Overview of Management of Change (MOC)

Advancements in technology offer organizations huge opportunities for improvement. However, adoption of new tools can change the way an organization functions. If not properly managed, these changes can lead to wasted time and money and ultimately, failed initiatives.

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Although value-drivers often differ between facilities, all can agree that effective asset management strategies should lead to better decision making. In this case study, the authors detail how process-based risk management strategies can make for improved use of equipment.

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The U.S. Occupational Safety and Health Administration (OSHA) recently released a new guide to help petroleum refiners comply with its Process Safety Management (PSM) standard (1910.119). The guide presents lessons learned from the petroleum refinery Process Safety Management National Emphasis Program.

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Integrity Operating Windows (IOWs) have a subset of operating variables that are important for degradation monitoring, but may not have direct operational controls. Per API RP 584 Integrity Operating Windows, these are known as IOW Informational Limits, which are often neglected or misunderstood by operations or technical personnel within a plant.

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Evaluating remaining wall thickness of an asset is not enough to ensure its continued safe operation. Proactive strategies should be implemented to assess the entire environment affecting an asset’s condition, including the development of more effective inspection plans.

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Turnarounds are costly in terms of lost production. In many respects a turnaround can be even more complicated than the initial construction of the facility, so a carefully designed plan will reduce overall costs. After execution, safety reviews, Corrosion Monitoring Program updates, MOC documentation, and PHA Revalidations are a must.

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This article presents a perspective on the human factor and emphasizes the value of using risk tools at all levels in the organization to help provide management focus during times of severe economic pressure.

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Data, in pure form, consists of raw, unorganized facts that need to be processed. Data can be found in databases, documents, drawings, reports, spreadsheets, and numerous other sources. Having data on hand is useful, however, it’s often inefficient and counterproductive to make decisions based on data in its raw form.

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Equipment integrity and reliability programs are essential for refinery and chemical facility operators. The processes of the programs are developed to ensure safety, optimize component life cycles, and promote smooth and economical operations.

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If we could measure, understand, mitigate, and most importantly, control corrosion, we can do a better job of keeping the product in the pipes. To accomplish this task, we needed to know what is causing the corrosion and how to control it.

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Management of change (MOC) for fixed equipment mechanical integrity (FEMI) issues is one of the most important of the 101 essential elements in pressure...

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The Vanta handheld XRF is Olympus’ first full spectrum PMI analyzer that is IP65 rated and drop tested. The analyzer provides accurate, repeatable material chemistry and alloy grade matching in as little as 1–2 seconds. Operation is simple with an intuitive touch screen and swipe interface. Optional Wi-Fi, with the Olympus Scientific Cloud, provides seamless connectivity for efficient data and fleet management.

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One of the major challenges inspectors and plant operators face after each turnaround is to ensure that all repair and scope work is and was completed in accordance with the client’s requirements. Sometimes that verification will be to ensure work was completed in conjunction with the applicable codes, and sometimes that it was completed in conjunction with the client’s own in-house specifications.

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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.).

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Fixed equipment mechanical integrity (FEMI) failures are not caused by damage mechanisms; rather, they're caused due to failure to create, implement, and maintain adequate management systems to avoid failures. Nearly all failures that have occurred in our industry could have been avoided if these human systems were more robust and sustainable in providing the primary layers of protection for FEMI.

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As I stated in my previous post, there are 10 essential Management Systems (MSs) needed for an effective PEI program that can achieve excellence. These 10 PEI MSs contain all the necessary information that describe what needs to be accomplished, and how to accomplish it, in order to achieve success in PEI.

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Knowing what needs to be accomplished in order to achieve excellence in pressure equipment integrity (PEI) is one thing, but knowing how to organize it all for success is quite another.

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Let Pro-Surve identify corrosion on your flange raised faces while your unit remains in operation. Using phased array TFM, custom transducers and proven procedures Pro-Surve technicians identify corrosion on flange raised faces from the flange outside diameter. Identify scope for pipe spools for turnaround pre-fabrication using this technique. Identify flanges needing replacement or re-machining.

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These posts came about because, 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. When that happens, they are suddenly on...

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Without doubt management needs to ensure that the appropriate resources (human and budgetary) need to be provided for corrosion control and prevention. The C/M engineer/specialist or other responsible party needs to assure that management is advised annually at the appropriate time what resources will be needed for the next budget cycle.

