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101 Essential Elements in a Pressure Equipment Integrity Management Program for the Hydrocarbon Process Industry Part 4

By John Reynolds at Intertek. This article appears in the November/December 2000 issue of Inspectioneering Journal
This article is part 4 of a 5-part series.
Part 1 | Part 2 | Part 3
Part 4 | Part 5

 

Part 4 of this article continues to outline the 101 essential elements that need to be in place, and functioning well, to effectively and efficiently, preserve and protect the reliability and integrity of pressure equipment (vessels, exchangers, furnaces, boilers, piping, tanks, relief systems) in the refining and petrochemical industry. This article is not just about minimum compliance with rules, regulations or standards; rather it is about what needs to be done to build and maintain a program of excellence in pressure equipment integrity management (PEIM) that will permit owner-users to make maximum use of their physical assets to generate income. Compliance is not the key to success in PEIM; excellence is.

In parts 1-3 of the article, which appeared in the three previous issues of the IJ, I introduced the full paper and provided some background on why and how the issues were being covered. It is against that background that I continue the article with 8 more of the 101 essential elements in a pressure equipment integrity management program for the hydrocarbon process industry.
There are at least 101 essential elements to any program aimed at preserving the mechanical integrity of stationary pressure equipment, in- service, in refining and chemical plants. Each of these 101 elements may need to be prioritized by site management, basis risk or current status of each element, in order to assign resources and schedule improvements in the PEIM work processes. However, the user must keep in mind that each of these 101 elements, regardless of work priority and resource limitations, needs to be implemented effectively, continuously, in order to avoid the potential for pressure equipment incidents.

In other words, it is not a matter of choosing between the 101 elements and deciding that some are important and others are not. If any one of these 101 elements is neglected long enough, there will be a potential for incidents involving the breech of containment, and the subsequent consequences, i.e. fires, explosions, toxic releases, environmental damage, personnel exposure to hazardous substances, and business interruption.
There is no real secret to achieving success in maintaining pressure equipment integrity at a high level. It’s simply doing all the things (101 of them), that need to be done, and doing them well, day after day, without let up, regardless of what the “hot program” of the month is, or regardless of what other priorities may get in the way. We must not let other distractions get in the way of effectively executing our PEIM programs, day after day.

One more thing before I continue. You may have already noticed that I have and will use the term “effective” on numerous occasions. Webster defines it as “producing a decided, decisive, or desired result”. And that’s exactly how I use it. I’ve seen a lot of time, money, and motion wasted on “supposedly” doing all the things described in this series of articles, without really being effective. It does no good to write procedures and best practices that are not effectively implemented or adhered to. It does no good if the necessary information to do the job is not transferred effectively to those who need the information. It does little good if the following issues are just a “flash in the pan”, and then take a back seat to the next “hot rock” of the day. Watch for the word “effective” through the remainder of this article and think about what it really takes to get the desired results for each essential element.

So now let’s continue with 8 more essential elements of an effective PEIM program. In Part 4 of this series of articles, I return to some foundation, building blocks for an effective PEIM program. Without excellence in these building blocks, you will never have a very effective PEIM program. In Part 5 of the series, I will return to more of the specific PEIM program failures that I’m aware have been at the direct root of process safety incidents within our industry.
Inspection Procedures

Clearly everyone knows the importance of procedures as a foundation for an effective PEIM program. But they may not be worth the paper they are written on, if they are not kept up-to-date and not effectively implemented. Inadequate procedures, or those that are not effectively implemented, can result in a lot of missed opportunity to find deterioration before it results in failures. These procedures should cover all vital aspects of a PEIM program, including those mandated by the API Codes for In-Service Pressure Vessel and Piping Inspections (API 510 and 570). In my experience, the most thorough sets of inspection procedures, for a major hydrocarbon process facility, number above 50. As with inspection records, an internal auditing and up-dating work process should be in effect to assure that these vital procedures are effectively implemented and followed. Inadequate inspection procedures have been one of the leading causes of OSHA citations in the USA, when a mechanical integrity problem was the cause of a failure and an process safety incident. We have a management system in place that requires review and up dating, when changes occur, or at least every three years.
Do you have a documented procedure for each procedure designated in API 510/570, section 4.3; and when was the last time you reviewed them to make sure they are up-to-date with current practices?

Welding Quality Assurance and Quality Control

A management system needs to be in place that will assure that only qualified welders utilizing qualified procedures are allowed to weld on any pressurized equipment, including storage tanks and piping. Within the USA, we follow the ASME Boiler and Pressure Vessel Code, Section IX requirements, as indicated by the three API Codes for pressurized equipment (API 510/570/ 653). Another important aspect of welding QA/QC is the need to keep welder log sheets, to help assure that welder qualifications stay current. The most effective welding QA/QC programs set a minimum amount of radiographic examination for every welder and track weld reject rates, to assure that rework is kept to a minimum. The best programs I’m aware of stay routinely below a 1% weld reject rate. Equipment failures very often initiate at welds, for a variety of reasons, including weld defects, inadequate heat treatment, hardnesses being too high, lack of preheat, poor weld repairs, etc.

Do you use only qualified welders and qualified procedures for welding on all pressurized process equipment and do you know what your weld reject rates are?

Qualified Suppliers and Fabricators

Each company and/or facility should maintain an up-to-date list of qualified and approved suppliers and fabricators for pressure equipment; and a work process should be in place to assure that non-qualified “low bidders” do not creep into the process. If this work process is not managed diligently, personnel turnover and those folks inclined primarily toward “low bidders”, no matter what their qualifications, will cause inferior quality goods and services to infiltrate your facility. You may pay dearly someday from a PSM event from an unqualified low bidder, if you do not manage this work process well.
Is your list of qualified suppliers and fabricators kept up to date and enforced with all purchasers of pressure equipment and inspection/ maintenance services; and do you know if your suppliers have passed quality assurance and quality management certifications like ISO 9000?

