Training Course Explained

on

API RP 578

By
Don Mears
Analytical Training Consultants
October 2-6, 2011

Author Don Mears Confidential 1

¾ President of Analytical Training Consultants (ATC)

¾ 30+ years of Oil and Gas industry experience

¾ Heavy involvement in API work groups

¾ Author of the API RP 578 2nd Edition PMI Certification Course

¾ Certified API Training Provider Certification TPCP # 0118

¾ G Industry
Oil & Gas I d C l
Consultant f Thermo
for Th Fi h Scientific
Fisher S i ifi

Author Don Mears Confidential 2

Guidelines & Application
pp Procedures
For
Positive Material Identification (PMI)
with
XRF & OES
Technologies

By
Don Mears
Analytical Training Consultants

Author Don Mears Confidential 3

¾ Introduction
¾ OSHA NEP-Directive CPL 03-00-004 for Refineries
¾ OSHA NEP-Notice CPL 02-00-148 for Chemical
Plants
¾ OSHA Oil & Gas Industry “Process Safety
Management” PSM Background
¾ Program Procedures
¾ Inspection Scheduling
¾ Proper Training and Refresher Training
¾ Compliance
p Guidance
¾ Enforcement Inspection- Penalties and Results
¾ Conclusion

Author Don Mears Confidential 4

` What is the Purpose of this API 578 PMI Certification Course ?

ƒ Purpose of the Course is to certify and re-certify API inspectors, in

understanding and applying API RP 578 through an approved API
Training Course, that will qualify personnel in proper Guideline and
A li ti procedures
Application d utilizing
tili i XRF and d OES ttechnologies
h l i ffor PMIPMI.

` The course is covered in 2 day sessions and instruction on both

classroom theoryy and field testing
g procedures.
p

ƒ Through Understanding API RP 578 Guidelines

ƒ Through Application of proper PMI testing procedures

` The need and now requirement for Positive Material Identification

(PMI) has dramatically grown in the past few years in refinery and
petrochemical plant operations to 100% alloy material verification in
today's risk-based QC environment.

Author Don Mears Confidential 5

¾ Occupational Safety and Health Administration (OSHA)
Acts
ƒ P
Process Safety
S f t M
Managementt (PSM) 1910-119-Highly
1910 119 Hi hl Hazardous
H d Chemicals
Ch i l (HHC) 2/24/1992
ƒ Refinery National Emphasis Program (NEP) CPL 03-00-004 6/7/2007
ƒ Chemical National Emphasis Program (NEP) 09-06 (CPL 02) Notice – Pilot NEP 7/27/2009

¾ American Petroleum Institute (API) Recognized And Generally

ƒ Standard-API-570-Piping Inspection Code Accepted Good Engineering
ƒ p
Standard-API-510-Pressure Vessel Inspection Code Practice” ((RAGAGEP))
ƒ Standard-API-653-Storage Tank Inspection Code
ƒ Recommended Practice-API RP-578-Material Verification Program-MVP/PMI
ƒ Recommended Practice-API 571 – HF Corrosion in CS Pipes ( REs, Cr, Cu, Ni )
ƒ R
Recommended
d d Practice-API
P ti API 939-C-Guidelines
939 C G id li for
f Avoiding
A idi Sulfidation
S lfid ti

¾ Mechanical Integrity Needs in the Oil & Gas Industry

ƒ Understanding HOW, WHY, & APPLYING:
9 ATC – API 578 PMI Certification Training Course
9 Data Management Software-PCMS, Ultra-Pipe, Meridian, Solid PMI
• According to OSHA’S refinery database:

• 36 fatality/catastrophe (FAT/CAT) incidents

• Related to Highly Hazardous Chemicals (HHC) since May 1992

• 52 employee deaths
• Includes 250 employee injuries, 98 with hospitalization

• # of incidents surpass the combined total of the next 3 highest

industries
• Chemical Manufacturing
Manufacturing-12
12 FAT/CAT
• Industrial Organic Chemical Manufaturing-12 FAT/CAT
• Explosive Manufacturing-11 FAT/CAT
 eg o 1
Region
Regional & Area Offices Region 8 Region 7 Region 5

