What do I mean by that title? Sometimes with our busyness with the “Daily Grind”, we can forget about our most important mission – prevention of a big event caused by an unanticipated fixed equipment mechanical integrity (FEMI) failure. Those big events are the ones that get a lot of media attention, cost many tens of millions of dollars, cause big losses of production & capacity, and worst of all, may result in fatalities. They are the ones on our risk matrix that are very high consequence but relatively low likelihood. They are the ones that are not about leak metrics and typically only happen to a company once every 20+ years. They are the ones that involve such large ruptures where 30,000 pounds of highly hazardous fluids may be released in a matter of seconds.
Surely, we must continue to make progress on all 101 Essential Elements of FEMI, but not at the expense of losing sight of preventing the big one. The really big events could even threaten our “License to Operate”, or in other words, could cause so much media and jurisdictional attention that most of the entire operating site is shut down for long periods of time while government investigations and lawsuits proceed. They don’t happen very often, thank goodness, but that infrequency can lull us into complacency with regard to these big events. Remember that it was 17 years between the big NASA events where they lost two space shuttles, the Columbia (2003) and the Challenger (1986), with seven crew member fatalities in each loss. The second event hastened the end of the shuttle program. In between those two space disasters, NASA lost focus on some important lessons learned from the Challenger event. Might our industry also lose sight of some valuable lessons learned from some of the big events that have happened in the past in our industry?
What are some of the reasons for these big events that we need to be concerned about? They involve things like:
- Class 1 piping ruptures (remember the injection point failure on the US Gulf Coast in 1988 with seven lives lost?) or
- Class 1 equipment brittle fractures (remember the Lessons from Longford in 1998 with two lives lost?) or the
- Class 1 equipment ruptures (remember the heat exchanger rupture on the US West Coast in 2010 with seven lives lost), etc.
I have nearly 40 big events in my files, but you get the point.
Yes, Class 1 releases and some of the big Class 2 events can result in huge, immediate consequences (vapor cloud explosions and huge pool fires) that disrupt our whole FEMI program and cast doubt on the quality of our efforts to prevent the big events. Surely, stopping leaks, inspecting equipment on time, completing recommended mitigations on time, and all our other efforts to make continuous improvement on our 101 Essential Elements of FEMI are important; but, again, we cannot lose sight of our primary mission to prevent the big one while we are focused on our continuous improvement journey.
Do you know what exposure you might have to a big FEMI event? Do you know what and where all the FEMI issues are at your site that could lead to a big event? Do you know if crude types or other process changes might result in aggressive localized corrosion where you may not have a CML? If not, get some input from those experienced subject matter experts (SMEs) that do know. Capture those potential events in your Corrosion Control Documents (CCDs) and make sure you have all the appropriate Integrity Operating Windows (IOWs) in place that will help to prevent the big events. Stay focused on preventing the big one!
There’s an old military saying that goes something like this: “If things are too quiet, you may be walking into an ambush.” For our industry and our FEMI community of practice, let me convert that to: “If things are going really well in our continuous improvement journey to improve our FEMI programs, are we overlooking a critical aspect that might cause an unexpected big event?” Remember, one “Aw-shit!” wipes out a thousand “Attaboys!”. Don’t let it happen to you.