Inspection Scheduling

A procedure must be in place to determine inspection intervals for pressure equipment to assure that the appropriate inspections are carried out, not only for API Code compliance, but also to assure that equipment is inspected with the right practices and tools at the right time intervals. With recent revisions to the three API Codes (510/570/ 653), the inspection strategy and frequency can now be risk-based, in lieu of condition-based or time- based. Risk-based strategies are usually more economic and result in a more reliable facility, by making sure that the higher risk equipment is inspected at higher frequencies and with more effective inspection methods. Once an effective inspection scheduling program and process is in place, then an effective strategy must be in effect to control overdue equipment (see part 2 of this series)
Does your inspection scheduling software handle external, on-stream, as well internal inspection frequencies and does it allow you to schedule special inspections like CUI and stress corrosion cracking inspections, as well as record all data and narrative results of inspections?

Leak and Failure Investigation and Reporting

A procedure should be in place to investigate, record, communicate, and follow up on all significant near misses, leaks and failures in order to identify the cause of the failure and take appropriate corrective action. Appropriate use of failure analysis and root cause analysis in these investigations is needed to ensure that corrective actions will be fact based. Significant near misses should get just as much attention as failures that cause fires or other safety and environmental problems. Lack of ignition or reportable pollution should not be a reason for not thoroughly investigating a near miss, so that future incidents can be prevented. Just recently I listened to a report at the API meeting, where a company had three corrosion-caused incidents from piping leaks within a short period of time at the same junction, because the failures were not adequately diagnosed. I’m sure that was embarrassing for their inspection group.
Do you investigate and record your leaks so that trending and corrective action can be applied to reduce future risk; and do you document and follow up on near misses with the same fervor as actual leaks?

Flange Gasket Selection and QA

Another “blocking and tackling” issue for us is assurance that the right gaskets are selected and properly installed during each flange make- up. This is another of the issues that takes procedures, training and discipline in order to get it right, every time. Periodically I hear about tragic accidents when the management of this issue Lack of ignition or reportable pollution should not be a reason for not thoroughly investigating a near miss, so that future incidents can be prevented. breaks down. Last year, there was a tragic accident in Saudi Arabia when a new hydrocracker was being brought on line. An improper gasket was installed and blew out during unit pressurization. And just before that, a spiral wound gasket at a gulf coast refinery blew out, causing a major fire. In this case the high temperature gasket had a carbon steel inner ring that suffered from creep. Just recently, a west coast facility suffered a gasket blow out, which resulted in an light hydrocarbon vapor cloud, that thankfully did not find an ignition source. Failure analysis indicated that the gasket installed was not adequate for the temperature of service, and it gradually degraded over a period of years before it blew out. I also know of two other gasket blow out incidents when stainless steel valves were installed in high temperature services with PTFE gaskets. Seems a lot of stainless steel valves come stock with PTFE bonnet gaskets because suppliers “assume” they are going into low temperature, chemical type services.
How effective is the selection and control over gasket installation in your plant?

Fitness for Service (FFS) Analysis

Everyone uses FFS, whether they know it or not. Each time a piece of equipment is inspected, decisions are made about whether or not repairs or maintenance are needed. All these decisions are FFS type decisions. Most often they are made on the basis of the knowledge of the inspectors and engineers directly involved with the issue. Sometimes, more engineering analysis is needed, and we should turn to the new API RP 579 (which is now available from the API). However, API 579 also includes a “Level 1” type analysis for quick, rule of thumb, type decision- making in the field. If a flaw is large enough that it does not pass a level one analysis then the user has the choice of making repairs or replacements, or turning to level two or three engineering analysis to determine if the equipment can continue in service without unnecessary repairs. This document is a break through for our industry, and the API Codes Committee is currently working on recognizing (and referencing) the benefits of FFS within existing API Codes (510/570/ 653). At the last meeting in October, we agreed to recognize API 579 in two of our Codes (510 & 570), and that item will be balloted in the first quarter of next year.
Does your plant have the benefit (economic and safety) of using API RP 579 for fitness for service decision making?

Inspection Recommendation Tracking

A systematic and effective procedure needs to be in place to assure that inspection recommendations for repair and other mitigation proposals are followed up on and completed or otherwise handled in an agreed upon manner. These tracking systems are usually more effective when they are built into inspection and maintenance management systems, and cannot be deleted unless agreed upon by the author of the recommendation (i.e. the inspector). One refinery on the Gulf Coast suffered a substantial loss when a thin pipe ruptured. Turns out the inspector thought the pipe had been renewed at the last turnaround, as he had requested, but due to miscommunications, it did not get replaced. An effective inspection recommendation tracking system could significantly reduce the chances of such events.

Do you have an effective inspection recommendation tracking system built into your Inspection Data Management Program?

Conclusion

In parts 1-4 of this article, I have covered the first 35 of the 101 essential elements of a pressure equipment integrity management (PEIM) program for the hydrocarbon process industry. In the next few articles, I will continue to enumerate what I believe are the other 65 essential elements, including such topics as: boxing of leaks, on-stream inspections, hydrotesting safety, cast iron equipment, heat tracing in safety systems, soil-to-air corrosion of buried piping interfaces, and much more. If you have some thoughts on what you have just read or suggestions for inclusion in the remaining 65 elements, let me hear from you through the IJ at admin@inspectioneering.com.

Continue to the next article in this series.


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