Region 2
Region 10

Region 3

Region 4

Region 9

Region
g 6

 
Author Don Mears Confidential 9
 % Change
OSHA Violation Statistics FY2003 FY2004 FY2005 FY2006 FY2007
2003-2007
Total Violations 83,539 86,708 85,307 83,913 88,846 6.4%
Total Serious Violations 59,861 61,666 61,018 61,337 67,176 12.2%
Totall Willful
illf l Violations
i l i 404 462 747 479 415 2.7
Total Repeat Violations 2,147 2,360 2,350 2,551 2,714 26.4%
T t l Other-than-Serious
Total Oth th S i 20 552
20,552 21 705
21,705 20 819
20,819 19 246
19,246 18 331
18,331 -10.8%
10 8%
 
BP Texas City, Texas
Fined $30.7 Million
For 439 willful Violations
On 10/30/09
¾ Chemical Safety Board ( CSB ) Report-BP
Report BP Texas City Texas
¾ NY Times report on BP Texas City Fines
ƒ Safety Bulletin-BP Texas City.pdf
ƒ BP Faces Record Fine NY Times
Times-10-30-09.pdf
10 30 09 pdf
¾ Safety Bulletin from U.S. Chemical Safety and Hazard
Investigation Board (CSB)-Chlorine Transfer Hose Failure due to
improper material braid construction (i.e., 316L and not the
recommended braid of Hastelloy C-276). On August 14, 2002, a
1-inch transfer line ruptured
p during
g a railcar offloading
g operation
p
at DPC Enterprises in Festus, Missouri and released 48,000
pounds of Chlorine into neighboring areas
ƒ SafetyBulletin-ChlorineShutdown.pdf
y p
¾ Chemical Plant NEP effective on July 27
27,2009
2009
¾ Extended through end of 2010
¾ Outlines
O tli a diff
differentt approach
h for
f inspecting
i ti
PSM covered chemical facilities
¾ NOT comprehensive
h i
¾ LESS resource intensive for both OSHA and
Chemical Plants

Author Don Mears Confidential 12

 Regions 1,7,& 10 Inspections for 5-10 facilities as
Pil t Program
Pilot P

Regional & Area Offices Region 8 Region 7 Region 5 Region 1

Region 2

Region 10
Region 3

Region 4

OSHA by Region

Region 9
Region 6

 
In response to increasing industry safety demands, Analytical Training
Consultants has pproduced the API 578 PMI Certification Training
g Course

www.ATC578.com
ATC578
¾ Why Should this Course be Given ?

¾ “Recognized
Recognized And Generally Accepted Good
Engineering Practice” (RAGAGEP) – are
engineering, operation, or maintenance activities
based on established codes, standards, published
technical reports or recommended practices (RP) or
a similar
i il document.
d t RAGAGEPs
RAGAGEP d detail
t il generally
ll
approved ways to perform specific engineering,
inspection or mechanical integrity activities
activities, such as
fabricating a vessel, inspecting a storage tank, or
servicing a relief valve (See CCPS [Ref. 33]).
¾
Author Don Mears Confidential 15
¾ Important information is found in APPENDIX A regarding the
“Static
Static List of”
of Inspection Priority Items (IPI) and contains
questions that the Compliance Safety and Health Officer
(CSHO)’s are to address in their compliance evaluation of an
employer’s
l ’ refinery
fi “Process
“P Safety
S f t Management”
M t” (PSM)
program.
¾ It should be noted that both PMI and proper OPERATOR
TRAINING programs are QUESTIONS that the (CSHO) will
address to the Owner/Operator as to compliance with their
Process Safety Management (PSM) program.

Author Don Mears Confidential 16

 Positive Material Identification (PMI)
¾ Does the employer ensure that replacement piping is suitable
for its process application?
¾ Yes, No, N/A
¾ If no
no, possible violations include:
¾ The employer did not follow RAGAGEP when it failed to conduct
positive material identification (PMI) testing to ensure that
construction materials of replacement/repaired piping were adequate
for process conditions (An example RAGAGEP for PMI testing for
existing piping systems includes but is not limited to, API RP 578,
Material Verification Program for New and Existing Alloy Piping
Systems, Section 4.3), and CSB, Safety Bulletin – Positive Material
Verification: Prevent Errors During Alloy Steel Systems Maintenance,
BP Texas City, TX Refinery Fire);
¾

Author Don Mears Confidential 17

 Proper Operator Training
¾ Have operating employees been trained on the procedures they
are expected to perform? If NO, Possible Violations Include:

¾ The employer did not provide initial operator training on each

specific procedure operators are expected to perform; or
¾ 1) The employer did not document the training,
training
¾ 2) The employer did not document the means used to verify the
training, or
¾ 3) The employer did not verify that the operator understand the
training.
¾

