2012 RESEARCH &

TECHNOLOGY FORUM
Madison, WI

MECHANICAL
INTEGRITY UPDATE
AT THE IRC AND BEYOND

Daniel Dettmers
Industrial Refrigeration Consortium
University of Wisconsin - Madison
 MECHANICAL INTEGRITY

• Mechanical Integrity has become a hot

topic in the ammonia refrigeration industry
among:
• OSHA inspectors
• Corporate engineering departments
• Plant managers & engineering managers
• Standard & code writing organizations
• Refrigeration & inspection contractors
• What is fueling this fire?
• What is being done by our industry?
OSHA’S CHEM NEP - BACKGROUND

• NEP = National Emphasis Program

• One year pilot emphasis program initiated 5/09
• Programmed inspections for Regions I, VII, X
• Unprogrammed inspections nationwide (CPL-02-09-06)
• Pilot renewed for a second year into 2011
• Extended administratively until fully national program
became effective on November 2011
• 15 “yes/no” questions with detailed compliance
guidance
• “Pop Quiz” approach
• Improve consistency across inspections
• Suggested citation elements and
reference RAGAGEP

Credit: George Yoksas, OSHA, Region V Program Manager for PSM

CHEM NEP INSPECTIONS – NOVEMBER 2011
(COMPLETION OF PILOT)

• 259 inspections attempted, 229 opened

• 59% Programmed (NEP)
• 41% Unprogrammed, includes complaints, referrals, follow-
up, and monitoring inspections
• 11.6% of total attempted (30) no-inspection
(not operating, or no covered process)
• 24.5% (56) of opened inspections found
“in compliance”
(inspected, no citations) Other
NH 3
Refrig
• 41% of selected facilities
were ammonia refrigeration Cl Contrcr

Credit: George Yoksas, OSHA, Region V Program Manager for PSM

CHEM NEP CITATIONS BY PSM ELEMENT

Element Description % of PSM Citations

j Mechanical Integrity 23.2%
d Process Safety Information 20.9%
e Process Hazard Analysis 15.8%
f Operating Procedures 14.0%
l Management of Change 5.5%
o Compliance Audits 4.5%
g Training 3.8%
h Contractors 3.4%
c Employee participation 2.8%
m Incident Investigation 2.6%
n Emergency Planning & Response 1.8%
i Pre-startup Review 1.1%
k Hot Work 0.6%
Credit: George Yoksas, OSHA, Region V Program Manager for PSM
 CHEM NEP CITATIONS BY PSM
SUB-ELEMENT

Sub-element Description % All Citations Cumulative %

119(d)(3)(ii) PSI RAGAGEP 7.0% 7.0%
119(j)(2) MI written procedures 6.7% 13.7%

119(j)(5) MI equipment deficiencies 3.7% 17.4%

119(l)(1) Management of Change dev & imp 3.7% 21.1%

119(j)(4)(i) MI I&T performed 3.6% 24.7%

119(e)(5) PHA findings & recommendations 3.5% 28.2%

119(d)(3)(i)(B) PSI P&IDs 3.4% 31.5%

119(o)(1) Compliance Audits performed / certified 3.0% 34.6%

119(j)(4)(iii) MI I&T frequency 2.7% 37.3%

119(e)(3)(i) PHA Hazards of the Process 2.5% 39.7%

119(e)(1) PHAs performed 2.2% 42.0%

119(f)(1) OP Developed & Implemented 2.2% 44.2%

119(f)(3) OP annually certified 2.2% 46.5%

119(j)(4)(ii) MI I&T follow RAGAGEP 2.0% 48.5%

Credit: George Yoksas, OSHA, Region V Program Manager for PSM

 INDUSTRY RESPONSE

• Mechanical integrity is gaining

visibility in our industry
• Fear of downtime
• & associated lost production time
• Fear of major/minor release
• & associated publicity
• Fear of OSHA NEP inspection
• & associated fines
 29 CFR 1910.119 (j)*

(j)(4) Inspection and Testing

• (j)(4)(i) Inspections and tests shall be performed
on process equipment
• (j)(4)(ii) Inspection and testing procedures shall
follow Recognized And Generally Accepted
Good Engineering Practices
• (j)(4)(iii) The frequency of inspections & tests of
process equipment shall be consistent with
applicable manufacturers‘ recommendations
and good engineering practices, and more
frequently if determined to be necessary by prior
operating experience
 GOOD ENGINEERING PRACTICE?

