ABS Consulting TRAINING SERVICES Presents: Mechanical Integrity ‘ABS Consulting Training Services 10301 Technology Drive Knoxville, TN 37932-3392 (865) 966-5232The information contained in this course notebook consists of facts, concepts, and principles for understanding, estimating, and controlling the risk of catastrophic accidents. However, this information is not specific to the operations of any company, plant, unit, process, system, or equipment. Therefore, ABSG Consulting Inc., operating as ABS Consulting, and the Process Safety Institute assume no liability for this course material beyond the material's intended purpose of Providing information to assist in applying risk management philosophy. DO NOT attempt to operate any facility, unit, process, system, or equipment based solely on the information provided in this manual. Refer to your own operating procedures, equipment descrip- tions, operating limits, safety and health considerations, etc, NOTE Attendance in any Process Safety Institute (PSI) course or workshop does not entitle any attendee to train any other person(s) using PSI materials, forms, formats, ideas, or concepts withouta specific license from PSI to conduct such tr: ©2002 by the Process Safety Institute, a division of ABSG Consulting Inc. ALL RIGHTS RESERVED. Material contained herein may not be copied by hand, mechanical, or electronic means, either wholly or in part, without the express written consent of the Process Safely Institute or ABSG Consulting Inc.Mechanical Integrity Table of Contents Introduction Designing an MI Program ...1..... Developing an MI Program... Implementing and Maintaining an MI Program, Assessing and Improving an MI Program Course Wrap-up..... Generic Written Program Material — JBFA Chemical Company Mechanical Integrity Program for the Anywhere Plant .. Resource MaterialInstructor Profile Mr. William M. (Bill) Bradshaw, a senior riskirelicbility engineer at ABS Consulting, has over 25, vyears of experience in the chemical and nuclear industries. He is the lead instructor for ABS Consulting's ‘courses on process safety management (PSM), mechanical integrity, and management of change, and, he also instructs ABS Consulting courses on process hazard analysis and PSM auditing. Mr. Bradshaw also consults within awide range of process industries, helping them to develop mechanical integrity and, other PSM programs, facilitating process hazard analyses and risk analyses/studies, and conducting compliance audits Before joining ABS Consulting, Mr. Bradshaw served in a variety of positions with ICI Acrylics, Inc, including business engineering and technology manager, plant operations manager, production superintendent, and maintenance manager. Previous assignments include technical positions in Union Carbide’s Nuclear Division in Oak Ridge, Tennessee, and 4 years service as an officer in the U.S. Army Comps of Engineers, primarily working on processes to dispose of chemical weapons at Tooele Army Depot, Utah, He has extensive experience with processes involving highly hazardous chemicals, including nerve agent and a variety of nonlethal chemical weapons and explosives, UF,, and highly flammable liquids, Mr. Bradshaw recently co-authored and managed the production of the American Insitute of ‘Chemical Engineers’ (AICHEs') book on the latest generation of PSM systems titled Guidelines for Risk Based Process Safety (2007). He also contibuted to other recently published AIChE books: Guidelines for Mechanical Integrity Systems (2006) and Guidelines for Management of Change (2008). In addition, Mr. Bradshaw has published several papers on topics relaied to PSM. Mr. Bradshaw received his bachelor of engineering degree in chemical engineering from Vanderbilt University in 1979. He received his M.S. in engineering scionce and mechanies from the University of Tennessee in 1985,Acronym ANSI APL ASME ASNT ASTM AWS BLEVE ccPs CFR CGA a CMA CMMs EPA HHC ISA Iso ITPM Mi Moc NBIC NFPA, ORC OSHA oT™ P&ID PHA PHM. PM PMI Pov PSC PSM PSSR Qa ac RMP Swe TML List of Acronyms Description American National Standards Institute American Petroleum Institute American Society of Mechanical Engineers American Society for Nondestructive Testing American Society for Testing and Materials American Welding Society Bolling liquid expanding vapor explosion Center for Chemical Process Safety Code of Federal Regulations Compressed Gas Association Chlorine institute Chemical Manufacturers Association Computerized maintenance management system, Environmental Protection Agency Highly hazardous chemical Intemational Society for Measurement and Control (formerly Instrument Society of America) Intemational Organization for Standardization Inspection, test, and preventive maintenance ‘Mechanical integrity ‘Management of change National Board Inspection Code ial Fire Protection Association Organization Resources Counselors Occupational Safety and Health Administration OSHA Technical Manual Piping and instrumentation diagram Process hazard analysis Process hazards management Preventive maintenance Positive material identification Program Quality Verification Process Safety Code of Management Practices Process safely management Pre-startup safety review Quality assurance Quality control Risk management program Safe work practice Thickness measurement locationMechanical Integrity: Introduction Process Safety Institute Course 111ree Cera ness MI Program Life Cycle + + i t as = Impure” |_ [Continual ‘pectteaton | | programm iereoement | | sectve red {compar aaa scion | [Ar | lacemenae fore feawoncy lequpone oncancy pe Introduction What is mechanical integrity? Mechanical integrity (MD) includes activities to ensure that mechanical equipment is designed. fabricated, procured, installed, and maintained in a manner appropriate for its intended application. Just as with a large engineering project, itis helpful to recognize the different phases of an MI program's life cycle. Many students in this course are ‘working with MI programs that have already been designed and, in some cases, are well into development. This course will ask you to re-examine the design assumptions and re-visit development efforts to help you understand and prepare for implementation/maintenance efforts and strive for continual improvement. Why do we need MI programs? * Safety. Good mechanical integrity really does make a plant safer. * Environmental protection. Good mechanical integrity helps keep chemicals contained, * Reliability. Good mechanical integrity helps reduce unplanned outages, reduce repairiteplace costs, improve plant efficiency, and improve product consistency. + Regulation/conformance. If motivated by nothing else, government agencies and industry societies help encourage good mechanical integrityCourse 111 Notable Mechanical Integrity FailuresMechanical Integrity: Tab 2 Designing an MI Program Process Safety Institute Course 111shat Marat) MI Program Life Cycle =... : MI Program Design A design specification for your plant's MI program provides (1) program developers with a blueprint to follow that includes an understanding of management's expectations for the MI program and (2) a vision statement that can help keep different affected departments on a consistent path toward ML. Program design parameters (particularly program scope) should be widely communicated. The workshop we will use in this section of the course can be a useful tool for initiating a dialog between affected departments (e.g.. maintenance, operations, engineering, upper management) on Mf issues, ‘Things to consider in your design specification include: + Company objectives for the MI program, including speeific company needs/desires + Compliance philosophy for regulations and standards + Program scope + Resource availability * Key global issues, such as the level of detail procedures will have and who will approve continued operation of deficient equipment * Schedule milestones Even for facilities that have already established an MI program, re-examining. design issues can (1) help orient new personnel to the goals of the MI program and (2) help existing personnel resolve MI the problems if the personnel involved in developing/implementing the MI program have lost focus on the design objectives.Satis Nigar Tees Overall philosophy + What approaci will be taken? ~ Are we trying to be world class? (Comprehensive) ~ Are we trying for compliance only? (Minimal) ~ Is there a part of the process that cleserves specta (Equipmendunidfacility specific) attention? Applicable codes, standards, etc. Of the many codes and standards available, which will be important for our facility? We're not an oil refinery, but should we follow API recommended practices? Do we have the resources available to comply with ISA? Listed below are some typical standards organizations. + ANSI + API + ASME + ASNT + AWS *CCA el + ISA + NBIC + NEPA In the Resource Material section of this course is a paper outlining an approach to "Recommended and Generally Accepted Good Engineering Practices. One petrochemical company's compliance statement Creative communication of codes and standards can help program developers and serve as a reminder to engineers and others involved with implementation. One company’s code document is included in the Resource Material section of this course. pe}DES acu sc MI Interfaces Within a PSM Program 7 cero! lntegrity MI Interfaces Within a PSM Program When establishing the MI program design, don't forget that MLis one element of an integrated PSM system. Take advantage of existing PSM activities and remember to be consistent with overall PSM objectives. The diagram above illustrates some PSM interfaces for your MI program to consider. Arrows indicate a ow of information or materials. In some cases. there is a two- way flow of information (illustrated with two arrows), Double-headed arrows identify opportunities to meet the requirements of two elements with ‘one activity. PSM program interfaces include the following: *+ Employee participation = employees from various departments should have input into your MI program ~ employees on your MI staf (e.g., maintenance employees) must be included in the employee participation plan + Process safety information ~ design codes and standards should influence MI activities ~ Ml activities can help document that equipment is appropriate for its intended use * Process hazard analysis (PHA) ~ PHAs can help prioritize MI activities ~ PHAs can help identify and document covered equipment boundaries + Operating procedures ~ procedures governing operator activities may contribute to MI (e.g.. operator rounds, preparing equipment for maintenance) ~ operating procedures may also contain inspection, test, and prevei maintenance (ITPM) activities performed by operators Ly Borneo Crm ne ts 2.EN eeooactd Com + Trai ML training in an overview of the process and its hazards should be consistent with operator training information + Pre-startup safety review (PSSR) ~ the MI quality assurance requirement to ensure that equipment is Installed according to design can be addressed during a PSSR + Contractors ~ the contractor selection process should consider both contractor safety performance and the quality of contractor work + Incident investigation ~ Mirecords may be needed by investigation teams = Investigation recommendations may impact MI activities + Emergency planning and response = emergency response equipment should be included! in your MI program. (explicly required in EPA's RMP regulation) + Management of change (MOC) MOC should apply to Ml activities and documents = the MOC program may be upgraded to help manage equipment deficiencies + Trade secrets = trade secrets cannot be withheld and may impact Ml act + Safe work practices (SWPs) ~ SWP% provide some basic MI procedures + Compliance audits = your MI program will be audited, which may result in audit recommendations that need to be addressed o wieWorkshop 2-1 Scoping Mechanical Integrity Program ImplementationCee es Designing an MI Program Problem Statement Purpose ‘The purpose of this workshop is to explore possible scoping boundaries for mechanical integrity (MD) implementation within your company. This workshop will guide you through the process of defining an overall MI implementation strategy that will serve as the specification for the MI program. This