Author Don Mears Confidential 18

 Proper Operator Training
¾ Based on the employer’s explanation of their management
of operator refresher training
g ((See document request in Section
X.E.3.o.), have the five randomly selected operating employees
received, completed, and understood the refresher training
(See document request in Section X.E.3.n.)? For each
employee who operates a process, has the employer ensured
that the employee understands and adheres to the current
operating procedures and that the refresher training is
provided at least every three years-- more often if necessary?
¾ YES, NO,N/A

Author Don Mears Confidential 19

 Proper Operator Refresher Training
¾ If no,
no possible violations
iolations include:
incl de

¾ 1)) The employer

p y did not p provide operator
p refresher training
g at
least every three years or more often, if necessary (e.g., on a
frequency consistent with that determined through
consultation with employees); or
¾ 2) The employer did not document the training;
¾ 3) The employer did not determine that the operator
understood the training it received; or
¾ 4) The employer did not document how it verified the training

Author Don Mears Confidential 20

 Incident Investigation Report
¾ The CSHO must document in the INCIDENT INVESTIGATION
REPORT the number of “Actual” and a “Near-Miss” incident
which has occurred in you plant. A very important part of this is
the “Factors
Factors that contributed to the incident”
incident . In section Q of
Appendix A OSHA list examples and PMI and Training are a
part of this list:
¾ Examples of "Factors that contributed to the incident”/“causal
factors” can include, but are not limited to:
¾

Author Don Mears Confidential 21

 Incident Investigation Report
¾ Examples of "Factors that contributed to the incident”/“causal
factors” can include, but are not limited to:
¾ The employer did not design, operate, maintain, inspect, or
change
c a ge ((MOC)
OC) equipment
equ p e t or
o equipment
equ p e t systems
syste s pe
per
RAGAGEP;
¾ The employer did not train its employees in its procedure for
transferring product from the Chemical X intermediate tank to
Reactor 23;
¾ The 3-inch reactor transfer line was replaced without
conducting a PMI, as a result, the replaced piping that was
constructed of an off-specification material failed in a short
period of time;;
p

Author Don Mears Confidential 22

¾ Originally
launched 6/7/07
¾ Updated
U d t d 8/18/09 to
t extend
t d timeframe
ti f for
f
completion
¾Region
¾R i VI onlyl region
i with
i h iinspections
i still
ill to open (4)
¾Completion by end FY2011
¾ The approach/content of the inspections has not
changed
¾ Combines
C bi “static”
“ t ti ” and
d “d
“dynamic”
i ” question
ti lists
li t
with guidance for compliance officers (CSHOs)
¾ Comprehensive
¾ Average 1,000 OSHA hours per inspection
¾ Typically use full statutory 6 months
available
¾ Also resource intensive for employers
¾ Compliance found to be highly uneven
¾ Substantial issues identified
¾ Average penalties/inspection ~$166,000
$166 000
¾ Average penalty/violation ~$9,560
¾ Average violations/inspection ~17.4
 Refinery NEP Most Frequently
Cited PSM Elements
Element Description % of Citations Cumulative %

j Mechanical Integrity 19.4% 19.4%

d Process Safety Information 17.5% 36.9%
f Operating Procedures 17.1% 53.9%
e Process Hazard Analysis 17.0% 70.9%
l Management of Change 8.2% 79.1%
m Incident Investigation 6.7% 85.8%
o Compliance Audits 3 8%
3.8% 89 6%
89.6%
h Contractors 2.8% 92.5%
g Training
g 2.7% 95.2%
n Emergency Planning & Response 1.5% 96.7%
c Employee Participation 1.4% 98.1%
i Pre-startup Review 1.1% 99.2%
k Hot Work Permit 0.8% 100.0%
¾ Chemical Plant NEP effective July 27, 2009
¾ Extended through end of FY2010
¾ Outlines a different approach
pp for
inspecting PSM covered chemical
facilities
¾ Not comprehensive
¾ Less resource intensive for both OSHA
and employers
¾ Oneyear pilot program for planned
inspections in 3 OSHA Regions:
ƒ Region I – CT,
CT MA,
MA ME
ME, NH
NH, RI
ƒ Region VII – Nebraska, Kansas, Missouri
ƒ Region X – Idaho

