Executive Q&A with Ryan Sitton, President and CEO, PinnacleAIS

Earlier this year, our friends at Pinnacle Asset Integrity Services hosted a webinar entitled Mechanical Integrity Assessment: Why Bother?. The broadcast included discussions on the history and value of asset integrity programs, as well as the evolution of the processes and methods necessary to ensure these programs achieve the objective of decreasing risk to improve safety. We have selected a small sample of these exchanges to present to you because we feel they provide important information regarding the need for mechanical integrity assessments in our industry.

There has been a lot of attention on Mechanical Integrity (MI) Assessments over the past few years. In your opinion, what is the reason for the attention and why should an operator bother performing a MI assessment?

RS: As most people in this industry know, the OSHA PSM standard came out in the early 90s and that really began to raise the bar, not just for mechanical integrity programs, but for PSM programs across the board. Since then, we’ve had a number of industry incidents and technological advances that have improved what we can do with all of these programs, and in particular, MI programs. In addition, there have been numerous industry initiatives that have been started by regulators, and more and more companies have had an opportunity to see the value of an effective MI program. That has driven the need or opportunity to improve programs across the board, so a lot of people are performing assessments to get an idea where they can go moving forward.

We’ve seen these assessments in a lot of industries, but the refining industry has particularly received a lot of attention because of the incidents that occurred a few years ago in Texas City. That led to increased focus from OSHA, who enacted the National Emphasis Program (NEP), in which they visited and inspected most of the refineries in North America, particularly in the US.

As far as the reasoning behind performing a MI assessment, if someone wants to improve their MI program they are typically looking to do one or more of these things: (1) reduce the costs of their program or costs associated with their program, (2) reduce or optimize risk and eliminate hazards at their facility, or (3) improve compliance with appropriate industry regulations, best practices, and jurisdictional codes. These MI assessments help identify where the opportunities for improvement are so that one can make educated and strategic decisions to increase the success of their MI program.

A lot of times we think of audits as more compliance based. Give an example of how an assessment would surpass that in terms of cost, or even risk.

RS: Let me first talk about compliance. Obviously, as industry codes change and revisions are put out to API 510 or other industry codes and standards, that changes what we call RAGAGEP, Recognized and Generally Accepted Good Engineering Practices, which is what is referenced, at least in the U.S., by OSHA as the PSM standard. As the MI assessments are performed, they should identify what programs in these facilities might not comply with the latest additions of codes and standards, or recent changes to jurisdictional requirements at a national, state, or even city level.

On another level, there is cost. New technologies have come on board both in software and in advanced inspection techniques, which may change the inspection process or the need for a large inspection staff. So if one still has a staff in place based on their requirements 30 years ago, it might be time to make some adjustments in light of the availability and utility of this new technology. A MI assessment will help point those things out.

From a risk perspective, if I’ve been performing fixed interval inspections—and over the last decade risk-based inspection has become very common in most industries— I need to ask if I am leveraging the technology available to implement those risk standards and perform a proper risk analysis, and see if those implementations can identify those hazards and reduce them. A MI assessment should help me identify where potential hazards are, what potential analyses I could be performing, and where those can be added into my program in order to reduce those risks.

Can you briefly describe what makes an effective MI assessment; what makes it good?

RS: Any MI assessment should have a couple different processes going on at the same time. The first is the subjective or qualitative process, where one should bring in industry experts. Those experts will interview personnel in the facility and find out what they know, what their experience has been, where they perceive there to be shortcomings or opportunities to improve.

At the same time, there are opportunities to leverage statistical analysis and more objective programs to assess things like the condition of data inside one’s inspection data management program, or how one is managing corrosion rates and degradation parameters, or what kind of access one has to their operating information. The availability and quality of that data has a very big impact on the overall quality of one’s program. By performing that objective analysis, one can make sure they are not overly skewing their results based on what the perception is just inside the facility and with their experts.

I would certainly recommend doing both of those in concert, so at the end of the day one can check those parameters against each other and make sure they are getting good overall results, independent of the opinions of the experts and the users.

So it’s both a quantitative and qualitative assessment process. Does that take a long time? Everyone is concerned about cost and how long is it going to take. How long would you recommend for an assessment?