exercise should help you clarify your MI strategy and/or help guide your company’s management to a definitive MI strategy before developingyimplementing an MI program. Ideally, a complete specification should provide all ofthe strategic information that you would need to develop and implement an Ml program that meets all of management's (reasonable) expectations. Instructions ‘Complete the following scoping checklist by (1) marking all of the boxes that seem to meet your company’s needs in each Mf area and (2) completing any blank spaces for items that you check. Be certain to consider both the positives and negatives for each choice you make (especially costs, staffing needs, production interruptions, etc., associated with your strategy for implementing Ml efforts).re eae Problem Statement (cont'd) eee ee Issue Comments [Specific objectives against which the Mt |program will be judged 2 OSHA PSM compliance 2 EPA RMP compliance 12 API RP 750 conformance 2 CMA PSC conformance 2 CCPS PSM conformance 2 180 conformance 1 Process incident reduction 12 Traditional safoty incident reduction 2 Downtime reduction 12 Equipment life improverents 2 Process quality improvements 2 Maintenance costefort reduction [2 Organizational improvements 1D other: Types of equipment lwithin the scope of the Mt program (O Pressure vessels (including jackets and internal coils) (C Low pressure storage tanks {including jackets and internal coils) 12 Atmospheric tanks (including jackets and internal coils) IO Secondary containment (including kes, curbs, sumps, other} 1 Fired heaters ID Heat exchangers 2 Piping and piping system components (valves, flanges, elbows, couplings, ot.) 2 Rotating equipment (including Pumps, compressors, convoyors, turbines, other): 10Core ee PG See Problem Statement (cont'd) Issue Issue Issue ‘Comments 2 (contd) [Types of equipment | Process instrumentation and |within the scope of the | controls (e.g., temperature, MI program pressure, and flow controls), including sensors, transmitters, ‘controllers, solenoid valves, actuators, alarms, interlocks, other: 1D Equipment protection instrumentation and controls (2.9.. temperature and vibration), including ‘sensors, transmitters, controllers, solenoid valves, actuators, alarms, interlocks, other: [Q Safety instrumentation, interlocks, shutdown switches, etc. [A Rott devices, (including rupture disks, relief valves, relief headers land atmospheric vent lines, manways, water seals, other) IO Structural members: supports, foundations, other: |G Electrical power equipment (including transmission lines, transformers, buses, broakers, snitchgear, other): VenProblem Statement (cont'd) Crees: Issue Issue Issue Comments 2 (conta) Types of equipment lwithin the scope of the MI program 1D Plantwide safety equipment (including firelevacuationtvaming systems, gas detection systems, ‘emergency communications systems, safety showers, eyewash stations, warning signsilights, other} 2 Other safety equipment (including fire extinguishers, respirators, SCBA, masksistields, ladders, harasses, other): 2 Liting equipment (including cables, chains, ropes, other): |G Protective devices on equipment; including shields, insulation, other: [Services to include (or to get special attention): ID Highly hazardous materials (as defined by OSHA PSM andlor EPA RMP) [2 Other “hazardous” materials (specify materials and hazards of interest) EatCees rua Problem Statement (cont'd) Issue Issue Issue Comments 3 (contd) [Services to include (or |O Utlity services for otherwise covered to gat special processes (circle or specify): attention): nitrogen, purge gas, air, carbon dioxide, carbon monoxide, cooling water, tempered water, process water, deionized water, fre water, waste water/streams, high pressure steam, low pressure steam, steam condensate, electrical equipment, heat transfer fluidsirefigerants, halon, foam, other: |G High temperature equipment (define temperature threshold} IG High pressure equipment (define pressure threshold} C1 Nonchemical services (specify): IC All equipment services handled similarly 4 [Characterizing the [0 Instrument loopslsystems: equipment lst (.e. or level of detail) JG instrument system components (e.g., sensors, transmitters, interiocks) 12 Piping systems 1Q Piping system components (e.9.. pipes, vaives, check valves, flanges, elbows, tees) ID Pumpicompressor systems or ID Specific component system (e.g, lube oil, seal flushing systems) Eee neTeac Problem Statement (cont'd) Correos Issue Issue Issue ‘Comments 5 [Phases of equipment life controlled under Mi activities |B Designing equiomentisystems [2 Ordering/ourchasing equipment systems, |O Fabricating/manufacturing equipmentsystems |G Ordering parts/materials ID Receiving and storing equipment parts/materials| 2 Installing equipmenv/systems 12 Operating equipmentisystems 12 Inspecting, testing, and maintaining equipmentisystoms 1G Ropairing equipmentisystems 12 Decommissioning equioment! systems IC Reusing equipmentisystoms 2 other: @ [Organizations invowved with Mt activites ID Unit oparations (including the unit manager, unit engineers}, shift supervisors, and operators) 1D Unit or central maintenance {including the maintenance manager, maintenance engineer{s), planner(s], supervisors, and technicians mechanics, pipeftiers, welders, painters, oilers, electricians, ‘and instrument technicians) 2 Inspection and testing (including inspectors for fixed and rotating equipment) 2 Procurement (inctuding purchasing agents) 1D Receiving (including the storeroom ‘manager, supervisors], and clerks) [2 Construction (including project ‘managers, construction engineers, supervisors, QC representatives, and workers) iyCree Designing an MI Program Problem Statement (cont'd) Issue Issue Issue Comments 6 (cont'd) [Organizations involved [O Project engineering (including the with Ml activities manager, engineeris], and ‘onginoering assistants) ID Safely (including the manager and safely specialists) Kd QA/QC organization IC Maintenance contractors IC Construction contractors IC inspection and test contractors IC Equipment and material vendors IG Plant management 2 Other: 7 [Resource allocation (in [Operation and maintenance funds relation tocurent © |Q Less. Same allocation for existing | More Substantially moro activities) |Capital improvement funds IQ less Same JO More Substantially more |Operating and maintenance staff IQLess ~ O Same | More Substantially more Construction and project staff tess Same | More Substantially more MI and PSM management staff Less Same J] More G Substantialy more Inspection and testing equipment Less © Samo J] More O Substantialy more Inspection and test contractors Loss =O Same I] More Substantial more lWarehouse capacity tess © Same J] More Substantial moreprsran Nie aera ocroe ee! Problem Statement (cont'd) Issue Issue Issue ‘Comments 8 _|Level of documentation [Policy and responsibilities for Mi features IQNone = Minimal I Moderate Extensive Guidelines and procedures [None Minimal J Moderate Extensive ‘Task completioniresults IQNone = Minimal IO Moderate O Extensive 3” [Procedure philosophy Purpose 1D Routine field usage 1D Reference 2 Training IA. Rogulatory compliance and industry! ‘company standards 12 Basis for field checklists Intended User 12 Person off the stract 2 Person with basic technical inclination (no technical raining) 12 Person with some technical training (vocational schoo!) 2 Person completing general company training 12 Person completing skill-speciic ‘company training IO Experienced plant personnel 10 [Training curriculum for [2 Basic technical and craft sklla/ maintenance personnel] certifications 2 Sate work practices and policies 2 Procedures 2 Mi roles and responsibilities JO Emergency response 2 General safety training PSM awareness (with specific responsibilities) Eeeees DES iu ewe gee sc) Problem Statement (cont'd) Issue Issue Issue ‘Comments 11 [Approval of continued [2 Operatorsimaintenance technicians loperation of deficient lequipment |Q Process/maintenance supervisors, |G Process/maintenance/inspection enginsars IO Process/maintenance manager |Q Engineering manager 2 Plant manager 1G Teams (specify): 12 |intogration with other | Work order system ectvties IC Work scheduling system IQ Financial approval system Stating plans 1G Purchasing procedures, [2 Contracting procedures 2 Document control 1 Process safety information {equipment files) IO Process hazard analysis (critical failure modes, recommended inspectionsitests, procedure modifications/additons, training modificaions/eddiions, etc) 2 Procedure and safe work practice programs (format, overlap of activities with operations, document control, ote) 2 Training programs (format, types of evaluations, scheduling, training overtep, records, etc) 1G Contractor management (selection, ‘monitoring, QA, etc) 1 Pre-startup safety reviews (QA, incorporation of inspectionftest requirements, etc) es EDesigning an MI Program Problem Statement (cont'd) Issue Issue Issue ‘Comments 72 (contd) [integration with other |G Management of change (resolving activities equipment deficiencies, QA, incorporation of inspectionitest requirements) IG Incident investigation (resolving equipment deficiencies, QA problems, ete.) |G Emergency response (training) (O Audits (Ml performance and compliancelconformance) IC Employee participation (employee input) canesMechanical Integrity: Tab 3 Developing an MI Program Process Safety Institute Course 111Te ees Te eget atv Developing an MI Program ‘When developing an MI program to meet your design specification, itis important to recognize how different features of your Ml program should ‘work together. [tis also important to address regulatory expectations. In this section of the course, we will cover strategies for developing a comprehen: sive, compliant MI program. AA successful MI program addresses three focus areas: + Equipment + Management systems + Personnel A Successful MI Program ig» & sy Personnel weCrista 8 A program effort that ignores any of the focus areas can lead to MI failures. Our equipment program should include: 1) an equipment list and 2) an inspection, test, and preventive maintenance (TPM) plan While all aspects of your MI program will probably have an assoctated ‘management system, the key management system discussed! in this course will be the quality assurance (QA) program. When QA is applied to all phases of equipment life, it becomes the comerstone of an effective Ml program. The section of this course that focuses on management systems also addresses the equipment deficiency resolution program as part of the QA program. ‘The section of this course that focuses on personnel will address activities needed to support the equipment and management system aspects of the Ml program. The personnel issues that need to be consicered in the MI program. are: + Inherent skills (Je., the skils personnel have when they are hired) + Supervision + Procedures + Training. Before addressing the individual focus areas, consider the overall program. ‘When the program is developed, a governing document can be beneficial. A generic example of such a written program document is included in the Resource Material section of this course A written program description allows you fo define the approach used for addressing each program aspect and identifies the roles and respor of company personnel. This document can be a road map for communicating the program to affected personnel, as well as to auditors. Ee(Core ees “J Equipment: Identifying Covered Equipment ‘The application paragraphs in the regulations suggest a starting point for your equipment lst 29 CER 1910.119()(1) and 40 CFR 68.73(a) Application (i) Pressure vessels and storage tanks (ii) Piping systems (inctucing piping components such as valves) (ii) Relief and vent systems and devices (iv) Emergency shutdown systems (¥) Controls (including monitoring devices and sensors, alarms, and interlocks) (v) Pumps However, this list is misleading and probably causes trouble more than it helps. You are expected to include all “critical” equipment, whether of not it fits into one of OSHA/EPA's six categories. PSM regulation — Appendix C Implementing an effective MI program should include: + Compiling a list of process equipment and instrumentation to be included in the program + Prioritizing the process equipment