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Who at your facility “owns” injection point hardware? Typically, injection point hardware falls into the “Gray Zone”.

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Over the past few years increased feedstock flexibility has become a growing reality for sustainability of the refining business, requiring processing of more difficult crudes, increased volumes of spot cargoes, and rapid response to crude acceptance requests. Equipment reliability and process safety threats have occurred in the industry from changes in crude supplies or varying crude blends and quality.

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High Temperature Hydrogen Attack (HTHA) is a long known and still occurring degradation issue for fixed equipment construction materials in the hydrocarbon process industry where hydroprocess plants (hydrogen plus hydrocarbons) are in service. Though HTHA failures in these units are the focus of this article, it is important to recognize that HTHA damage can also occur in high pressure boiler tubes, hydrogen producing units, synthetic gas units, ammonia plants and other equipment where hydrocarbons may not be involved but high temperatures are involved.

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How long does it take for you to receive reports after an inspection has been completed? A week? A month? Does the data come from multiple sources with no way of knowing if it has been manipulated? Traditional inspection contractors do not have the ability to provide reliable and real-time data once an inspection is complete. The only way to ensure accurate, reliable data is with technology.

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This article in the series will focus on two more of the necessary MSs for achieving excellence in PEI: Integrity Operating Windows (IOWs) and Management of Change (MOC).

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Catastrophic oxidation can occur when certain contaminants are present in a high temperature environment, i.e. inside furnace fireboxes, in our industry. Those contaminants are typically vanadium pentoxide with sulfur oxide or sodium sulfate.

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High temperature oxidation is not a real common type of failure in our industry, but it can and does happen when temperatures exceed design maximums. All metals oxidize, even at room temperature, and in many cases that slow oxidation process actually protects the metal from rapid oxidation.

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High temperature sulfidation is probably the most common high temperature corrosion nemesis in the refining industry, since there are very few “sweet” refineries still in operation. Sulfidation corrosion typically is of concern in sour oil services starting at temperatures in the 500F (260C) range.

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This is the first of a series of articles that outlines the 101 essential elements that need to be in place, and functioning well, to preserve and protect the reliability and integrity of pressure equipment (vessels, exchangers, furnaces, boilers, piping, tanks, relief systems) in the refining and petrochemical industry.

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In the Jan/Feb issue of the IJ, I mentioned how important the Management of Change (MOC) process is when it comes to maintaining safe, leak-free piping systems; stating that we in the inspection business cannot do it alone; that is, we taint the integrity of piping systems without a lot of help from operating personnel and operations support engineers.

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It's probably more important to those of us who don't have a brain tumor. Unfortunately, it's precisely because piping inspection is not neurosurgery that it's often done poorly, which can lead to significant impacts on process unit reliability, or worse, a catastrophic event, where people can get hurt.

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This publication outlines 101 Essential Elements that need to be in place and functioning well in order to effectively and efficiently preserve and protect the reliability and integrity of pressure equipment (i.e. vessels, exchangers, furnaces, boilers, piping, tanks, and relief systems) in the refining and petrochemical industry.

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OSHA recently released a new guide to help petroleum refiners comply with its Process Safety Management (PSM) standard (1910.119). The guide presents lessons learned from the petroleum refinery Process Safety Management National Emphasis Program.

• Continue reading...

The U.S. Chemical Safety Board (CSB) has released its final report into the August 28, 2016, nitrous oxide explosion at the Airgas manufacturing facility in Cantonment, Florida. The blast killed the only Airgas employee working at the facility that day and heavily damaged the plant, halting its manufacturing of nitrous oxide indefinitely.

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Vanessa Sutherland, Chairperson of the U.S. Chemical Safety Board, released a statement on Thursday, the 12th anniversary of the BP Texas City disaster that killed 15 workers and injured 180 others.

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The U.S. Chemical Safety Board (CSB) has released a safety video detailing its investigation of the June 13, 2013 explosion and fire at the Williams Olefins Plant in Geismar, Louisiana, which killed two workers and injured an additional 167. The deadly explosion and fire occurred when a heat exchanger containing flammable liquid propane violently ruptured.

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The U.S. Chemical Safety Board (CSB) has released its final report into the June 13, 2013, explosion and fire at the Williams Olefins Plant in Geismar, Louisiana, concluding that process safety management program deficiencies during the 12 years leading to the incident led to the explosion, which killed 2 workers and injured over 150 others.

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