys in a tropical forest, constantly climbing through their pipe racks taking thickness measurements in hopes of finding something changed. One of the important communication functions of the PEI group is to help others understand that PEI groups are dependent upon timely and thorough MOC communications in order to adjust inspection strategies appropriately. Without timely MOC communications, inspection strategies will continue to be based upon historic types and rates of deterioration and not on the current or changing deterioration conditions. Hence the likelihood that inspection will find changing corrosion rates because of process changes that are unknown to them is quite low.

The second important adjunct to an effective PEI program is what I call Shared Integrity Management (SIM). Shared Integrity Management is an integration of “ownership” and responsibility for pressure equipment integrity by all involved site functions, including operations, engineering and maintenance. As such, operations management and process engineering share PEI leadership roles with the PEI function, to preserve and protect the integrity of pressure equipment. Similarly, PEI personnel should share with Operations management the goal to attain the full useful life of pressure equipment cost-effectively. This shared integrity management leads to everyone being on the same page with regard to pressure equipment integrity, all working for the same shared goals, all understanding that they have a vital role in integrity management and knowing specifically what that role is. Inspection cannot do it alone.

The sites that are best at implementing SIM, all have documented and implemented PEI roles for folks in operations, engineering, maintenance, inspection, and materials specialists. For instance, process engineers may be in charge of keeping the list of injection and mix points up-to-date and reporting any changes (or anticipated changes) in operation of those injection/mix points to appropriate inspection personnel. Maintenance may have the role of implementing specifically defined PMI for all new and modified alloy hardware piping. Engineering may have the role of making sure that inspection is involved in all the previously defined aspects of QA/ QC for every step of a new or plant change project. These are just single examples of a list for each function that may have 20-30 specific tasks listed for SIM. These types of specific roles, endorsed by plant management, go a long way toward alleviating the need for inspectors and inspection engineers to constantly be chasing down others in operations, maintenance and engineering to get them to cooperate with and participate in the PEI needs of the site, which as we all know is a little like “pushing on a rope”.

The third vital “leg of this stool” that supports an effective PEI program is that of identifying and implementing effective integrity operating windows (IOW). IOW’s should be established for all variables (both physical and chemical) that could impact equipment integrity if not properly controlled. Just a very few examples of the variables include temperatures, pressures, fluid velocities, pH, flow rates, chemical or water injection rates, levels of corrosive constituents, chemical composition, etc. These IOW’s should be established by a team of operators, process engineers, materials/corrosion specialists and inspection personnel who are directly involved with each process unit where IOW’s are needed.

Variations from IOW limits should be brought to the attention of appropriate Inspection/Engineering personnel. This communication link provides early warning to PEI personnel when established IOW’s are exceeded so that appropriate plans and changes in inspection strategy can be implemented if equipment deterioration rates are expected to change.

Once again, inspection cannot do it alone. Sites that do not have effective MOC, SIM, and IOW programs that directly and specifically support their PEI program will likely struggle to build real excellence in pressure equipment integrity.

Next week I will provide the final two reasons why some operating sites “just don’t get it.” Sign up for the Inspectioneering Turnaround to get notified when it comes out.

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