Equipment and repair recommendation should never become overdue for inspection and handling. Furthermore, every operating site should have a management enforced policy in place that doesn't allow these recommendations to become overdue. Such a practice goes a long way toward increasing the credibility of the inspection efforts at each operating site, as well sending the message that fixed equipment mechanical integrity is just as important as other plant priorities. Of course, in order to get to that point, inspection scheduling, data quality, data analysis, and record keeping have to be of sufficient quality and credibility that ignoring inspection schedules actually increases risk -- as well as putting the operating site in violation of codes and standards and potential jurisdictional regulations.
At the same time, fixed equipment and inspection recommendations that, for some valid reason, cannot be inspected or completed by their due dates can sometimes be deferred by using a valid risk-based deferral process. My experience indicates that a structured risk assessment for potential deferrals of scheduled inspections is far better that the old ways that involved either (1) someone in inspection drawing an arbitrary “line in the sand” and saying “Absolutely no deferrals”, or (2) someone else in the organization just making arbitrary decisions (without inspection involvement or approval) that a scheduled inspection or inspection recommendation will simply be allowed to become overdue without understanding the risks associated with such arbitrary “hand waiving” of the due dates. In my experience, the work process for deferring equipment inspections and/or inspection repair recommendations should be rigorous, well documented, risk-based and not be so simple and easy that the site ends up with such a long list of deferrals that the process becomes nearly equivalent to just letting equipment and/or inspection recommendations become overdue. A best practice for such deferrals is to require the approval of a site senior manager before equipment or inspection recommendations are allowed to be deferred. That level of approval will usually keep the process from being abused.
Such a deferral process is currently in effect at many operating sites and has now been approved by the API Inspection Subcommittee and will be part of the next editions for API 510 [1] and 570 [2]. The following is some quoted material from the approved 10th edition (publication pending) of API 510. Definitions:
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“Overdue inspections: Inspections for in-service vessels that are still in operation, that have not been performed by their due dates documented in the inspection plan, which have not been deferred by a documented deferral process.”
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“Overdue inspection recommendations: Recommendations for repair or other mechanical integrity purposes for vessels that are still in operation that have not been completed by their documented due dates, which have not been deferred by a documented deferral process.”
In the body of the 10th edition of the API 510 Code, the deferral process is addressed this way: [Quote]
“Inspection tasks for equipment and PRDs (not set by RBI) that cannot be performed by their due date can be risk-assessed and deferred for a specific period of time, where appropriate. A deferral procedure shall be in place that defines a risk-based deferral process, including a corrective action plan and deferral date, plus necessary approvals, if inspection of a piece of pressure equipment is to be deferred beyond the established interval. That procedure should include: (1) concurrence with the appropriate pressure equipment personnel including the inspector and appropriate owner/user management representative, (2) any required operating controls needed to make the extended run, (3) need for appropriate non-intrusive inspection with NDE, if any, as needed to justify the tempo- rary extension, and (4) proper documentation of the deferral in the equipment records.
Notwithstanding the above, an inspection or PRD servicing interval may be deferred by the Inspector, without other approvals, based on a satisfactory review of the equipment history and appropriate risk-analysis, when the period of time for which the item is to be deferred does not exceed 10 percent of the inspection/servicing interval or six months, whichever is less.
For equipment with risk based inspection intervals, the existing risk assessment should be updated to determine the change in risk that may exist by not doing the originally planned inspection. A similar approval process used for equipment with non-RBI intervals should be used to document the change in risk levels.
Deferrals need to be completed and documented before the equipment is operated past the scheduled inspection due date; and owner/user management apprised of the increased risk (if any) of temporarily operating past the scheduled inspection due date. Pressure equipment operated beyond the inspection due date without a document- ed and approved deferral is not permitted by this code. The deferral of scheduled inspections should be the occasional exception not a frequent occurrence.” [End quote]
With regard to deferrals of inspection repair recommendations, the body of the API 510 Code deferral process is addressed this way: [Quote]
“Inspection repair recommendations that cannot be completed by their due date can be deferred for a specific period of time, if appropriate, by a documented change in date of required completion. The deferral of the due date shall be documented in the inspection records and have the concurrence with the appropriate pressure equipment inspection personnel including the inspector and the inspection supervisor. Inspection recommendations that have not been completed by the required due date without a documented and approved change of date are not permitted by this code and are considered overdue for completion. The deferral of inspection recommendations should be the occasional exception not a frequent occurrence. Equipment must remain within the limits of the minimum required thickness as determined in this Code or by other engineering evaluation during the period of deferral.” [End quote]
And finally with regard to reviewing and potentially changing of inspection repair recommendations, the body of the API 510 Code addresses the issue this way: [Quote]
“Inspector recommendations can be changed or deleted after review by pressure vessel engineer or inspection supervision. If that is the case, inspection records shall record the reasoning, date of change/deletion and name of person who did the review.” [End quote]
Do you keep your management informed of equipment that is overdue for inspection? Does your plant management practice a strict “no overdue” equipment policy? Does your site have a structured deferral process for equipment and/or inspection recommendations that may become overdue that is at least as good as the new sections that will be in the 10th edition of API 510?
References
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API 510 Pressure Vessel Inspection Code: In-Service Inspection, Rating, Repair and Alteration, 9th edition, June 2006 (10th edition approved and publication pending).
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API 570 Piping Inspection Code: In-Service Inspection, Rating, Repair and Alteration of Piping Systems, 3rd edition, November 2009 (4th edition in balloting as of 2/Q/2014).
This article originally appeared in the 101 Essential Elements in a Pressure Equipment Integrity Management Program. The entire guide is available for download now. Simply click the button below to get it.
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