Reynolds Wrap Up: Should We Shut Down Now to Fix It, or Can We Wait Until a Better Time?

Introduction

We are nearing the end of a major turnaround that has been going well, and it is forecasted to end on schedule. Then “BAM!” – our fixed equipment mechanical integrity (FEMI) nondestructive examination (NDE) group discovers a significant flaw in a major reactor. Now what? Do we need to take an unplanned extension to fix it now, or can we wait until the next turnaround? How long will it take to fix it, and how much will it add to the TA cost and timing? Can we operate safely for some period of time before we need to fix it? Can we make it to the next scheduled TA without “failure” if we don’t fix it now? What are all the things we need to think about in relation to fixing it now versus waiting for a more convenient time to conduct planned repairs? But as the title implies, this situation could arise (and has occurred) when a significant flaw is found even during on-stream inspections and not just during a TA.

Clearly, there would be substantial unplanned repair costs and lost profit opportunity involved with remaining shut down and conducting repairs now. Management and maintenance are demanding answers right now. What must we do? What are all our options? What are the risks involved? What issues do we need to assess in order to make a decision? It’s a demanding, high-stress situation for any FEMI personnel involved in the decision-making process. Most of us FEMI veterans have faced such a demanding, urgent situation before; some of us on multiple occasions. This article is all about applying a qualitative risk-benefit analysis (RBA) process that I have used on several occasions over the last 50 years to help understand all the options and then make the decision on what to do under similar circumstances.

Qualitative Risk-Benefit Analysis (RBA)

What is risk-benefit analysis? RBA involves identifying, assessing, and prioritizing potential FEMI risks and comparing them with the potential benefits from the decisions that may be taken using the analysis. RBA can be used in FEMI decision-making by providing a clear understanding of the potential outcomes of implementing a decision on what to do. RBA can help sort out the uncertainties that contribute to the risk. Risk-based decision-making (RBDM), on the other hand, is the follow-up process to select the best alternatives or rank the alternatives to achieve a specific risk management need. RBA provides the options and alternatives for RBDM by management. So, this RWU is all about a combination of risk-benefit analysis and then using the results of that RBA for risk-based decision-making, which is a decision by FEMI management to accept an option having a given risk-benefit in preference to another option or in preference to taking no action at all.

Risk-Based Decision-Making (RBDM)

Risk and benefit are closely related. The greater the risk that a decision may end up in a loss, the greater its potential for providing a substantial benefit. By the same token, the smaller the risk, the smaller the potential benefit it might provide. Hence the importance of coming to our primary decision-makers (management) with both risks and benefits spelled out, and not just the benefits of our favored solution. Management needs to understand both sides of the issue – the upside and the downside of every option. The overall goal of the RBA process is to consider all the potential consequences of the selected option and all other decision alternatives before the decision makers can select an option using informed and intelligent reasoning.

Before we get further into describing the RBA process as it applies to FEMI RDBM, it’s very important to recognize that the application of fitness-for-service (FFS) analysis could/would clearly play a significant role in the decision-making process on how to handle our hypothetical situation. So, a basic assumption for this article is that an immediate FFS analysis would be conducted in this situation following all the good guidance in the latest edition of API 579-1/ASME FFS-1 with reference to the many good Inspectioneering Journal FFS Forum articles over the past several years.

For the purposes of this hypothetical situation, which is often the case, let’s assume that the appropriate FFS assessment was conducted and indicates that the flaw size, characteristics, and growth rate would be low enough to allow continued safe operation for a definitive period of time. Hence, the decision on whether to fix the flaw now or later does not involve a potentially large process safety risk but rather mostly the issue of significant financial impact. Clearly, there is always some level of uncertainty involved in how long one can operate with a significant flaw and how much in-service inspection/NDE will be required to prove the assumptions made for the FFS assessment.

The graphic in Figure 1 indicates where we would ideally like to be after we apply our RBA process to our hypothetical situation when our RBA is completed and accepted by the decision-makers using RBDM. Not all such RBA results are as heavily weighted on the benefit side of the seesaw shown in Figure 1 (in fact, most are not); but this graphic depicts the ideal result of a major RBA. Many RBA results are more nearly balanced between risk and benefit, thus making the decision-making process more difficult and bringing in factors other than just FEMI logic and technical analysis, including the type of decision-makers involved [1].

