Inspectioneering Journal

The Importance of Choosing the Right Inspection Plug System - Equipment Under Insulation

By Deal Moore at NDE Seals, Inc. This article appears in the March/April 2001 issue of Inspectioneering Journal.

Determination of the mechanical integrity of pipe and equipment in US process industries has evolved from day to day business to federal mandate (OSHA 1901.119) to a part of industry best practice. Insulated pipe and equipment pose specific challenges for the examination effort. This article is an attempt to review the regulations that are driving these efforts and the innovations designed to address these challenges. Understanding both will enhance the value added services offered by the insulation industry.

The Requirements to Test

Non-destructive testing has long been a best practice in the process industries’ total preventive maintenance efforts. The mandate to examine mechanical integrity is an integral part of several pieces of legislation and administered by a variety of both federal and state agencies. Industry groups have further defined how such examinations take place in the form of generally accepted standards.

OSHA 29 CFR 1910.119 defines the Process Safety Management guidelines for the operations and monitoring of process equipment. One element of this ruling is the requirement to perform a process hazard analysis, in accord with recognized and generally accepted good engineering practices another is mechanical integrity. The timeline for implementation of a Process Safety Management effort was to be phased in over a period of years and completed by May 1997.

EPA regulations require the implementation of a Risk Management Plan aimed at preventive maintenance and monitoring to assure the public’s safety outside the perimeter of the processing facility. The Risk Management Plan is to be coordinated with the Process Safety Management rule and should be implemented by June 21, 1999.

Compliance is a major undertaking. It includes developing and updating process drawings, identifying the age and composition of structural materials, defining the temperature, flow rates and corrosiveness of the process materials and ultimately defining the location, type and frequency of testing required.

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