and instrumentation based on which items require closer scrutiny (or are more critical) than others + Expanding the lst of process-related equipment and instruments specified VE Creer EaDAG se sean ea in the PSM standard to include important mitigation systems or components (fire protection system components, dikes, drainage systems, etc.) One company's approach ‘The eight-step program below was developed by a company after OSHA performed a full-scale Program Quality Verification (PQV) inspection of one of its fa ies. This document has been successfully defended as a criterion for including/excluding equipment in an MI program at other plants of the same ‘company, “8 Step Program” ently highly hazardous chemicals (HHCs) present in the process(es) ~ Processes that contain HHCs are included in PSM ~ Per OSHA list and definitions (Appendix A and paragraph (a) applications) Application of PSM by pracess area (plot plan) ~ Establish typical physical boundaries within each plant or unit that plant personnel typically use to define or describe the work area = Of those areas or sub-divisions, Identify areas that are known “hazardous areas” Safeguard equipment are covered, including = Firewater systems, gas monitors, flares, etc. = Compressors/fans for pressurized control rooms, breathing air systems Review processes outside PSM areas that may affect a covered area = Utilities, non-HHC raw materials, waste treatment, etc. = Identify effects of functional and mechanical failures = Include processes that have potential for catastrophic consequences ~ Exclude systems/equipment that have no effect on the HHC process ~ Exclude systems/equipment for which catastrophic consequences of failures are mitigated by highly reliable redundant design and are proven to not cause an emergency state OSHA says: “System failures that result in enactment of emergency procedures in HHC processes and these enacted emergency procedures result in going to the last line of defense, is a test for inclusion, so those and associated systems are to be included.” Review processes within a PSM process area for possible exclusion ~ Include all components that contain the HHC (piping, vessels, etc) ~ Include equipment supporting the HAC process that would adversely affect the process in the ‘event of a functional or mechanical failure ~ Exclude systems/equipment that have no effect on the HHC process ~ Exclude systemsfequipment for which catastrophic consequences of failures are mitigated by highly reliable redundant design ~ Exclude systems of the HHC process that, upon failure, are mitigated by highly reliable redundant design, and are not the last lines of defense 5.4 Controls: Define controls to include instrument loops that provide information or control of process variables that have “safe operating limits.” (Cross-reference with operating procedures) wie Pry uetPEG wn eae sc) = Include loops that, upon fallure, result in loss of process control or provide information that could result in improper process control ~ Establish rationale by which process control loops will be included or exclucled 6. Review plant for non-HHC processes or equipment that upon failure, may by themselves lead to catastrophic event ~ Exclude processes/equipment that have no impact ~ Include equipment if failures were subject of a prior incident investigation for an incident that led to catastrophic events ~ Include equipment based on employees’ input: perceptions, experience 7. Document this analysis: develop PSM list ofthe plant's covered equipment and processes ‘Analysis Report” — body of information defining the scope, purpose, and results Method for documenting equipment subject to Mechanical Integrity provisions Marked-up PIDs ~ Equipment lists Final step! 8. Once a system or equipment item is included, the next step is to prepare the appropriate PSM Mechanical Integrity program that is necessary to mitigate the identified failures = Programs can vary based on risk, probability, and existing historical data; but above all, base programs on sound engineering judgment — and document! G Process SafetyDAG G aa eukeeat Creare! — CERI Equipment: Inspection, Test, and Preventive Maintenance 29 CFR 1910.119(j)(4) and 40 CFR 68.73(d) Perform Inspections and Tests (0 Inspections and tests shall be performed on process equipment 29 CFR 1910.119())(4) and 40 CFR 68.73(d) Follow Accepted Practices (li) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices Appendix C — Proper Procedures and Types of Inspections Proper inspection and testing procedures for instrumentation and equipment can be developed from methodologies in consensus codes and standards (NBIC, ASTM, API, NFPA, ANSI, ASME, etc.) While many different types of inspections and tests exist, Appendix C specifically mentions: * External inspections (e.g, surfaces of vessels and piping) ‘+ Internal inspections (e.g., vessel and piping thickness) *+ Critical inspection objectives (€.g.. corrosion, erosion, cracking, bulges or blisters, thickness) 29 CER 1910.119()(4) and 40 CFR 68.73(d) Frequency of Inspections and Tests (iti) Frequency of inspections and tests of process equipment shall be consistent with = manufacturers’ recommendations Ly Bere Neosreat = good engineering practices ~ operating experience, which may dictate that frequencies be increased! Appendix C — Frequencies of Inspections and Tests Frequencies for inspections and tests can be established in several ways: + Consensus codes and standards (NBIC, ASTM, API, NEPA, ANSI, ASME, etc.) + Manufacturers’ recommendations or data for mean time to failure of instruments or equipment parts + Actual operating or experience data collected by the employer + Inspection frequency formulas based on observed or derived corrosion rates for materials of construction Preamble — Frequencies of Inspections and Tests OSHA intended to provide a performance-oriented requirement that allows flexibility in choosing the frequency of inspections and tests performed to ensure equipment integ Semaneu Coes Creating an ITPM Plan Creating an ITPM Plan Inspections and tests (including frequencies) A compilation of inspections and tests found in industry guidance documents. is included in the Resource Material section of this course. It provides reference to the applicable code, standard, or other document, and indicates ‘a recommended frequency if the document specifies one. Note: This compilation should NOT be considered complete; it is provided as an ‘example of how existing codes and standards information might be provided to personnel developing specific inspection and testing plans. Please note that the CCPS references provide examples of what specific companies implement, not necessarily guidelines for the chemical industry in general Features of an ITPM plan + Represents all equipment in the MI program + Specifies frequencies + References applicable procedures + Documents bases Steps to creating the plan *+ Gather ITPM specs, standards, recommendations, etc., after consulting: = publications from authoritative organizations (e.g., NFPA, NBIC, AP) = manufacturers’ recommendations, anid = company specs. + Organize your equipment list into equipment classes. 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Cmecettear ere | ouses peomimoacreeiny |” COS oie tare | enn ae Soaecma ses | Mammon me Sanna a.” | sauce cans Tomo en + Stn otra coo a ee er Mindsdt nected |" poaanntettigmans|" teompnattace tie |” Seamimantar Tee ame ae fauesetmncanauy’ | cautyeestunrean | cosctinesatuberse proctns maicte’s | Teeabecnistrte | tarecnitenin, | iments crs oe E ae | ac Scuelnesec shew | Gumeteyles een Seogems ramen es 3-11ease Coie eet Documentation! 29 CFR 1910.119()(4) and 40 CFR 68.73(d) Document Inspection and Testing (iv) Document each inspection and test performed on process equipment and identify: = date of the inspection or test name of the person who performed the inspection or test serial number or other identifier of the equipment tested or inspected description of the inspection or test performed = results of the inspection or test Preamble — Document Inspection and Testing + Documenting inspection and testing does not require third-party verification, nor does it preclude electronic storage of the information, + Because of the flexibility allowed in choosing the inspections and tests, employers are required to describe the inspection or test performed and record the results LR reer cnaCoreen Management Systems: Quality Assurance An MI program motivated solely by “paper compliance” with the PSM regulation may be lucky and get by without much QA effort. Examining OSHA citations reveals that few citations regarding QA or deficiency resolution are written unless there is obvious neglect or a serious accident. However, when we look at the whole QA picture, we see the management system that isthe foundation of the MI program. Quality assurance is best examined over the life of your equipment. Understanding management system strengths and weaknesses allows your program developers to address critical areas. The following represent many different approaches to QA at different equipment life cycle phases. No plant is doing all of these things, but some of these ideas may help you: Design: Design is usually the only opportunity you have to “add” quality to your equipment. The remainder of QA generally is aimed at preserving ‘quality. Some QA tools for equipment design include: + Company specifications + Codes and standards + Engineering and safety reviews (e.g., PHAs) Purchasing: Are there multiple departments that purchase parts and. equipment? Are the rules the same or comparable? Key issues to consider include: + Adherence to specifications + Change guidelines + Approved vendor tists es ec paectCourse DS a sua A sample veridor QA/quality control (QC) plan is in Appendix J of the genetic program in the Resource Material Fabrication: QA of fabrication may be closely related to purchasing QA. QA tools include: * Adherence to specs + Shop approvals + Shop inspections + Positive material identification (PMI) Receiving: Again, at some plants. multiple departments may be involved. Do all parts and equipment go through your storeroom? Do contractors bring in their own materials? QA tools include: + Adherence to specs = PMI + Receipt inspections + Packing list verification (vs. purchase orclers) Storage: Is the storeroom centralized? Are there informal storage areas (eg., at the process units)? QA tools include: * Labeling * Binning + Special storage requirements (e.g, turning motors, upright PSV placement, humidity and static electricity controlled areas) + Segregated storage areas (e.g. for exotic metals) + Inventory control measures (e.g, fist-in, first-out, cycle count) Retrieval (issue from storage): Few storerooms are manned around the lock. If your storeroom is manned 40 hours a week, what controls are in place the other 75% of the time? + PMI + Work orders linked to equipment specs and issuing * Locked storerooms, with very few keys Installation/startup: A critical phase for QA. Weaknesses in the previous phases can be compensated for prior to startup, as long as they are Understood and the proper controls are in place. QA tools include: EeDEG aa Unease eee + Approved contractor lists + Contractor safety and quality audits + Installation specs + Instrument/interiock te + PSSRs + Water runs + Hydrotesting A sample contractor QA/QC plan Is in Appendix K of the generic MI program in the Resource Material Operation/maintenance: QA for operations is the focus of other PSM elements (e.g., operating procedures, training, MOC, incident investigation process safety information). Equipment deficiency resolution is part of the QA of this phase that will be handled separately, Maintenance/tepair QA (€.g.. procedures. training) will be addressed in our personnel section Decommission/reuse: QA for decommissioning is not an MI concern unless reuse is intended. Does your plant have a boneyard? Most do. Are there controls on purchasing used equipment? QA tools include: ‘+ Decommissioning protocol * Recommissioning protocol ‘+ Change-of service approval processes(nent Eu td Management Systems: Deficiency Resolution Deficiency resolution i a specifi part of QA: one way quality of operations 4s ensured is by managing/removing deficient equipment from service. Deficient