When I was called upon to use RBA for RBDM purposes, I usually started by pulling out a sheet of paper (or, if you prefer, creating a Word document) with a potential FEMI option written across the top of the sheet describing in brief how we might handle such a demanding FEMI challenge. In our hypothetical case, such a statement at the top of the sheet might read like any one (or eventually all) of the following options, assuming that the FFS analysis indicates each is an acceptable option:

• Finish this TA now and monitor the flaw with ongoing in-service NDE;
• Finish this TA now and schedule an intermediate SD to conduct planned repairs;
• Finish this TA now and wait until the next TA to conduct planned repairs;
• Fix the problem now by extending the TA and conducting the unplanned repairs;
• Finish this TA now and schedule a future SD to replace the reactor, or
• Some other viable options that you can think of.

After listing the potential decision options that we wanted to analyze at the top of the sheet, I then drew a vertical line down the center of the paper, thus making two columns on each sheet that described a selected option. The top of the left-hand column is labeled “Benefits,” while the top of the right-hand column is labeled “Risks.” Then I would list all the benefits and risks that I can think of for each option (as well as all those offered by my involved FEMI cohorts) by applying a brain-storming process. When the list is relatively complete, we would do the best we could to create scope estimates of the monetary costs/impacts/value of each of the listed benefits and risks in our list. Then, we would sit around the table and hash out all the issues, making necessary revisions until we were satisfied that we had all the data and analysis that time would allow considering the urgency of the situation. At that point we are ready to put each of the options we considered somewhere onto the graphic shown in Figure 2 for further review and discussion.

As shown in Figure 2, our optimum FEMI options needed to plot somewhere in the upper left-hand portion of the graphic labeled NET POSITIVE ZONE, as that’s where the benefits would clearly outweigh the risks. Other potentially favored options may be plotted out in the areas labeled “Higher Risk/Benefit Area” and “Lower Risk/Benefit Area.” The other options are still worthy of discussion with the final decision-makers in management as the risk profile for the site or the risk tolerance of site managers may vary [2]. For valid reasons, some managers with a higher risk tolerance may prefer to take higher financial risks because the benefits of those risks are substantially higher, while other managers may be significantly risk-averse and prefer options that fall in the lower right-hand corner of the NET POSITIVE ZONE. On the other hand, those options where the risks outweigh the benefits would fall out of consideration because they would plot somewhere below the 45-degree vector in the lower right-hand portion of the graph (NET NEGATIVE ZONE).

Summary Comments

By using this RBA process, my experience has been that it led to the best FEMI decisions under time-constrained circumstances (barring unforeseen circumstances that later may come to light). Most often, this RBA process led to an almost unanimous choice for the best option by all FEMI stakeholders involved, while at other times, it clearly led to a consensus choice where everyone’s concerns were tabled and discussed. I always found that management was highly appreciative of this type of RBA process when it involved looking at multiple decision options, as they appreciated hearing about the downside as well as the upside of each potential option. This RBA process for these types of major FEMI decisions helps to reach a risk-sharing environment, which reduces finger-pointing in the event of eventual undesirable consequences. I remember having some colleagues who typically over-emphasized the upside and minimized the downside of their favored option, which lost them some amount of credibility with management.

This is clearly a qualitative (with some semi-quantitative costing/benefits information) method of RBDM that can be used under substantial time-constrained situations. For FEMI issues that don’t have such a demanding time constraint, more semi-quantitative methods of decision-making can and should be applied.

Have you used RBA and/or RBDM processes like these? If so, what has been your experience with them? Comments are welcome, both positive and negative.

References

1. Reynolds, J., 2023, “The Three Types of FEMI Decision-Makers - Which One Are You?” Inspectioneering Journal, 29(3), pp. 18-20.
2. Reynolds, J., 2022, “Optimizing Your Level of FEMI Risk Tolerance and Risk Mitigation Activities,” Inspectioneering Journal, 28(4), pp. 13-18.