Build an Effective PEI Program with Management of Change, Deterioration Management, Risk Assessment, and Life Cycle Management

By John Reynolds, Principal Consultant at Intertek. October 21, 2013

Today’s post is a continuation from last week, where I started to outline the first steps to setting up an effective PEI Program.

As I stated in my previous post, there are 10 essential Management Systems (MSs) needed for an effective PEI program that can achieve excellence. These 10 PEI MSs contain all the necessary information that describe what needs to be accomplished, and how to accomplish it, in order to achieve success in PEI. Last week I covered the first two MSs; today I will cover the next four Management Systems, starting with Management of Change:

3. Management of Change (MOC)

MOC for PEI issues is another one of the most important PEI MSs. There is a multitude of incidents that can be traced to changes that were made in the hardware or process chemistry without effective MOC that eventually caused a breach of containment. Changes to the hardware are typically easy to recognize. Changes to the process that might affect pressure equipment integrity are more difficult to recognize. Both must be included in the MOC process to ensure its effectiveness. Unfortunately, many who are involved more in the operation and process side of our business, sometimes make changes to equipment and process variables, assuming that any change in material degradation will be picked up in the next inspection. That’s simply not the way it works. An effective MOC process is vital to the success of any pressure equipment integrity management program in order for the inspection group to anticipate changes in corrosion or other deterioration variables, anticipate other potential effects and alter the inspection plan to account for those changes. Even when MOC is triggered for a process or hardware change to the facility, if experienced, knowledgeable people are not involved, asking the right questions, then the MOC process for avoiding breaches of containment could be flawed, leading to breaches of containment.

4. Deterioration Management and Control

This MS contains all the systems, work processes and procedures for controlling the rate and types of deterioration in pressure equipment, like all of those outlined in my articles on the Ninety Nine Diseases of Pressure Equipment and those outlined in API RP 571 Damage Mechanisms Affecting Fixed Equipment in the Refining Industry. An experienced, knowledgeable corrosion/materials (C/M) engineer/specialist is central to the effectiveness of this MS because most of the technical work that this person does falls within this MS. The C/M engineer/specialist must have sufficient time in their schedule, not only to respond reactively to all the C/M issues that arise from time-to- time at an operating site, but also to proactively determine what issues might become a problem and to be able to prevent or minimize them before they lead to breaches of containment. Some sites are fooled into thinking that their chemical treatment vendor is all they need for corrosion control. Nothing could be further from the truth. As important as these people are, they are but one small aspect of the entire deterioration management and control MS.

5. Risk Assessment and Inspection Planning

Certainly the only person who is not aware of how important risk assessment is to inspection planning these days has been living in a cave these past 20 years. So as you would expect, it is another of the vital PEI MS, one that is closely associated with most other PEI MS, especially the previous one on deterioration management and control. Though the use of risk assessment in RBI is core to our inspection planning activities these days, it’s not the only use of risk assessment in the PEI MS. As you probably have already experienced, and will see in one of my succeeding articles, risk assessment is also key in making turnaround work scope planning (T/A WSP) decisions which affect PEI, reliability centered maintenance (RCM), which may deal some of the non-integrity aspects of pressure equipment, and risk-based decision making (RBDM) processes, like the one in use to determine the best repair option for major repairs to large equipment. Though you can still do inspection planning with a time-based or condition-based method, rather than risk-based methodology, you will miss out on a lot of efficiency gains and may not understand what your biggest risks are and therefore may not be focused on them.

6. Life Cycle Management (LCM)

This PEI MS drawer is a large one. It contains many of the issues that are implemented in order to design, fabricate, install, maintain and eventually retire pressure equipment in order to achieve the lowest total cost of ownership over the life of the equipment. It could in fact be the name of the whole PEI MS filing cabinet, since everything we do for PEI is included in LCM in one way or another. However, some of the 10 PEI MSs are worthy of standalone drawers in our filing system, and whatever is left over ends up in this drawer. As such our LCM MS is closely related to and integrated with all other drawers in our filing cabinets, especially the next drawer on PEI Codes and Standards.

This PEI LCM MS contains all the necessary input to projects and maintenance in order to select materials of construction and design pressure equipment to avoid breaches of containment for the equipment to last the design life of the process unit. Following that is the appropriate PEI MS that specifies the necessary QA/QC during fabrication and installation to assure ourselves that we are getting exactly what we specified in the purchasing process. Inspection planning and execution is certainly a vital part of LCM, but as you can imagine it is a large enough PEI issue that it has its own PEI MS file. Once the inspection plan is executed, we must decide on whether the equipment is fit for continued service or needs to be repaired or replaced. Those latter aspects of LCM fall into this PEI MS drawer. Any necessary QA/QC that needs to specified and applied during those repairs or replacements also falls into this PEI MS drawer. Finally, any work processes and procedures to protect idle equipment or to retire it are covered herein.

In my next post, I will cover the remaining Management Systems needed for an effective PEI Program. Subscribe to the free weekly email newsletter, Inspectioneering Turnaround, to get my next post along with other valuable asset integrity information.

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