Canadian Province Issues Minimum Requirements for RBI

The Alberta Boilers Safety Association (ABSA) issued the requirements document, Risk Based Inspection Programs for Pressure Equipment, in March 2001. This document defines the minimum requirements for the development and use of risk based inspection (RBI) to manage the safety of pressure equipment operating in Alberta.

The document is to be used in conjunction with the document Inspection and Servicing Requirements for Pressure Equipment, published in August 2002. This procedure covers the requirements for determining inspection practices and establishes maximum inspection/servicing intervals for pressure equipment and pressure relief devices under the Safety Codes Act. The document provides the overall requirements in a pressure equipment inspection program.

ABSA is the organization responsible for the administration and delivery of safety programs related to boilers and pressure vessels in Alberta.

Following is a synopsis of the scope and intent of the RBI document with similar information on the sister document, since one would use both, as appropriate.

Much of the following information is excerpted from the guidelines/ requirements:

RBI

While a RBI program is not mandatory in Alberta, a company who chooses to apply RBI in this context must meet the requirements specified in this document.

A committee of representatives from the Alberta Boilers Safety Association (ABSA) and the Upstream Chief Inspectors Association (UCIA) developed this document with input from other industry groups. The requirements specified in the document apply in all industries where RBI may be utilized.

A committee will review the document, annually. The committee will include representatives from ABSA and user groups such as ARPIA (Alberta Refinery and Petrochemical Inspection Association) and UCIA to ensure that it remains current with industry practice and that safety considerations are adequately addressed.

The stated purpose of this document is to promote and maintain pressure equipment safety in Alberta by defining the essential elements of a RBI program. Through the use of these guidelines, it is intended that RBI programs will be applied correctly, based on sound judgement and principles, such that the inherent fiscal and operational benefits of
RBI can be realized in conjunction with enhanced safety.

RBI is a complex process that requires careful and detailed development and planning. It is not the intent of this document to provide comprehensive information regarding RBI program development. Owners, wishing to pursue such a program, are directed to the reference documents section for more detailed information about RBI.

A comprehensive risk based program will typically consider environmental, economic, and other factors in addition to safety. Since ABSA is concerned with the safety and integrity of pressure equipment, this document addresses safety and environmental considerations only...

RBI may be applied in any industry in Alberta provided that the requirements of this document are satisfied. In addition, all RBI programs must meet the intent of API RBI RP (recommended practice) 580 (qualitative assessments at a minimum). The pressure equipment in a facility to be managed under a RBI program needs to be clearly defined. Consideration should be given to the impact on the auxiliary equipment not included in the RBI scope. RBI is not to be applied to public occupancy equipment.
Because RBI is a complex process that requires a thorough understanding of processes, material degradation and failure mechanisms, mitigation strategies and techniques, inspection techniques and their reliabilities, companies must meet and demonstrate certain basic pre-requisites before embarking on a RBI program in Alberta.

For a RBI program to be accepted in Alberta, the company must be an Owner-User with a valid Certificate of Authorization from ABSA. The company must maintain an accurate inventory of all pressure equipment along with relevant design details. The scope of the Owner-User Program must include pre- commissioning inspections (inspection of new installations) since this is the time when the initial risk assessment of new installations should be made. The Owner-User audit performed by ABSA must include the RBI program. The results of the audit must demonstrate program compliance with this document.

A company, wanting to implement a RBI program, must have the resources and structure to make such a program work. This would include having the ongoing involvement of experienced corrosion, materials, maintenance, and process engineers/ technologists. If a company proposes to contract some or all of this capability to an outside vendor, then this would have to be reviewed by ABSA on a case by case basis. It is essential that the personnel involved in the operation of the RBI program are intimately familiar with the processes, operating parameters, procedures, history and other factors to make thorough risk assessments. Furthermore, since risk tolerance is highly subjective, it is mandatory that policies governing RBI be the responsibility of upper management, within the owner company, as defined in the Owner-User Program.

The document goes on to cover the following areas:

• Inspection Intervals - Most of the direction is contained in the sister document Inspection and Servicing Requirements for Pressure Equipment, which references industry codes such as API 510, 570, 572 and NB-23 along with ABSA guidelines.
• Basic Requirements of a Risk Based Inspection Program
• Logical and Fully Documented Process
• Personnel
• Documentation
• Pre-commissioning Inspections
• Management of Change
• Computer Models
• Determination of Risk
• Hazard Identification
• Consequence Assessment
• Likelihood Assessment
• Risk Determination
• Mitigation/Inspection Plan
• Reassessment

Inspection and Servicing Requirements for Pressure Equipment This document contains the overriding guidelines allowing for inspection strategies and programs like RBI. The purpose of this document is to establish procedures covering the requirements for determining inspection practices and establishes maximum inspection/ servicing intervals for pressure equipment and pressure relief devices under the Safety Codes Act.

The “General” section explains the relations to other codes and clearly defines which have authority. It also introduces a reference to the “grading system” which is based on the Institute of Petroleum Pressure Vessel Examination Code of Practice grading system. It was selected as an adjunct to complimentary inspection codes referenced in the document to provide an objective method for setting inspection intervals that is suited for all sectors of Alberta’s pressure equipment industry.

Other sections include, and are not limited to:

• Inspection Practices
• Ownership and Location Changes
• Installation Inspection
• Thorough Inspection Grading Allocation (Except as otherwise provided in the “Owner-Users” Section)
• Inspection Grade (0)
• Inspection Grade (1)
• Inspection Grade (2)
• Inspection Grade (3)
• Allocation to lower Grade/lower Interval
• Grading Review
• Requirements for Certified Owner- Users
• New Vessels in Known Service Conditions
• Sample Inspection of Pressure Vessels (similar service rules)
• Risk Based Inspection Programs
• Inspection Date Deferral
• Pressure Relief Devices
• Pressure Relief Valves
• Rupture Discs
• Control of Pressure Relief Devices
• Other Protective Devices
• Accompanying Tables for Determining Inspection Intervals Based on Grade

Referenced documents include:

• API 510 December 1998
• API 572 ANSI/API RP-1992
• ANSI/NB-23 Inspection Code 1998
• API 580 - Risk Based Inspection Recommended Practice 580 Draft #1 - October 1999
• API 576 - ANSI/RP 1992 Inspection of Relieving Devices
• API 570 - Second Edition, October 1998

Note: At the end of this document the following note appears, “ The above references show the current issues when this procedure was issued. The latest Edition and Addenda of these documents shall be used in conjunction with this procedure”.

It is this editor’s opinion that such wording helps expedite the effective inclusion and availability of the latest in recognized and generally accepted good engineering practices into regulatory rules and law without the delays encountered in most regulatory governments. It would seem to make more sense to exclude questionable references by exception, thus assuring that best practices are available in a timely manner.

The documents may be accessed in their entirety via the internet at: http://www.absa.ca/ Inspection/default.htm
If you have any suggestions on how to improve the RBI document, please send them to ABSA at 200, 4208-97 Street, Edmonton, AB, T6E 5Z9, Attention: Bill Litvinchuk. (litvinchuk@albertaboilers.com)