Utilizing Risk Assessment to Determine the Scope of FEMI QA/QC

Introduction

Quality assurance and quality control (QA/QC) on maintenance repairs and replacements can chew up a lot of valuable FEMI effort from trained, experienced inspectors that might be better spent on higher priority FEMI issues. This is especially true for repair, replacement, and minor projects going on during a turnaround where there is a high demand on FEMI personnel for other priority FEMI needs. But it’s also true for routine maintenance during operations, and especially for temporary repairs that must last until a more permanent repair can be accomplished ^[1]. Hence, it’s important that we have a methodology and plan in place to do the right amount and the right type of QA/QC by the right people for each site project or repair job. For more commentary on QA/QC on maintenance repairs and replacements, refer to elements 61, 64, and 65 in "The 101 Essential Elements in a Pressure Equipment Integrity Management Program" ^[2].

Qualitative Risk Assessment for QA/QC

Utilizing a risk assessment methodology to determine the amount of detail in our QA/QC plans, as well as who needs to be involved, may help us improve both the effectiveness and the efficiency of our QA/QC work process. Many sites have a standard plan and approach to QA/QC for repair and replacement of equipment conducted by site personnel and/or contractors. However, it makes good sense to do a risk (criticality) assessment beforehand to determine how much QA/QC is really needed for each job in on-site shops and in the field while complying with any code or other regulatory requirements. Likewise, the risk assessment should consider the availability of qualified, capable, conscientious FEMI personnel, be they in-house or contractor.

Higher risk equipment usually requires more intensive QA/QC, often because the consequence of inadequate quality fabrication and installation is greater than that of lower criticality equipment. Lower risk equipment, where the risk of failure is less than higher risk equipment, may deserve less attention from FEMI personnel and more reliance on maintenance or contract personnel to get it done right.

Just as risk assessments for shop source inspection is important in accordance with API 588, conducting risk assessments for QA/QC field work needs is a worthwhile effort for site repairs and minor projects during routine maintenance and turnarounds ^[3]. Risk assessment issues to consider when determining how much QA/QC to apply to these maintenance projects and jobs and the qualifications of those who conduct the QA/QC may include:

• Safety or environmental issues that could occur because of equipment failure while in service; for example, equipment that might fail and cause a significant process safety or environmental issue may require more QA/QC attention during fabrication and installation.
• Equipment complexity and integration with other equipment; the more complex the equipment, the higher level and skill of source inspection may be required.
• Knowledge of maintenance and project craft capabilities and having previous experience with them in delivering equipment-meeting specifications; for example, working with trusted, highly-experienced in-house and company crafts may need less QA/QC attention from FEMI personnel.
• Criticality of equipment should it not operate as designed or fail in service; for example, if a sold-out process unit or section of a process unit could fail in service without adequate QA/QC attention during maintenance, more priority would be placed on making sure the site had adequate QA/QC. On the other hand, low criticality equipment that would not have much impact if it were to fail in-service might be a candidate for less FEMI QA/QC attention and more reliance on well-trained, conscientious crafts to conduct the specified QA/QC.
• Critical path items in a turnaround or an unscheduled maintenance shutdown; such jobs would typically require more QA/QC attention from highly competent FEMI personnel to make sure the site is not exposed to unduly extended shutdown due to lack of adequate QA/QC.