Inspectioneering Journal

Why Some Operating Sites "Just Don't Get It"

By John Reynolds, Principal Consultant at Intertek. This article appears in the May/June 2007 issue of Inspectioneering Journal.

From time to time, I’m asked why some operating sites don’t seem to pay adequate attention to the need to protect and preserve pressure equipment integrity (PEI). Too often a few sites don’t seem to “get it” until they have a major process safety event associated with a failure of pressure equipment. And unfortunately when that happens, they are suddenly on board with PEI needs and don’t seem to be able to apply their available resources fast enough. Fortunately, I see less and less of this type behavior as time passes and the word spreads throughout the industry about PEI catastrophes and how to avoid them.

In this article, I will address some of the reasons that I believe some sites don’t pay enough attention to PEI needs. But first, I need to emphasize once more that you can’t start with a mediocre PEI program and expect to have an excellent one in a year or two. It just doesn’t happen that fast. In my experience, if you have a mediocre PEI program (or even worse than mediocre), it may take between 5 and 10 years to build it into a really solid, sustainable PEI program of excellence by systematically and meticulously putting in place all the necessary management systems for the entire spectrum of the “The 101 Essential Elements of Pressure Equipment Integrity Management for the Hydrocarbon Process Industry”(1).

By no means is this article meant in any way to be a finger-pointing or faultfinding exercise for anyone or any site. It’s meant only to help sites recognize if they might suffer from any of these symptoms (i.e. excuses) for lack of an adequate PEI program, and to help them address them, as necessary, before it’s too late. You will also note as you read through the reasons, that they are highly intertwined, i.e. that most are interrelated and that if one reason exists, then several others may also exist.

Now let’s begin with those seven reasons that I have observed about why a few sites just don’t seem to “get it”.

Reason No. 1

Lack of risk management knowledge or ineffective application of risk analysis by some plant management. Effective risk analysis and risk management are keys to successful management of PEI risks, just as they are to all other risks in a plant environment. Most cost-effective inspection planning these days is accomplished by the application of RBI, at least at the operating sites with more advanced PEI programs. Clearly effective risk analysis is the heart and soul of effective RBI programs. Well, lo and behold, effective decision-making is also accomplished based on effective risk analysis. If management understands the magnitude of the risks they are carrying by not having effective piping inspection programs, injection point management programs; deadleg programs; PMI programs, CUI programs, etc. on down the list of the 101 Essential Elements, then they are much more likely to provide the necessary resources to build excellence in those programs. If management acts to resource these programs based on their past experience and knowledge, then well-and-good; but if not, effective risk analysis which indicates the combined consequences and probability of PEI failures, is a very effective method of getting management attention to the higher risk PEI issues that need to be addressed.

Reason No. 2

Lack of strong-willed, competent PEI engineers/supervisors/leaders willing and able to be advocates for the necessary PEI issues. Management does not come by their knowledge of the importance of PEI issues by “assmosis” (which has been euphemistically described as the practice of sitting on a copy of the 101 Essential Elements until they are fully understood). Management has a lot of issues on their platter, most of which compete for attention and budget funds with PEI issues. Typically one of the main responsibilities of many managers is to determine how to “stuff a quart into a pint jar”. So management needs to hear about PEI issues from strong advocates for the 101 Essential Elements. They need to hear about incidents in your company and in other companies where failures of pressure equipment have led to process safety incidents and poor reliability. For many years, I have routinely attended the API Operating Practices Symposium (OPS), which is a day-long session at each of the semi-annual API Refining Meetings. At these meetings (which are only open to attendees from operating companies in the industry), numerous process safety incidents are explained in detail, i.e. what happened, why it happened, what corrective action was taken, and how such incidents can be prevented. At every OPS, there are presentations on PEI failures, on which I would report back to my management and technical associates to keep them apprised of higher risk PEI issues that were causing process safety incidents in the industry.

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