equipment may include the following: + Thicknesses below minimum + Any other equipment outside of inspection tolerance * Instrumentation that is bypassed (if there are safety impl + Safety equipment that is out of service + Temporary repairs such as: - patches ~ encapsulated leaks ~ sleeves = clamps = leaks stopped by injection of materials How are deficiencies identified? + Operation problems + Inspection/test findings Frequently, plants use at least two systems for resolving deficiencies, depending on the deficiency type. However, for all types of deficiencies, there are similar management responsibilities: + Reporting/communication at al stages of the resolution process to all affected personnel (e.g., operations, maintenance, contractors) Eat)Deo ee ea rartay roe oe + Safe management while operating with the deficiency + Tracking to resolution + Documentation Equipment deficiency reporting/communication + Imminent hazard communication ‘+ Shutdown/repair authority ‘+ Notifying affected personnel of the deficiency and keeping them informed (Gtatus updates) Safe management: equipment deficiency resolution + Immediate fix + Temporary operations, including: = temporary operating limits = temporary repair inspection provisions = temporary repair time limit = authorization requirements = contingency plan + MOC program ‘Tracking to resolutio: + Assign follow-up responsibilty + Update at least periodically + Take advantage of other PSM tracking systems (PHA, audit, incident investigation, etc.) Documentation * Leave a path for auditors (internal and external) + Tracking (Are there repeated/related problems occurring?) + Root cause analysis (tracking/resolving root causes is an idea worth considering)Course 111 Eee Equipment Deficiency Cycle Equipment Deficiency Cycle Equipment deficiency plan A sample deficiency resolution is included in the generic MI program in the Resource Material section of this course. The plan includes deficiency identification, communication, and authorization requirements, instructions for informing affected personnel, and documentation requirements. EenPersonnel: Procedures and Training As previously mentioned. the personnel issues that need to be considered in the MI program are (1) the inherent skills of your personnel, (2) supervision (3) training, and (4) procedures. We will focus on training and procedures, but will keep the others in mind when considering content and level of detail Types of Personnel Skill/Knowledge Requirements atkDra eae sacra Consider the knowledge and skills needed to safely and efficiently perform maintenance activites. Together your procedures and training program should address them all. Items toward the top of the pyramid are most often included in training programs (ancVor expected as an inherent skill [i.e., a job qualification]). Items at the bottom of the pyramid tend to be addressed by procedures. Building your personnel program * Use your ITPM plan + Use your QA plan * Brainstorm with experienced personnel from each craft to develop a list of skills knowledge required Considering the inherent knowledge you expect a new mechanicitechnician to have, and accounting for tasks that will be done only with expert supervision, identify a combined procedure/training approach to achieve the needled skillnowledge level. Also, recognize that some tasks may be done solely by speciality contractors. More information on setting up a training program is contained in the paper “Federal Regulations Prompt Mechanical Integrity Training” which is included in the Resource Material section of this course. Using manufacturers’ manuals '* Ensure content + Ensure availability + Ensure employees will use them “Upgrading” your existing workforce + Employee self-analysis * Peer analysis * Supervisor analysis Avoid the temptation to weed out personnel or to declare someone unlit to do. tasks he's been doing for years (exception: upgrading to a code welding or Inspection program). Your existing workforce can help validate the training program you create for new personnel Certification + No mention of “certification” in paragraph () * Certification for some crafts (e.g., welders, inspectors) + Some companies are “grandfathering” maintenance employees BE Eee crpneeste(ore e es ‘Training program features + Base -vel requirements for each position * Training frequencies, if appropriate (ie... topics requiring refresher training) + Trainer qualifications * Skill verification requirements + Provisions for personnel who don't pass + Tracking for each individual ‘Training resources/methods + Schools = technical schools ~ correspondence prog = community colleges * Purchased skills packages * In-house classroom/shop programs * Vendors/contractors * Apprenticeship eomueecs EreDeveloping an MI Program Crees Contract Maintenance Contract Maintenance Procedures * Provided to or supplied by contractor + Procedute details to match contract employee skill base ‘Training + Types of training required = overview of the process ~ hazards of the process = craft skills training ~ written MI procedures ~ other regulatory training (lockout/tagout, et.) Issues + Who will sponsor/conduct the training? + Who will monitor that each contract employee is properly trained? + What documentation is required? + Integrating MI contractor quality concerns into select of the contractor safety program nvauditing aspects bea)Workshop 3-1 Developing an Inspection, Test, and Preventive Maintenance Plan(noes DIG wae un ae Problem Statement Purpose ‘The purpose of this workshop is to experience the process of developing an inspection, test, and preventive maintenance plan for a process. Though the system that is the subject of this workshop may ‘not be similar to the systems that your company operates, you should gain significant insights about practical methods of developing plans for your applications. For this workshop, focus on the process of developing the plan, not necessarily the resulting plan Instructions Use the inspection and test guidelines provided in your notebook, as well as your own experience, to develop an inspection, test, and preventive maintenance plan for the LPG system described and shown on the following pages + Begin by classifying the types of equipment and their services using the attached forms. *+ For each class/service of equipment, list the specific equipment items belonging to that group. * Identify the appropriate inspection, test, and preventive maintenance activities for each class/service of equipment, and specify the nominal frequency for each activity. Supplement available information with your own experience/opinions as necessary to complete the exercise. Recognize that more comprehensive investigation of applicable codes, standards, regulations, industry practices, and ‘manufacturers’ recommendations may be necessary for your company’s applications. *+ Document the basis for your selection of required activities and frequencies. + Establish the format for a scheduling/tracking system that would allow your company to track the interiance tasks for each equipment item, status of required inspection, test, and preventive mPE sae ar ae) ree Problem Statement (cont'd) A consumer products company uses the system shown in the figure (see next page) 1o unload, store, and transfer butane, (The company uses the butane as a propellant in spray cans of their products.) Butane trucks arrive at the plant and park at the butane unloading station. A plant operator connects liquid and vapor hoses to the truck. Next, the operator opens the isolation valves in the liquid unloading line and the vapor recycle line (SV-1 and SV-2, respectively) for the storage tank (V-1). Then, the operator starts the unloading compressor (C-1), which uses vapor from the storage tank to force the liquid in the truck through the unloading line into the storage tank. Once the truck is emply, the operator (1) closes the ‘solation valve in the liquid line, (2) stops the compressor, (3) closes the isolation valve in the vapor line. and (A) removes the hoses from the truck. (A small amount of butane vapor is released when the operator disconnects the hoses.) If the level in the storage tank reaches the setpoint of the tank’s high level switch, the switch will close the isolation valve in the liquid unloading line, stop the unloading, compressor (LS-1), and trigger an alarm (LAH-1) The butane remains in the storage tank at ambient temperature untila pump (P-1) transfers the butane (0 one or more of the eight spray can filing stations. ‘The storage tank has a spew-type level indicator, a pressure indicator, and a temperature indictor. The tank also has two pressure relief valves that combine to provide the required relief capacity for the vessel When operators activate one or more of the filing stations, the filing station controller starts the butane transfer pump and opens the isolation valve(s) (XV-3/4/5/6/7/8/9/10) between the pump and the filing station(s). When filing operations are complete (or if there is an emergency shutdown signal in the filling station area), the controller closes the associated isolation valve ard shuts off the butane pump {if no other filing stations are in use). ‘The equipment in the system has the following characteristics: + The unloading hoses are rated for butane, tested at 300 psig, and certified by the manufacturer + Allof the butane system piping is Schedule 40 carbon steel with ANSI 150b gasketed flanges + The storage tank is fabricated of carbon steel, supported on concrete saddles (with corrosion-reducing material between the concrete and the tank), and electrically grounded + The compressor is centrifugal with an electric motor driver + The transfer pump is a centrifugal pump with a single mechanical seal + The isolation valves are pneumatically operated twin-seal valves suitable for butane service + The manual valves are gate valves suitable for butane service + The unloading area has a Class 1, Division 1 electrical classification, and all other areas associated with this system have a Class 1, Division 2 electrical classification + The unloading area has sloped drainage to a spill containment area This process area has four fire hydrants (each with a fire hose), four fire extingui LEL detectors (with alarms) located at various locations. hers, and four area| J 2 3S a Toe Problem Statement (cont'd) punning psconbng-9 aor es assays AS 0) oun 9¢ voneng Bons 01, CORA ess pam) upc S500 - 3 ators (NN ears pe $1 Loreapey ames, ‘exo e105 FNP A Lee 1-HVI veyenpuamesay)- jy aya.uengiosi porsde Ken aurg-d en pu -AD syeruonepsr pesto ‘o¢ wners Bom o1 se omnes 6 Dy faba a 9 DY cc onnens Bm 4 24 vonerg Bom 0, ue sbs0ag oueang a voneng fume 0,ines teneMe mmidOstCreme DAG uu ue ecard Problem Statement (cont'd) Basis Frequency Associated Ml Activities € 5 3 3 — 2 A a(Cree es Problem Statement (cont’d) Basis Frequency Associated Ml Activities Equipment Classification Eg Eee cme(oe Guidance from Recognized and Generally Accepted Good Engineering Practices for Equipment Inspection and Testing (Including Frequencies) Equipment Type Design Cod ‘standard Comments All process equipment |~regardless of design code or standard None Monitoring of process equipment by operations lpersonnetis a vali part of mechanical integrity (assuming the plant operating procedures coquire loperators to perform rounds and tnat the subject Jenipment isin an area where can be abserved). Ao functional ests performed by operators (e.g. ensuring nat discharge check valve closes when a pump i shit down for routine maintenance) are also pertinent to mechanical iteoriy [SOPs should speciy what Jmontering and tunctonal ing of process equipment te operating stat performs Bollers lASME BaPY Cove! Section I= Power Boles | NBIC (ANSUNG-23}°, Chapter I Extra inspection (1-200) 'temat inspection (1-300) Inspection frequencies are not specified: they ace specited as proved fon uredicbona regulators» atthe time of installation and at regular pariods threaten” Many states spect blir Inspection protocol ana requency Boers (and fred heaters). |ASME BAPV Code, Secon |- Power Bolers ASME B&PY Code, Section IV — Heating Boles api Re 573? Visual inspection of heater cols, Section 5.1 Visual inspection of red bolle, Section 5.2 Determination of wal thickness, Section 5:3 Cther miscstaneous inspection (e magnate, utrasoni, raographic, hare ‘Section 5.4 Inspection of foundations, satings, and other sppurtenances, Secton 7 Inspection o stacks, Section 8 Frequencies forthe recommended nepections are not specifes. Semiannual inspection of stacks is provided Jas an example, Inspection frequencies are dscussed qualtavely in [Section 2.4 Often, baler inspection requencies are mandated by sat or cal awe Chaitalls,Raas, and sings |SCPS, Append a8" inspect every 6 months per pertinent standards Compressors Typical esting performed: + Overspeed tip testing ater maintenance and during ‘major shutdowns |. Periodic or contnuous vation mentoring Adonai nspecton and esting general fcllows the manufacturers recommendations for equipment tems Phe compressors [cranes — monorails land overhead cranes JDeserators (mn steam systems) ASME B8PY Code, [Section vill — Pressure Vessels NACE Standard SPO580-2007" [Because of cracking experienced inthis service, internal visual inspection and wet fuorescent magnetic partie {esting ae recommended. Other methods, such a8 radiographic or ultrasonic testing may be required i problems are found. Tho teat interval for vessels that have experienced cracking previously should not exceed} 3 years.uae Course 100 Guidance from Recognized and Generally Accepted Good Engineering Practices for Equipment Inspection and Testing (Including Frequencies) (cont.) Protection in Refineries | UL Standards Equipment Type Comments ‘GOPS; Appendix 68 cial dlstbution Arr eee ‘Inspect based on history or company poiy. items Fire protecton NEPA codes (various) | Typical sources offre protecton equipment inspection | many dterent exuipment ‘AP12001 - Fie intervals approaches Protection in Refineries | Insurance company requirements se uted for inspection ULStandords + Specific code requirements and testing offre ‘Company poties protection equipment ‘he requencies shown Example frequencies here are typical of those + Dally— mobile re equipment found inmany company + Wioehiy — process operator inapecton of programs. They are ‘exingushere included here to ensure + Nerthy — Safety Ofleeinepecton of fre that personnel eaize tht cxtingushers fre protection assets + Annually — lw testing of rowater headers mmustbe included in and pumps the mechanical Integrity program as safely aystome, Fire protecton [NEPA codes (various) | NFPA putileation Fire Protection Systoms — ceauipment ‘API 2001 = Fre Inspection, Test, and Maintonance Manvar Many inspecions and test ae specited in te publication, ining +" Deluge system teting at intenats nt to exceed year ‘+ Rute testing ofthe fre alarm system at Intervals not 0 exceed 4 month + Biterflow teats (onere applicable) atintavals not to exceed t month: + Fite extinguisher inspectons at intervals not to exceed merih. + Detaled annual extinguisher maintenance atinlewals nolo exened 1 year, + Weeki inspections of fam-water spinker systems to;nsure that valves are open and sprinklers are not ‘damaged. Flow tests through system drains, land water flow alarm tests at intervals not to {he tan drai)atintervals not to exces ‘Tests of fam concentrate quality and foam concentrate nection systems ater to FE es cama + Week intpections (dung heating season) 9 rau that frewat: pumprouse heting 2 operators + Weenly tests of trewater pumps, suction and Sischatgs pressure gauges. pump diver taps and slams, Dataled pump performance eat at ileal exceed f year: bsars pee, Sueton, and discharge pressures at each how Felt vive setings;epeate water ow and alse Stones and contin valve postions, ABS Consulting Traieee WON Maree ec Cs) Design Code or Industry Guidance on Specific Equipment Type Standard Inspections and intervals Commonts Fie protection NEPA codes (various) |+ Daily inspections (during heating season to check ‘equipment ‘API2001 Fira water tank condition, temperature, and eperation| Protection in Refineries | of te heating system. UL Standards ‘+ Weekly checks of water level and valve posiors. + Detaled frewatr system inspection at intervals not to exceed 1 year. verity accessibilly ofhose connections and condi of hose threads, conduct ‘extemal inspection of fowater storage tank, and ‘conduct system flow test, ‘+ Atintervals not to exceed 8 years, conduct Tove — Tenor, OPS, Appenaiz oH nie hemos! noses Inspection every & mont per partner standards ieescang? — ea fectoze — |'94840000 80 | 4990118 apadomarcaaaed saa fx he design, Tequredtoprovere | S880 Imanagemst and martonance of eal ebuered personnel hazard, — ‘systems (SISs) (¢.g.. interlocks, emergency Paoreaspnent” | eceisit etdonna) it deinas pertomence itera or he sarc nae srobabity of alure on demand (6F5) of Sse produeton bes ‘hese enforasfect he ceign (level of Eitan redundane) and maintenance and testing Se frequency, However Se401 does not provide mpc proscipive testing Requencies for naruent Tt pecnepredu ay nes conain's granciatnesesuse Tor S186 In peraton bore Ap 196, a Insiumetaton — “is andar) arses the coneraorsin te process analyzers {phertn el anaes nd stools ayn ‘alton and mantonance ne sage ses process ‘montrhat messes runt reason beuk ‘hema canpsson, ya properties, ocr ‘Mopars Proce ayes ate Now wd ey nt ‘ign oo moran ad caren OS {uly ()oaertng advanced con sategen trorovng proces pears) exancig res sae tnd @) ietnous ems shorng ard enomerial ewe of and wee ual. Phing ANSI/ ASME 91.3" | API 570, Section 4" With the exception ofa “Thickness measurement and visual extemal inspections | few chemical-specic. based on classes of piping (classes are defined in APL | standards, theres no 570). Inspection intervals fr each cass are chemical industry Sanda forinspecion of Ti chess Extomal process piping w easurement Visual Refineries, chemical Class 1 (righ hazard) Syears——Syeare Plants, and other procass Plants efor to API 570 Gloss 2 foyears —Syears na APL S74 hon Case 3 fovea: 10years | Stening tee and Iecion Pots years By Gass | sectan cae and Soetotrintraces By Cass | iaeral ‘This standard also suggests locations for ‘establishing speci thickness measurement location. APLRP 674, Section 6.1" Various types of nepecions (0. eval, thickness ‘measurement, other), withthe frequency based on + Severity of service + Degroe of risk {Corrosion alowance remaining {Historical data + Regulatory requirementsGuidance from Recognized and Generally Accepted Good Engineering Practices for Equipment Inspection and Testing (Including Frequencies) (cont.) Equipment Type, Design Code of Standard Industry Guidance on Specie Tnspections and intervals Comments Piping — (here) ANSI ASME B31.3 Chlorine Instituto Pamphlet 60" Annusl comprehensive inspection ‘Semiannul visual inapection Bimonthly prevertve maintenance Theveis not a cherical Industry equivalent othe API standard. Many Piping — 1 eine tax hoses an “expansion loins COPS, Appendix a ‘Annual extemal inspection ues ewe tardars_ | Nosema sda ae etm tad waseneye® |eeaen Renetere | Rpea taco ine: ANSIAGME | Rt tea sat Sra zetmnsy, |" poiaccsmarhosa rt Aaue eis, | sear [aero i con eating ron a) os c2?5,pypeni08 pumps —crtiat | agus Standart panp ot moor inspection, wth equancy aatualeemecs ‘based on history or as specified in corporate standards: feeteadpmen— |acueasevcom | ansinazs ana arto" Petarcrtsvaies |Setunsme" | Mase, aesouetsb stapes sontine Frasca vrea | (siphons au ave konto Seo ana APIRP 5207 ‘mC Set 11d psa a eon treme acters tae ‘erat ton sotet eng tbe erat feaeconer ms fess apa Ore soins" SeaSbervosyps cts ars pest coat coPs ovo eit epee — cove tangled | AMER Vn | ah cee Sat hgh as (ioc sping loadea) Pressure Vessels the folowing frequencies: Water ane steam service —2 years Clean quid service —2 years guid service, where protected by rupture dik ‘With knife blade — 1 to 2 years Wanout knife blade — 30 6 years \When rupture dike serviced Hazardous quid service — 1 year or loss Clean, ery, and noncorasive gat service —2 years Moderately clean gas service —2 years Diy or corosive gas service — 1 year Block valve postion and seat leakage —mantly Role equipment — ASME BEPY Code, Senin Vi Pressure Vessels CPS, Appendix 3 Inspect sot pressure, seals, leakage, and blockage on the flowing frequencies Moderately dean gas service — 1 year Clean dry. and noncorosive gas service —2 years Hazardous chemic: Nonresidue/lean chemicals — 2 years Block valve postion and seat leakage —montlycoe eee Guidance from Recognized and Generally Accepted Good Engineering Practices for Equipment Inspection and Testing (Including Frequencies) (cont.) quid chorne serage ation coe or Industry Guance on Specie exuiomenttipe | "Sincere spuctons and nas comments eetecspmen— |asme oxy code, |wo-3, anenc A300 | eteresteryratet |ectnt— Power’ [low rarsre hetog tues — mony ett east | fee Es ence pt mrt presuretot way sue suey cos, |eower tons po 00 tan tt ate cal ence per mont press tot era |Heating Boilers e se w poner toler ver 400 pl — he tat faquenoyehoulé a Eedtmines ton acl pesig ty eatetenupmer— |asw aarv code, —|ctrne tute Parphat cere st Soston vin ornonetigernea (Secon vil Inspect safety valves annualy or biennial, Section 9.1. [Rete equiemert — cae valves in lammonia storage and handing services |ASME BAPV Code, Section vin — [Pressure Vessels JoGa G21) anst Ke1.1" Extemal inspection — 1 year Refurtish or replace — 8 years storage tanks |APt standard 620 — Design ana |Consiucton of Large Welded, Low-pressure Storage Tanks |aPt Standard 653% External — Inspect at 4 of remaining corosionate lie of shel or 8 year, whichevoris leas (Secton 4.32.1) Intamal— inspection interval established by owner bated on corosion rates, but nat to exceed 20 year. if 3 or similar serice experience are nat avadable, nat to exceed 10 years (Section 44.2}. [API Standard 850 ‘replaced API 120. |API Standard 659 External — inspect at 4 of remaining coosion~ate life or 5 yeare, whichever is less (NBIC-29 U-106 Section f and APL 10 Section 4.2), Internal — inspec at 1/2 of remaining corasion-rate fe or Oy ears, utichever isles. For 260 comosionata serie, provisions for forgoing ineral inapections are otailed (NBIC U-108 Sections b and e and APL S10. Section 42). ‘Special provisions apply to interitent sence (NBIC U- 108 Section). act standard 0 = sor aet ee tr ae Sat Fae ow'stese art tanta 9 abo Noguituneepctcto UL ta2tana wan found, opps uaifcatons tz st $2aine cofoen ie frt for fegunenei ark Rar as (pecs acon 10 _|snb pense) storage ts — ovr APR 2380 Ove |p zo, secton a7 prtedlon saan vel |PFOTTIN (OT | pee analy dpa aul gle tim Seane Takata, | sien, uong he manfoctae’s eng oom Naess — manvet ose ve re choxne institute Pamphlet 5 \retrigerated chlorine |ANS!891.3 Inspect every 2 years, Section 9.2. rae Nase vars — RSME SEP Code. Larne a Secon |exerat tam and tang (0.9 amma ete, as unset pases an at 10 Note and ae s10 requirements are very similar, ifnot identical |Also, NBIC specifically states (p. vii) that it overs "irsiaations ether than these coverea by API-810, unless the jurisdiction rules otherwise.” Frequency Information in NBIC-23 is in Chapter.ee Course 100 Partial Listing of Recognized and Generally Accepted Good Engineering Practices 1. ASME Boiler and Pressure Vessel Code, American Society of Mechanical Engineers, 2. National Board Inspection Code — A Manual for Boiler and Pressure Vessel Inspectors, ANSI/ NB-23, The National Board of Boiler and Pressure Vessel Inspectors. Inspection of Fired Boilers and Heaters, AP! RP 573, American Petroleum Institute. 4. Plant Guidelines for Technical Management of Chemical Process Safety, Appendix 8B, Example of Test and Inspection of Equipment and Procedures, Center for Chemical Process Safety, 1992. 5. Prevention, Detection, and Correction of Deaerator Cracking NACE Standard SP0590-2007, National Association of Corrosion Engineers. 6. Fire Protection Systems — Inspection, Test, and Maintenance Manual, National Fire Protection Association. Functional Safety: Safety Instrumented Systems for the Process Industry Sector, ISA-84,00.01, Instrument Society of America, 8. Manual on Installation of Refinery Instruments and Control Systems Recommended Practice for Process Analyzers, API RP 555, American Petroleum Institute. 9. Chemical Plant end Petroleum Refinery Piping, ANSV/ASME B31.3, American Society of Mechanical Engineers, 10. Inspection of Piping, Tubing, Valves, and Fittings, API RP 574, American Petroleum Institute 11. Inspection, Repair, Alteration, and Rerating of In-Service Piping Systems, API 570, American Petroleum Institute, Second Edition, 1998, 12. Chlorine Pipelines, Chlorine Institute Pamphlet 60, Chlorine Institute. 13. Specification for Horizontal End Suction Centrifugal Pumps for Chemical Process, ANSVASME B73.1, American Society of Mechanical Engineers. 14. Specification for Vertical In-Line Centrifugal Pumps for Chemical Process, ANSV/ASME B73.2, American Society of Mechanical Engineers. 15. Specification for Sealless Horizontal End Suction Metallic Centrifugal Pumps for Chemical Process, ANSI/ASME B73.3, American Society of Mechanical Engineers. 16. Petroleum, Petrochemical and Natural Gas Industries, API 610, American Petroleum Institute. 17. Sizing, Selection, and Installation of Pressure-Relieving Devices in Refineries, Part 1 — Sizing and Selection, API RP 520, American Petroleum Institute. 18. Pressure Vessel Inspection Code — In-Service Inspection, Rating, Repair, and Alteration, API 510, American Petroleum Institute. 19. Inspection of Pressure-Relieving Devices, API RP 576, American Petroleum Institute 20. Plant Guidelines for Technical Management of Chemical Process Safety, Appendix 8E, Example of Criteria for Test Inspection of Safety Relief Devices, Center for Chemical Process Safety, 1992. 21. 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In this section, we will address typical implementation and program ‘maintenance challenges ‘+ Managing and reacting to [TPM results + Using computers effectively + Maintaining a fling system In this section, we will also cliscuss upgrading your MI program to a reliability program, my(re soe Results from ITPM Activities Itis easy to be so consumed with developing your program that you don't have time to analyze your results. Before long you can be buried under a pile of inspection reports and unable to manage your MI program effectively ‘Among the problem areas you will encounter if you clon't have a system for reacting to your results are the following * Safety, environmental, reliability. Not reacting to inspection results can lead to the very accidents your Ml program is being designed to prevent + Employee participation. When relying on others to contribute to your program, the worst thing you can do is to not react to their work + Audits, These are easy pickings for internal and external auditors. In addition, if you are not reading your ITPM reports, no mechanism is in place to adjust ITPM frequencies (up or down). Evaluation of task frequency should be a priority. Managing ITPM results Once ITPM activities begin to be implemented, we need to be ready to handle the flood of inspection reports. One of the common difficulties in many plants is that inspection reports are not properly reviewed and ‘managed to ensue that (1) equipment deficiencies are identified and appropriately managed (e.g., corrected, communicated) and (2) ITPM schedules are updated based on the ITPM results. The best defense for this situation fs to define the process for managing the inspection reports, This process should include assignment of responsibility for (1) reviewing results, we Eeeene (2) updating ITPM schedules, and (8) initiating the equipment deficiency process for identified deficiencies. Issues beyond deficiency correction + Retiring equipment. Obviously, an important objective of the MI program is to repait/replace equipment before it fils. However, at what point before it fails should it be retired? + Adjusting ITPM frequencies. We rarely set frequencies “right” the first time. Establish a protocol for increasing/decreasing frequency. This protocol should include a process for determining when deviating from the tasks and frequencies in a code or standard is warranted. Once we have a documented history that indicates that the tasks or frequency in a code or standard are not applicable to the equipment in your plant, the [TPM activities should be altered to match the conditions and equipment damage mechanisms in your plant. However, itis important to document the process used and the supporting evidence used to determine when deviation for the code or standard is warranted. + Managing your backlog. In many plants, the work order backlog is 50 deep that itis an ineffective tool for managing ITPM activities and tracking, equipment deficiencies. One of the main reasons why the backlog is ineffective is that the built-in prioritization system is improperly used by plant personnel (e.g., most work orders are assigned emergency status) ‘To effectively manage the ITPM activities. we must develop and implement an effective prioritization system to ensure that ITPM and deficiency correction activities are completed as scheduled. Too busy to do this? Some practical advice: + Add staff, Well, may not be practical, + Prioritize ITPM activities. ‘Typically, plants identify more tasks than they can perform and/or are too optimistic when setting inital frequencies. ‘We will cover task pr ization inthe discussion on relibiliy caTOTEM RST Cro B1 Using Computers Effectively While it’s possible to manage an MI program without computer support. plants of any significant size will fast become overwhelmed without a computerized maintenance management system (CMMS). Unfortunately, there are as many bad things to say about CMMSs as there are good. Why is this so? One of the reasons is that many people have systems selected for them. Frequently, the selection of a CMMS is not the choice of the maintenance department, Sometimes maintenance is a module of an integrated software system and seems like an afterthought. Other times, the maintenance software is bought with purchasing or stores in mind ands still nota fully effective MI tool. Stil other problems are caused when your CMMS is selected by personnel at a corporate office or a sister plant. ‘The motivation for these personnel selecting your system is generally good. ‘There is value in having integrated systerns and consistency throughout your corporation. However, plant maintenance departments are happiest in the Tong run when they can be involved as early andl as deeply as possible in the initial set up, if not the selection, of the CMMS. CMMS expectations ACMMS designed for MI would manage the equipment list and the [TPM plan to schedule [TPM tasks, verify that personnel assigned to the tasks have appropriate and up-to-date training, and produce a smarter-than-usual work order, including pertinent steps/reminders from the applicable procedure and highlighting relevant work history. Maintenance planners would have a tool for verifying parts are available (as many CMMSs provide), but would also be able to select the procedure and history information to include on the work cayOnan! DD eure tn ‘order and personalize the work order, if necessary, for the craftsmen involved Crafismen would have a means to record pertinent equipment history information, and the system would process the information, flag data ouside of expected ranges, and calculate a recommencled date for repeating the task. In practice, there may be several different computer systems involved in these functions. In particular, processing inspection results is often handled by a separate system. This can and does work well at some facilites, but you need to ensure that personnel are accountable for managing and reacting to the inspection results. Other times, separate programs can be used to maintain current procedures and training databases. Again, this can work well, but to be most effective, the procedures and training records should be available to the personnel scheduling and performing the work.Cree e ee Filing Systems While the process safety information management system may include equipment design information, personnel managing an MI program also accumulate a lot of equipment information and should anticipate the challenge of organizing this data. Some companies put together file organization checklists. What information should be available in MI files? Covered equipment list. As discussed in Section 3, one of the initial activities for your Ml program is to identify the covered equipment to be included in the MI program, The result ofthis activity is usually documented as a covered equipment list. The list typically contains (1) the identification number (e.g. tag number) for each piece of equipment and (2) the equipment name (¢g,, HPU reactor). The covered equipment is usually documented by including it on a spreadsheet and fling it with other Ml- related documentation, or by including a designator in the CMMS equipment record (Le., including an identifier [e.g.. PSM, Ml] in one of the data fields in the equipment record) for each piece of covered equipment. As an alternative to the covered equipment lst, some plants highlight the covered equipment on a set of P&IDs. Pressure vessels and atmospheric storage tanks. OSHA provides us assarting point here. The OSHA Technical Manual (OTM) generally refers to matters of protocol and proper steps for conducting an OSHA inspection; however, in Chapter 10, Pressure Vessels, the OTM provides some technical information of interest to MI programs. A copy of this chapter is included in the Resource Material section of this course. You may find the overview of inspection practices and vessel failure information interesting. However, this OTM section is included in this course because of the appendix, Appendix 10-A, Recordkeeping Data for Steel 48 LeconteIG UCE LT Sencar Vessels and Low Pressure Storage Tanks. This provides you with an idea of information OSHA is expecting to find, and it is not a bad starting point for ‘your pressure vesselstorage tank checklists Piping. The main challenge for your piping files may not be what goes in the files, but eather what is on the file tab—counting pipes is not an abvious assignment. For small units you may be able to keep al piping records in one file folder, but this is unusual. For some plants it may make sense to file by the chemical contained (the chlorine piping, the alcohol piping, etc.) Frequently, plants have a system for generating line numbers, and this may be a good system to use. Some things to consider: + Circuit definition, Will each tine number be a circult? Will there be several line numbers to a circuit? Several circuits to a line number? + Auxiliary systems. Will co wal ipressor lube oil piping be its own circuit? just be kept with the compressor file? systems + OSBL systems P&IDs or some other documentation should reference your piping specs. ‘These specs should be available. Also, isometric drawings are used to track thickness measurement locations (TMLs) for the thickness inspection program. These drawings are important for ensuring that thickness measurements are taken at the same points from inspection to inspection. ‘Some plants are not able to determine meaningful corrosion rates for thei piping systems because the same points were not used in the inspections. Rotating equipment. Pumps, compressors, fans, etc., will need service history records. Also, current records of items such as impellar size and performance curves are useful. PSVs. Current size and sizing criteria are useful. For plants that remove PSVs while the plant is operating, we'd recommend having (for each PSV) a pre-approved contingency plan: the list of things to be done to safely remove a PSV on line (e.g... valves to be car-sealed open) and the supporting calculations. Instrumentation and miscellaneous electrical systems. Information should include instrument spec sheets, instrument setting sheets, loop sheets, and calibration information for instruments. One-line diagrams for electrical systems are also useful. Some plants that opt not to update loop sheets and electrical drawings find that technicians squirrel away their own sketches. Consider including this instrumentation and electrical data in your document control system. Also, consider including logic diagrams and configuration documentation of programmable devices (e.g. printouts of programmable logic controller configuration) for control loops and emergency shutdown, systemsfinterlocks. LW eercmennis Apop acaenttay Coren Reliability Reliability Although companies sometimes rely on different personnel groups for Ml and reliability, the goals of an MI program are usually consistent with good reliability concepts. In fact, a solid MI program is an excellent foundation for a reliability program. The Resource Material section of this course includes a paper describing how to transform your MI program into a reliability program. ‘The paper assumes you have an “OSHA compliant” MI program ‘and want to have a state-of-the-art reliability program. {t emphasizes prioritized task selection, root cause analysis, and a commitment to QA. 410 EeceeceeeisWorkshop 4-1 Where Do We Go from Here?Problem Statement Purpose Identify the steps to implement/refine the MI program at your facility/company and assign tasks to appropriate personnel Instructions Based on the status of the MI program(s) at your site/company and the material presented in this course, ‘you should be able to identify an appropriate plan of action. The worksheets offer an outline of such a plan. You may start at the beginning or anywhere in the middle. Alternatively, you may just select a section or two that are appropriate for you. Check off the tasks and subtasks that are appropriate and identify others to fit your own needs. For each checked item, complete the accompanying blanks (most of which are to identify a responsible party or team leader and a team), EsSe creer) Mi Program Design Establish Mi program scope (e.g., using Workshop 2-1) Team Leader Team Review existing Ml program scope (e.g., using Workshop 2-1) ‘Team Leader Team Seem ceceeee Implementing and Maintain MI Written Program Development CO Create written administrative program (2.g., customize generic program in Tab 7) Team Leader Team O Reviewlupdate writen administrative program Team Leader Team CrCrees Ci Createlupdate Mtl covered equipment lst Team Leader Team 1 Identify applicable codes, standards, and manufacturers’ recommendations ‘Team Leader Team C Create/update ITPM plan Team Leader Team 7 Integrate ITPM plan with CMMS Responsible party DB tdentity critical repairs ‘Team Leader Team es puesImplementing and Maintai 5 Quality Assurance Program Development and Implementation 1 Develop QA plan ‘Team Leader QA for design Responsible person (QA for procurement Responsible person QA for fabrication Responsible person QAforreceiving/storestissues Responsible person QA for instalation Responsible person QA for startup Responsible person {QA for equipment repair Responsible person QA for decommissioningire- ‘commissioning Responsible person Veer uUre eee eres (eee! Equipment Deficiency Program Development and Implementation Create list of types of deficiencies that the program will address Team Leader Team 1 Write equioment deficiency plan ‘Team Leader Team Establish system for managing ITPM results, Responsible person Establish system for managing deficiencies found during operations Responsible person 1 Pilot test equipment deficiency plan Responsible porson Affected process area(s) CO Reality check Are deficiencies recognized? Are affected personnel informed? ‘Are precautions being taken to manage the safety Of deficient equipment in operation? Is deficiency tracking up to date? Is deficiency resolution documented? Team Leader Ly Boreas poeticsree es F DOE uC RCT 3 MI Personnel Management Program CO Create list of skildknowledge requirements for each affected position ‘Training Team Leader TrainingTeam C1 Identify personnelidepartments to perform each task in ITPM and QA plans (task can be done as part of the creation of these plans) Responsible person 7 Identity lists of procedures, training, and contractor-assigned tasks based on the ITPM and QA plans, and the list of orical repairs. Integrate the skillknowledge requirements into the training plan. Team Leader Team 1D Dofine training program parameters (how to qui ate.) trainers, verify training is understood, document training, Responsible person(s) (if other than Training team) 1 develop procedures and training materials Team Leader Team @ Process Safety Institute C)Mtoe MI Personnel Management Program (cont'd) C eentity contractor procedureitraining requirements Training Team Leader TrainingTeam C1 Heentify GA and other administrative procedures to manage contractor activities Responsible person C1 Develop contractor-rolated procedures Team Leader Teamau pT ecu eB MI Program Assessment/Continuous Improvement C1 Create Mi assessment protocol/strategy Team Leader Team bec reatshasovougnlenMechanical Integrity: Tab 5 Assessing and Improving an MI Program Process Safety Institute Course 111Ne acti) peony [onan Le connor Wrovites Foor | Past | Pa Continual Improvement: Periodic Audits While this is not an auditing course, this section will briefly cover M-specitic auditing concerns and audit strategy. What can be audited in your MI program? * Coverage boundaries + Maintenance worker qualifications * Inspector quali ations + Ml procedures ‘+ Equipment deficiency logs ‘+ Equipment deficiency resolution ‘+ Inspection documentation + QA documentation + Contractor quality assurance ‘An MI audit can focus on these and other MI documents or can target specific MI concerns (e.g., Are workers able to locate and use MI procedures?). A sample MI audit checklist is included in the Resource Material section of this course. Assessment methods * Record reviews * Field observations * Personnel interviewsCert Course Wrap-up EXAMPLES OF WAYS TO IMPROVE EFFECTIVENESS, ‘This section provides specific examples of industry-tested methods for improving the effectiveness of work activities related to your mechanical integrity program. Develop «a corporate standart for ITPM tasks. ‘The {TPM plan should be based on standards, ‘manufacturers’ recommendations, and equipment history of the particular equipment in similar service at the facility (or sister facilities within the company/industry), However, reviewing all of this data and defining a rational set of requirements takes a significant amount of research. More consistent and efficient ITPM plans can be achieved by centralizing this Function within a company or business unit and developing a set of ITPM tasks that (I) are based on all of this information and (2) are specific to the range of service conditions at ‘operating facilities. This approach also facilitates sharing of best practices between facilities. Corporate standards typically address the following topics + Equipment identitication/riortization. + ITPM guidelines for each type of equipment © pressure vessels © storage tanks heat exchangers © piping systems 69 telieFand vent devices © rotating hardware (likely futher subdivided into pumps, compressors, agitators, te.) © instruments © control systems © interlocks and emergency shutdown systems © utility systoms (likely further divided by type of utility) © mitigation systems © emergeney response equipment Inspection and test requirements for each type of equipment. ‘Templates for procedures and checklists foreach type of test or inspection, Training and certification requirements for each category of ITPM tasks, (Quality assurance standards/inspection checklists foreach type of equipment. Sample deficiency management procedures ‘An aut protocol for specific ITPM tasks associated with the mechanical integrity clement. Provide a clear link from risk analysis efforts to the ITPM plan. Companies spend considerable effort identifying hazards and analyzing risks. One byproduct of these efforts is 8 list of safeguards that help prevent or mitigate the effects of accident scenarios that are analyzed. Depending on the technique, the consequences (or sometimes even the safeguards) have a risk ranking associated with them. This information can provide clear direction to a sroup charged with developing an ITPM plan, Formally integrate hazard identification with developing ITPM plans. Some companies use formal hazard identification/sereening tools to assign units to various “levels of rigot” within their process safety program. These tools often take the form of a matrix that lists inherent hazards of various materials on one axis (extremely toxie material which, ifreleased, presents 4 substantial danger to the public, extremely flammable material stored above iis normal boiling point, flammable liquid, ete.) and the quantity of material (in mass units) on the other axis, The intersecting cells provide additional guidance on what ITPM tasks should be assigned, Depending on risks, consider running certain equipment to failure. At some companies, the zenetal belief is that all equipment failures can and should be prevented. Although detecting and preventing equipment failures by spending more time and effort on activities associated wn & Se(ore oe! ‘with the mechanical imegrity element is normally feasible, many failures (or failure modes) «do not lead to an unacceptable outcome. When developing ITPM plans, consider: + The consequences associated with the failures/failure modes that the ITPM task will help prevent. + The expected failure rate + The likelihood thatthe ITPM task will help detect or prevent the failure. + The risk introduced by the ITPM task, for example, potential to damage the equipment, making an error when placing the equipment back in service, and so forth. + The total cost of the activity, including lost production time, costs to prepare the equipment for the ITPM task, impact on product quality'yield, and so forth, This, consideration is particularly pertinent for failure modes that’ result in equipment ‘damage or downtime but are unlikely to lead to an unacceptable safety consequence. Take advantage of training offered by local colleges. Many local colleges, particularly community colleges, are keen to develop job-specifie curricula, particularly if good ‘employment opportunities exist in the fel. Ask equipment suppliers to provide training. Equipment suppliers often provide short, hhands-on training modules (e.g. 1 hour to I day) on specific equipment. This taining ean be 1 particularly effective means to update the skills and knowledge of trained maintenance employees. Use inspectors from one facility to audit programs and practices at another facility Auditing the mechanical integrity element requires deep knowledge of standards. Audit teams lacking such knowledge often hire a third-party expert to review that part of the program. An alternative to this approach isto use certified and experienced inspectors from a sister facility. This also promotes cross-learing; both the audited facility and the facility that loaned the inspecior tothe audit team are likely to benelit from this approach, Implement a risk-based inspection program. n recent years, facilities have applied cisk- based analytical techniques in an effort to develop mote performance-based mechanical integrity programs, In fact, some inspection standards, such as American Petroleum Institute (API) 510 (Ref. 123) and API $70 (Ref. 12.4) now include provisions for determining inspection requirements based on risk, including: + APL-S80, Risk-Based Inspection, and API-S8L, Base Resource Document ~ Risk-based Inspection (Ref. 12.5). ‘+ ANSI/ISA-84.00.01-2004 Part 1 (IEC 6151-1 Mod), Functional Safety: Safety Instrumented Systems for the Process Industry Sector ~ Part 1: Framework, Definitions, System, Hardware and Software Requirements (Ref. 12.6). Many organizations find that using risk analysis techniques to determine [TPM tasks provides several benefits, including ‘+ Assurance that a structured, systematic, and technically defensible approach is being used to make decisions ‘+ Improved knowledge of the system operation and the causefeffect relationships that result from specific equipment failures ‘+ Confidence that resources are being focused on the most important failures by explicitly assessing the risk and then assigning ITPM resources to those areas in which they will be the most effective. Engage operators in the mechanical integrity element. Some facilities seem to ereet a wall between the maintenance and production departments. In reality, operators can often sense ‘when equipment is not operating properly. Instituting a sense of equipment ownership among ey(rie Bee Course Wrap-up production team members, and having operators frequently patrol areas looking for unusual conditions, will help detect abnormal conditions before they become equipment failures. Assign some testing and preventive maintenance tasks to operators. Certain tasks should be assigned to operators, particularly activities that do not require special tools or highly specialized taining. Implement systems for continuous condition monitoring. Advances in technology have made it technically feasible and cost effective to implement continuous condition monitoring for some types of equipment. Collecting real-time condition monitoring information and alarming an unacceptable condition or a high rate of change on the operator’s console can help identify and mitigate the effects of failures that were previously considered random events Consider ITPM tasks at the design stage. Designers and project engineers often overlock ‘maintenance and ITPM needs atthe design stage. Trend results, Review test data periodically to detect changes in equipment condition, Fally utilize equipment reliability analysis tools in CMMS sofoware, Many companies ppurchase and deploy very capable software systems to manage maintenance activities. The initial rotlout of these systems is normally very chaotic. ‘The focus during commissioning is fon maintaining continuity of operations. Tools that can help users analyze equipment reliability, repair history, and so forth are planned for “Phase ll," which is scheduled for sometime after the work order processing, preventive maintenance scheduling, inventory, time accounting, and other basic CMMS functions ate operating as intended, Too often, the Phase initiatives never oceut. Invest in software that can help monitor equipment condition by analyzing process data. Many facilities have implemented distributed control systems with data historian modules that provide the capability to capture large amounts of data ata very low cost. However, assigning engineers or others to periodically review the data simply to look for indications that the performance of process equipment has degraded can be very cost prohibitive. Software packages can monitor equipment on a virtually continuous basis and can be programmed to alert reliability or process engincers ofa significant change in performance. Use proven tools to analyze reliability and failure data. Many tools that were originally developed to support product quality initiatives can be used to analyze other types of data as well EXAMPLE METRICS + Display a simple chart showing which facilites or units have fully implemented specific programs or practices. Sometimes simply displaying this information, and reviewing it in management team meetings, will spur management interestsupport + Number of equipment items included in the mechanical integrity program. Aithough this number has very litle meaning in isolation, it could be used as a basis to compare ‘mechanical integrity programs, particularly ifthe company operates similar processes at multiple icilities + Number of ITPM work orders (per month or quarter) that apply to equipment that is no fonger present atthe faciligy. & higher than expected number may indicate a weak link between the mechanical integrity and management of change elements Se 6Corr EET Rea) + Number of inspectors/maintenance employees hotdi certification. decline in this metric may be a leading in than acceptable backlog for ITPM tasks. + Number (or percent) of overdue ITPM tasks. © high number (or rate) of overdue {TPM tasks may indicate resource constraints or that equipment is not being made available for scheduled maintenance, + Namber of emergencyhmplanned repair work orders per month. One of the primary objectives of the mechanical integrity element is to reduce unplanned/breakdown maintenance work. An increase in this metric may be a leading indicator of an overall slip in the effectiveness ofthe maintenance program atthe facility. + Work order backlog for the inspection group, in other words, planned activites dhat are ‘not yet past due. Similar to the number of pastsdue ITPM tasks, a backlog may indicate resource constraints + Total time charged to ITPM tasks each monthiquarter, A decline in the amount of time that is charged to these activities may indicate a change in focus for the maintenance department, + Number of temporary repairs currently in service (deferred maintenance items). This metric is another leading indicator of risk. + Total number of deferred repairs, such as known deficiencies that will be addressed at ‘the next turnaround. Note that this metric will often increase linearly overtime until the next maintenance shutdown, when it drops off sharply. However, the rate of increase could be @ leading indicator of risk. + Average time t0 address/correct deficiencies. This can be another leading indicator of risk and may help indicate if a step change has occurred in the ability to quickly repair ‘equipment, + Number (or percent) of ITPM tasks that uncover a failure. An increase in this metic may indicate that cisk associated with equipment failute is gradually increasing. Equipment reliabiligy (or availabilty). decrease in reliability (or availability) may indicate that risk associated with equipment failure is gradually increasing each ype of required tor of skill gaps or a higher EXAMPLE MANAGEMENT REVIEW QUESTIONS/ISSUES Many specific questions/discussion topics exist that management may want to check Periodically to ensure that the management system for the mechanical integrity clement is working properly. In particular, management must first seek to understand whether the system being reviewed is producing the desired results. If the organization's level of ‘mechanical integrity is less than satisfactory, otitis not improving as a result of management system changes, then management should identify possible corrective actions and pursue them. Possibly, the organization is not working on the correet activities, or the organization is not doing the necessary activities well, Even if the results are satisfactory, Management review can help determine if resourees are being used wisely — are there tasks that could be ‘done more efficiently or tasks that should not be done at all? Management can combine meities listed in the previous section with personal observations, direct questioning, audit results, and feedback on various topics to help answer these questions. Activities and topics for discussion include the following: + Compare the plan that is used to assign ITPM tasks at the facility to corporate standards. Does the plan contain any blanket exceptions? If so, review the justifications) for these exceptions to ensure that they are still vali. + Review individual exceptions to the [TPM plan that have been authorized since the last management review. (Note, ths item should only address tasks not being performed, not individual ITPM tasks that are currently past due or were performed late.) AS a ‘group, are these exceptions justified or does the facility have an underlying tendency to not perform certain ITPM tasks (or not perform a variety of ITPM tasks in a certain unit)?eee eRe ‘+ Review inspection or test results that have been obtained using new/trial methods. Did these methods deliver the expected benefits and should their use be extended to other areaslequipment a the facility? Review the special certitications that maintenance department personnel hold. Has this changed since the previous management review? IF any personnel holding critical certifications are planning to retire soon, review plans to train their replacements Determine if failure to comply with the [TPM work schedule is more often caused by random events or systemic issues. For each systemic issue that is identified, determine if t was reviewed in advance to assess the risk, Determine the dominant causes of past-due [TPM tasks that appear to be random, (© Is equipment not available? (© Areintervals for [TPM tasks intentionally st low because a widely held belief exists that tasks are not normally completed on time (ie. the “snooze buton” approach to scheduling)? ‘© Was the maintenance or inspection group unprepared to conduct the activity when equipment was available? + Review which inspection activities are routinely contracted out and which are Performed by maintenance department employees. Does this make sense fiom a risk management and business perspective? + Review metrics related to the fraction of maintenance work that is planned. IF the work is planned, the OEM parts and shop manuals are much mote likely to be available, and the work can be scheduled when a fully staffed and trained work crew is available, Furthermore, an increase in unplanned maintenance work may reflect an underlying increase in the ate of unplanned breakdowns. + Review new maintenance programs and work methods that are designed to reduce maintenance costs. What, if any, impact has the cost cutting had on equipment reliability, the ffaction of ITPM tasks completed as scheduled, or other key meties for this element? ‘+ Examine Pareto charts showing chronic equipment failures and determine if the facility hnas a practice to report and investigate these failures as chronic (possibly near miss) incidents Reliable equipment, coupled with reliable human performance, is critical to managing risk. In Addition, both are nevessary conditions for reliable operation. The management review for this clement often stats with questions related to metrics such as equipment availability or performance. However, the management review must delve deeper, examining the quality of ‘work activities that underpin the mechanical integrity element.” Just as the lack of a catastrophic process safety incident inthe past 10 years is not necessarily a reliable predictor (of the likelihood ofa catastrophic incident in the next year, the lack of catastrophic equipment failure does not indicate thatthe mechanical integrity element is fully Funetional. Piping may bbe about to fil as a result of corrosion, nozzles on vessels may be eracked, safety systems that ‘mitigate the consequences of an incident may have already failed. Thus, the management review for this element must examine the details, asking hard questions such as, “How many ITPM tasks have we missed?” and “What temporary repairs or deficient equipment are curently in service?” Also, maintenance and contract personne! can make errors that compromise the integrity of equipment. Are the training programs and procedures adequate? Answering these and other tough, but fundamental, questions is critical to understanding the true health of the mechanical inegrity element Ret fOrgp 6S though 69: Gidlins for Rk Based Proce Safe, Ariza tit of Chania Engin 2007Cee Coe BE Ee Ret: Gnideines for Mechanical ner Stems, America nina of Cheical Engines, 2008Implement? Activity Provides (aay Summary Discussion and Where to Go from Here Immediate follow-up *+ Preliminary assessment of MI program + Review/design MI program specifications + Re widevelop covered equipment lst) + List general equipment categories Short-term follow-up + Create an ITPM plan/schedule + Revise/upgrade QA + Developrimplement equipment deficiency plan *+ Identify personnel strategy (i... training/procedures required) + Write procedures * Develop training materials *+ Reality check (e.g, [s all equipment on the list covered in plans and procedures? Are special cases given special attention?) Long-term follow-up * Continuing assessments of MI program © Stay aware of: = regulatory developments = new codes/standards = updated codes/standards 63Provont catastrophic Eliminate near-miss Optimize mt ‘events (resulting from “ ‘events (resulting fom resources Number of events |“Yeee than adequat Number of events |"Iegs than adequate ‘my my T 7 + program costs sng | Minimize scheduled Prevent teases of + Donte esting | owntme esuing + rrPMinor ours | Minis TPM bor |. unberof eases | hacardous cereals Matai evaliabityof 3 from ITPM tasks — ‘from equipment = _ { it a iota i ; 1) | | «mac 825 | ‘operating with a ‘+ Numberof | Minimize maintenance) iaineai ear sent Sener insets coaentey, ‘+ Number of TPM | Optimize IPM tasks + numberof SCE | Optimize SCE list ea ae TPM tasks| ‘+ Number of SCEs |” “compliance with + Average operating | time of equipment See Mono smaoninee Sictcompaann | cesetad ante |” bso een | | temporary repairs rooms. | ip i i 7. fi i ; + Numer pat ‘eeu at panaaee ; SRectereies | prove pei feview TP wat Pero tort Prk cats SeeTtyces : ious” | "pcomet —_ * NoITPM task a walteereerificatca procedure or ‘instructions aoe eres eaesot feet Fg i sigue AOS SEL, Onn aR TORR | AOR DERE | ane os #8 at } aaa igh 3