This post concludes the Top 7 reasons why some operating sites “just don’t get it.” Reference the previous post for here and here. And for examples of all of the management systems for a sustainable PEI program of excellence, read my article, "The 101 Essential Elements of Pressure Equipment Integrity Management for the Hydrocarbon Process Industry”
Reason No. 6 – Lack of experience with on-site process safety incidents caused by PEI failures. This one is also closely related to reasons no. 1 & 2 mentioned in my previous post. If your site is small and has limited communications with other sites and limited information about what pressure equipment failures occur in our industry, then plant management may not understand the PEI risks that are being carried and how to avoid them. Also, some managers have this belief that “if it has not happened here, then we must already have adequate safeguards in place”. That belief may not recognize that other safeguarding barriers may have been active in preventing an incident or may not recognize that unreported or under- reported near misses have already occurred that could have easily escalated into a serious incident. Fortunately, every release of hazardous substances does not ignite or does not expose personnel to toxic or hazardous substances. But we all know that “just dumb luck” can only protect us just so far. So once again, implementing the corrective actions for reasons no. 1 & 2 above will usually correct this problem, too.
Reason No. 7 – Lack of effective application of industry PEI codes and standards for in-service inspection and maintenance of pressure equipment. And last but certainly not least is reason no. 7. There is an enormous, useful body of knowledge about in-service inspection (ISI), pressure equipment integrity (PEI) and materials and corrosion (M/C) contained in the numerous codes and standards published by the API. These documents are very helpful in building a solid foundation for PEI programs in the refining and chemical industry. These PEI codes and standards are assembled by dozens of very knowledgeable ISI & M/C specialists from across the USA and around the world; and then balloted (often multiple times) and published by using the ANSI consensus process to ensure that they truly represent industry best practices for PEI. Though too numerous to mention here in their entirety, some of the more prominent API codes and standards (with abbreviated titles) include:
- API 510 In-Service Pressure Vessel Inspection Code
- API 570 In-Service Piping Inspection Code
- API 571 Materials Deterioration Mechanisms
- API 572 Pressure Vessel Inspection Practices (sister document to 510)
- API 573 Furnace and Boiler Inspection Practices
- API 574 Piping Inspection Practices (sister document to 570)
- API 575 Tank Inspection Practices (sister document to 653)
- API 576 Pressure Safety Device Inspection and Servicing
- API 577 Welding Inspection and Metallurgy
- API 578 Piping Material Verification and PMI
- API 579 Fitness for Service Analysis
- API 580 Risk-Based Inspection Programs
- API 581 Risk-Based Inspection Methodology
- API 582 Specialized Welding Practices
- API 653 Atmospheric Storage Tanks
Inspection
Hopefully you are all very familiar with each of these codes and standards and have the latest editions readily available to you. Each of these standards is updated (and sometimes substantially improved) every 3-5 years, while others like 510/570/653 have addenda published every 1-2 years in order to keep them up-to-date. So you need to make sure you are working with the latest edition.
Since each of these codes and standards represents a consensus of best practices put together by subject matter experts from owner- users, consultants, and those that provide services to our industry, they are sometimes general in nature and sometimes cannot provide the detail that may be needed to effectively implement them at your site. That typically means that you will need to document some extra details about just how each of them will be effectively implemented at your site, i.e. who does what, when and how often, etc. Most sites do that by creating their own set of PEI procedures, which then expands upon the PEI issues (more detail) that are covered in the API codes and standards to make them site-specific.
Conclusion
Do you recognize any of these symptoms at your site? Hopefully not; and your management is completely on board with what needs to be done in order to keep your pressure equipment safe and reliable. Once that is true for all operating sites, then there should be no more pressure equipment failures, fires, explosions, toxic releases, etc. in our industry.
So what did I miss? If you have experienced other reasons for inadequate PEI programs, send them along to me through our Inspectioneering Group on LinkedIn. If just one of the above reasons applies to any one operating site, that site will probably struggle to achieve excellence in their PEI program. But if multiple reasons are present at any one site, then “may the force be with you” as you climb the mountain of PEI excellence.
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