Risk Based Inspection - The Regulatory Acceptance Process

Note Well: It is the reader’s responsibility to verify all information contained in this article prior to any decision making with their appropriate authorities, corporate and or plant management and policies. Although we believe the information to be correct the Inspectioneering Journal assumes no liability for the accuracy of information contained in this article and welcomes comments, corrections and updates. Please e-mail all updates, comments or corrections to inquiries@inspectioneering.com. The IJ will verify and publish such. As most readers know, the state of RBI rules written around acceptance is in an active state of “ flux" in many jurisdictions around the world. Some are more established and a sampling is provided in this article.

Over the past 18 years of serious RBI involvement, it has become clear to me that there are certain hurdles, that when “cleared”, have paved the way to jurisdictional acceptance of RBI (and fitness for service, for that matter). This article will cover many of these “steps”, not all as they are numerous, that have lead to success in some of the “toughest” jurisdictions in the US and the world. On your marks, get set, here we go....

An Understanding of RISK

We must first have a clear understanding of risk/s. This is made clear in API’s RP for RBI 580. Anyone wanting to comply must wrestle with these types of questions:

• What do we want to include in the risk equation
• Health and safety
• This is a “must” and is the primary concern for most regulators
• Environmental impact
• Depending upon your jurisdiction, this could be an important facet considered by environmental protection agencies who typically have marginal “up-front” direct impact on a pressure vessel/piping inspection program. Their typical impact is usually tangential and after an incident. They are not the usual regulating agency exercising authority over pressure vessels and piping. They usually have more direct impact on above ground storage tanks and associated facilities’, over water facilities, and buried structures inspection programs. For the sake of this article, regulatory acceptance will be limited to pressure vessels and process piping inspection programs
• Business risks, e.g. business interruption costs, capital equipment replacement costs, turnaround costs, inspection costs, associated maintenance costs, etc.
• These are generally of no concern to regulators but of high concern to owner operators

• What is/are our risk targets or thresholds (an article in the September/October 2007 Inspectioneering Journal covered this topic)

Now as we set the stage for working with regulators to achieve compliance let’s rst take a look at how far we have come in the last 15 years and how we have gotten to where we are.... At a large industry conference in Las Vegas, circa 1989, I recall giving a presentation on RBI to a crowd of approximately 300- 400 attendees. The general attitude was - “Risk is a bad word. If I don’t bring it up or say I am using risk management principles to manage my equipment integrity, then I don’t have any risk!” If you have any trouble believing this, read these two real accounts of comments and questions during my presentation, one from an owner operator representative of an oil refinery and the other from a chemical processing facility representative: