Who at your facility “owns” injection point hardware? Typically, injection point hardware falls into the “Gray Zone”. Gray Zone equipment is that equipment which falls between functional disciplines, so there is not always a responsible person or functional discipline to ensure it is tinspected and maintained in an appropriate manner. As a result, this kind of equipment sometimes fails, which can lead to an unscheduled outage, or (worse) a safety incident, as the injection point hardware is usually installed to inject a chemical that mitigates corrosion or cracking, etc.
Failure of ancillary hardware that leads to major equipment failure often catches management by surprise and produces a lot of finger pointing between different departments. Each of these departments has an interface with the Pressure Equipment Management (PEM) function, so it is imperative to make sure there is a designated party responsible for important aspects of each part of injection point hardware; be it design, operations, inspection, or maintenance. A set of guidelines detailing roles and responsibilities should be developed, clearly defining the aspects of the injection point hardware. It does not always have to be the same party for each aspect of the life cycle.
Who is responsible for ensuring the continued effectiveness and integrity of the injection equipment?
All too often the answer to this question is dependent upon who you ask, but the typical response is one of the following:
- The Chemical Supplier, or
It is typical to find that no one has direct responsibility; it just falls into that Gray Zone! Inspection always has the ownership of the “Injection Point”, as described in API 570, but that only involves the pipe itself, not the hardware.
As Vince Lombardi said when he took over a mediocre National Football League (NFL) team in a small town in northern Wisconsin back in the late 50’s, “if we go back to the basics, including blocking and tackling, and do them well, we will win.”
It is important for everyone, including Plant Management, to understand that the job of protecting and preserving all stationary assets in a hydrocarbon processing facility belongs to a multitude of people, not just the Engineering, Inspection, or Corrosion group. An effective PEM program includes specific roles for Operators, Craft persons, Asset Managers, Process Engineers, Project Engineers, as well as Inspectors and Corrosion Engineers. Plants that have specific roles and expectations clearly defined and effectively implemented for each of these contributors will be the most effective in preventing asset losses from breach of containment.
It does no good to write procedures and best practices that are not effectively implemented or followed. It does no good if one person knows the necessary information to do the job, but does not effectively transfer that information to those who need it on the front lines. This article discusses some of the many aspects of injection equipment and how the various parties could be involved.
Industry documents such as API 570 “Piping Inspection Code” and NACE Technical Committee Report 34101, “Refinery Injection and Process Mixing Points, identify which injection points require special attention during engineering design, and recommend additional monitoring and/or enhanced inspection during operation. The guidelines were developed with the recognition that injection points that are not functioning properly have caused significant equipment integrity problems. In some cases, injections have been installed without close attention or engineering study, simply because they were perceived as small add-ons with little potential for causing a problem. Unfortunately, many people think of injection points as process tie-ins or process connections, and may even categorize the equipment as “unimportant.”
Design of injection systems and injection points should be no different from the design of any other part of the process system or a tie-in. The same rigorous principles of chemical, mechanical, materials and corrosion engineering apply. Design requirements and strategies are selected based on the need to accomplish the particular purpose of the injection and to avoid potential problems.