Based on my 45+ years of experience working with fixed equipment mechanical integrity (FEMI) issues in the refining and petrochemical processing industry, this article summarizes what I believe are the top 10 reasons why pressure vessels and piping systems continue to fail, thus causing significant process safety events (e.g. explosions, fires, toxic releases, environmental damage, etc.). This top 10 list does not include the physical causes of the failure, such as corrosion, cracking, embrittlement, or the other 65+ damage mechanisms and failure modes that can afflict fixed equipment in the petroleum petrochemical industry, as those damage mechanisms and failure modes are just the final result of several other layers of protection that fail first. Rather, this top 10 list is mostly focused on the human system failures associated with inadequate or poorly implemented management systems for FEMI. Being aware of these human system failures and mitigating the reasons for them can substantially reduce process safety events caused by fixed equipment failures. I caution you not to “blow this off” because you have not had any big fires, explosions, toxic releases or process safety incidents lately. They do not happen very often; but when they do, they are often major events which not only threaten lives, but may even threaten the sustainability of your on-going business.
The hydrocarbon process industry as a whole continues to have numerous repeat failures of pressure equipment and piping, and too many of them involve large process safety events with major asset losses, environmental damage, injuries, and fatalities, even though most of the reasons for those failures and the necessary mitigation steps are well known and documented in industry codes and standards. Having been involved in numerous failure investigations and having read about hundreds more, I have come to the conclusion that there are 10 primary reasons why they continue to occur. Certainly there are more than ten reasons and there are many contributing factors, as well as root causes for each major failure, but it is my opinion that if the necessary management systems and mitigation steps for these top 10 reasons were adequately implemented and sustained at each hydrocarbon process site, the vast majority of the these failures could have been avoided. These top 10 issues are not stand-alone. Each one is typically integrated and overlapping with the other nine; but for organizational purposes, I needed to separate them individually to highlight their importance. So let’s get right to the meat of the issue. Here are my top 10 primary reasons for continuing FEMI failures in the hydrocarbon process industry:
- Inadequate or lack of identifying and managing the highest priority FEMI risks in each process unit.
- Inadequate or lack of comprehensive Corrosion Control Documents (CCDs) for each process unit.
- Inadequate or lack of a thorough, comprehensive piping inspection program
- Inadequate or lack of a comprehensive program for Integrity Operating Windows (IOWs) for FEMI.
- Inadequate or lack of a comprehensive Management of Change (MOC) process for FEMI issues.
- Inadequate implementation of all the guidance contained in the latest editions of industry codes and standards for FEMI.
- Inadequate or lack of comprehensive programs to learn from the bigger FEMI failures in the industry before similar failures at your site.
- Insufficient inspection planning and not using the best available technology for nondestructive examination (NDE).
- Inadequate or lack of comprehensive FEMI record-keeping and data analysis.
- Insufficient FEMI training and knowledge transfer for all those with a role in maintaining FEMI.
Some might look at that list and say to themselves: “Well, we already do all of those things.” But my point is that if each operating site wants to largely eliminate the risk of a major FEMI event at their site, then each operating site must be able to obtain an “A” grade on each of these top 10 FEMI issues; not “Cs, Ds, or worse (i.e. they need to achieve excellence in implementation, not just “compliance” or “checking the box”, whatever that is). As many of my readers already know, those that are just seeking compliance with rules and regulations will not likely be able to achieve excellence in FEMI and will remain exposed to a serious FEMI event. In an effort to not provide you with more information than you could reasonably digest in one sitting, Part 1 of this article was published in the September/October 2014 issue of Inspectioneering Journal and covered the first five reasons for FEMI failures in the hydrocarbon industry. Part 2 herein covers the next five reasons, starting with failure to adequately follow industry codes and standards.