¾ State Plans urged to participate voluntarily

ƒ Some states are doing Chemical NEPs
¾ As you know,
know Voluntary Participation Program
(VPP) sites are not subject to programmed
inspections
¾ However, the NEP applies OSHA-wide for un-
programmed PSM related inspections:
ƒ Accidents
ƒ Complaints
ƒ Referrals
ƒ Catastrophes
p
¾ Selected from list of:
ƒ EPA Risk
Ri k Management
M Program
P (RMP) P
Program 3 ffacilities
ili i
ƒ OSHA database (previous PSM citations)
ƒ Explosives Manufacturing
ƒ Facilities identified by local (Area and Regional Office)
knowledge
Chemical Plant NEP Inspections

¾ As
A off A
August,
t 2010
2010, 112 iinspections
ti opened
d
ƒ 38 Unprogrammed (34%)
ƒ 74 P
Programmed d (66%)
ƒ 9 resulted in no inspection occurring because there was no
PSM covered process
¾ 62inspections have issued citations
¾ Average 9
9.00 citations per inspection
¾ Average $3,500 per citation
¾ Over 60 different standards cited
¾ 44% of all citations were other than PSM
 Chemical Plant NEP Citations by PSM
Element
% of PSM 
Element Description Citations Cumulative %
j Mechanical Integrity 23.8% 23.8%
d y
Process Safety Information 20.2%
% 44.0%
%
e Process Hazard Analysis 19.0% 63.0%
f Operating Procedures 13.9% 76.9%
g Training 4.8% 81.7%
h Contractors 3.8% 85.6%
o Compliance Audits
Compliance Audits 3 4%
3.4% 88 9%
88.9%
l Management of Change 3.1% 92.1%
n Emergency Planning & Response 2.9% 95.0%
m Incident Investigation 2.6% 97.6%
i Pre‐startup Review 1.4% 99.0%
k Hot Work
Hot Work 1 0%
1.0% 100 0%
100.0%
Training Course Explained
on

API RP-578

By
Don Mears
Analytical Training Consultants

Author Don Mears Confidential 32

¾ THROUGH UNDERSTANDING API RP 578 GUIDELINES ( DAY 1 )
¾ Scope of the Course
¾ General
¾ Alloy Substitutions in Carbon Steel Systems
¾ Roles and Responsibilities
¾ Industry References
¾ Terms and Definitions
¾ Extent of Material Verification Program
¾ Explain use of Material Verification Program Test Methods
¾ Field Evaluation of PMI Test result procedures
¾ P
Proper M ki and
Marking d Record
R d Keeping
K i
¾ Review and Testing on Academic Material of API-RP-578

Author Don Mears Confidential 33

¾ THROUGH APPLICATION OF PROPER PMI TESTING PROCEDURES ( DAY 2 )
¾ Using XRF Technology- (Hands-on Application/Demonstration)
¾ Review of XRF Technology
¾ Who should use it?
¾ What is XRF – Technology Explained
¾ When should XRF be used?
¾ Where should XRF be used—Types
used Types of Alloys
¾ How should XRF be used—PMI methods and Procedure Guidelines
¾ Why should XRF be used-Percent of PMI needed?

Author Don Mears Confidential 34

¾ THROUGH APPLICATION OF PROPER PMI TESTING PROCEDURES ( DAY 2 )
¾ Using OES Technology-(Hands on application/Demonstration)
¾ Review of OES Technology
¾ Who should use it?
¾ What is OES-Technology Explained?
¾ When should OES be used?
¾ Where should OES be used—Types of Alloys
¾ How should OES be used—PMI Methods and Procedure Guidelines
¾ Why should OES be used--Percent of PMI needed?

Author Don Mears Confidential 35

 Summary Comments for Presentation:
¾ “Reasons Why! This Course should be given ! ”
¾ OSHA INSTRUCTION for Both Refining and Chemical Plants Uses Examples:
ƒ API RP 578
ƒ Operation Training and Refresher Training
¾ Safety Bulletin from U.S. Chemical Safety and Hazard Investigation Board (CSB)—BP
Texas City
¾ Safety Bulletin form U.S. Chemical Safety and Hazard Investigation Board (CSB)---
Chlorine Transfer Hose Failure
¾ All the Reported and Unreported “Near Misses” the Oil and Gas Industry has
experienced.
¾ This is true with all Global Oil & Gas Petro Chemical Companies !

¾ Joint US and Mexico Efforts to Ensure Safe and Healthful Working Conditions for Workers from
Mexico and other Latin American Countries. True also with North America, Europe & China
http://www.osha.gov/international/index.html

Author Don Mears Confidential 36

Q
Questions
i ?

Author Don Mears Confidential 37