RS: Rather than a recommendation, let’s talk about what different time frames will mean inside these assessments. Believe it or not, you can do an assessment of a program in just a day. But assessments have both breadth and depth. By breadth, I mean the number of units and the sheer amount of data sources one is evaluating. Depth is how deep one can go into those things. For example, if I’m looking at procedures inside a facility to determine how well those procedures comply with industry practices and I leverage the latest technology that can be utilized inside the facility, I can single out one procedure and look at a lot of details inside that procedure to see how it complies with what I expect in terms of RAGAGEP. Or, I can look at a number of different procedures, which would be breadth, and I can go into each of those procedures in a little or a lot of detail. For example, what guidance does it give on surface preparation or the methods for lubricating my NDE machinery?

So the difference is not just about time; it is how much breadth and depth does one need to assess the quality of their program. If I know that I’ve got a lot of uniformity inside my facility, and I know that my program has not changed much in a long time, I may not need a lot of breadth; I may just need a lot of depth and I can time my assessment accordingly. However, if I know that I have had numerous units come online at different times, and I have had lots of different systems implemented in various parts of my facility, I may require significant breadth. Therefore, I need to plan more time to do that.

Short assessments can be done in just a day or two to get a good snapshot of where the facility is. But often we see assessments taking a week or two weeks, depending on the level of breadth and depth the facilities feel they need to accurately assess the quality of their program.

What are some important things you try to accomplish when initiating an assessment?

RS: Any time a facility is going to begin an assessment, the first step needs to be identifying what they are trying to achieve. With this in mind, I will speak with personnel not just in the MI or inspection departments, but across the facility. What are they trying to achieve? Is there a need to reduce risk? Is there a need to reduce budgets? Is there a need to improve their turnaround intervals and are they looking at their MI program to help contribute to that? Another important step is getting the facility’s leadership team on board. I can’t tell you how many times we’ve been into facilities and the inspection team is very committed to making strides and moving from an average performing facility to best-in-class. Unfortunately, they haven’t gotten the plant manager and the other department managers on board with the improvements they want to make. This can lead to tension and unnecessary hang ups.

So we always want to start with a) a determination of what is the facility trying to accomplish, and b) a strategic push to get the leadership team on board. When we start an assessment, we always start with a kick-off that includes the leadership team of the facility, even if it’s just for a few minutes, to make sure they understand what we’re doing, that their personnel are engaged, and that they’re committed to really utilizing the results of that assessment.

For those who want to do an assessment, what do you recommend in terms of next steps?

RS: As I mentioned before, the first thing to do is identify “WHY you would perform the assessment”. Do you simply want to check your facility’s status? AKA - You believe you have a good program and you would like to validate that your program is in fact good. That is a great reason to do an assessment.

I would recommend doing an assessment any time. Because if you are going to make a big program change like implement risk-based inspection, or re-circuitize all of your piping, or implement new portions of advanced non-destructive testing, those can be very costly initiatives. Often an assessment will identify if you are going to get a good return on that investment. So before initiating an assessment, one should understand why they are doing that assessment, what exactly they are looking for, and how they are going to utilize the results, particularly if those results are surprising or expose serious problems.

That is where I would start. Once you truly understand why you are doing the assessment, then you can figure out the best way to achieve your goals for the assessment. Do you want to do it just locally? Do you want to bring in people from outside the MI group to participate with your inspection staff to perform that assessment internally? It is obviously easy and low cost, but you may not be able to leverage the knowledge outside of your facility. You will be limited to what you know inside the plant.

Can you utilize corporate personnel, people from a central group, or other sister facilities to come in and help you perform an assessment? Or should you reach out to an external group for help? Right now the American Petroleum Institute is performing assessments of PSM programs, including mechanical integrity, and doing some very good ones.

One should identify which option will best meet the objectives defined at the beginning, and then engage that group. Before they come in, make sure the assessment is well documented and you’ve built a good checklist of things you want to accomplish before they ever get onsite.

Finally, get the leadership team involved and bring them into the process, so when the assessment team comes onsite they are engaged with the leadership team, they know exactly what they are there to assess, and there is an established plan for how that assessment is going to occur.

To see the entire webinar discussing MI assessments, please visit https://inspectioneering.com/expo/8