“(j)(4)(ii) Inspection and testing procedures shall follow

Recognized And Generally Accepted Good Engineering
Practices”

• Industry standards/guidelines
• ASME, ASHRAE, IIAR
• Kindred industry standards?
• Prior operating experience
• Manufacturer’s recommendations
• Industry “best practices”
WHAT IS OUR RAGAGEP?
 RAGAGEP FOR NH3
REFRIGERATION

• Industry standards/guidelines
• ASME Section VIII Div. 1, B31.5
• IIAR 2, IIAR 5 (and others to come)
• IIAR Bulletin 109 &110
• IRC’s MI Guidebook, Volume 2?
• National Board Inspection Code (ANSI/NB-23)?
• Kindred industry standards/guidelines?
• API (American Petroleum Institute)? Applicability
to ammonia
• CGA (Compressed Gas Association)? systems is
suspect
 IIAR BULLETIN 109 & 110

• 109: Guidelines for: Start-up, Inspection and

Maintenance of Ammonia Mechanical
Refrigerating Systems
• Basic requirements for safe start-up, inspection
and maintenance of ammonia refrigerating
systems.
• 110: Guidelines for: Start-up, Inspection and
Maintenance of Ammonia Mechanical
Refrigerating Systems
• Specific requirements and general
recommendations for inspection and
maintenance.
• All maintenance per manufacturer’s instruction.
• Focuses on maintenance which promotes safety.
 IS NDT REQUIRED?

• 110:6.4.4.1: “…The independent person should carry out

such examinations and tests required to determine if the
equipment is safe and recommend and necessary
action...”
• 110:6.4.4.2: “Where external corrosion has formed pits or
caused material loss that reduces the thickness of the
pressure vessel or shell-and-tube heat exchanger, the
inspecting person should measure or cause to be
measured the thickness of the remaining
metal to determine whether the replacement
is necessary
• 110:6.7.1: “Deeper pitting or loss of metal,
where considered by subjective assessment
to be greater than 10% of original wall
thickness, should be checked accurately by
using techniques such as ultrasonic
measurements.”
 NB-23
Introduction:
A05 purpose of the National Board
Inspection Code (NBIC) is to
maintain the integrity of pressure-
retaining items after they have been
placed in service by providing rules
for inspection, installation, repair
and alteration, thereby ensuring
that these objects may continue to
be safely used.

• Excludes anything covered by

API 510/570/579
• Written for pressure vessel
inspection, but not specifically for
the ammonia refrigeration
industry.
 IS NDT REQUIRED?

• Yes…when
• Corrosion is identified
• “Corrosion rate” and “Remaining Life” need to be
calculated
• Wall thickness needs to be calculated to verify vessel is
above “T-min”
• Can an NDT contractor
declare your system “safe”?
• No, they can only inspect to your
go/no go criteria
• Does an NDT inspection help
or hurt you?
• Yes and yes
 SOON TOO ARRIVE?

IIAR 5 - Start-up and IIAR 6 – Inspection and

Commissioning of Closed-Circuit Maintenance of Closed-Circuit
Ammonia Mechanical Refrigerating Ammonia Mechanical Refrigerating
Systems Systems

?
 GO VS. NO-GO

• Industry struggles with go/no-go

criteria for piping
• New appendix under development
for B31.5 called “Non-mandatory
requirements for Fitness
-for-Service”
• Derived in part from ASME B31G Manual
for Determining the Remaining Strength
of Corroded Pipelines: Supplement to
ASME B31 Code for Pressure Piping
 IRC’S EFFORTS

• Held MI workshop for IRC members

and invited guests
• Identified industry deficiencies
including:
• RAGAGEP undefined
• No consistency across industry
• Lack of go/no-go criteria
• Insufficient support for MI
• Reference material
• NDT contractor focus
• Few MI related KPIs defined
 IRC’S EFFORTS

• Workshop participants determined IRC’s

assignments:
• Update the 2007 Nondestructive
Testing Methods for Mechanical
Integrity Guidebooks
• Update NDT technology
• Expand scope to cover all
essential components
• Include further information on
Risk Based Inspection
• Develop a procedure for a
Visual Inspection Program that plants can
adopt for their programs
 WHAT’S NEW WITH NDT?

• NDT inspectors and refrigeration system owners are

flushing out the technology that works
• Example: using radiography instead of U.T. to get piping
thickness

vs. vs.
 WHAT’S NEW WITH NDT?

• New competitor to the radiometric profiler

• Portable x-ray imaging
• Both good at finding ice/water

Lixi ProfilerTM OpenVisionTM LT

DIGITAL RADIOGRAPHIC PROFILER

• What it can do:

• Tell changes in density (thickness) due to:
• A weld
• Change in pipe schedule
• Wall loss from corrosion
• Addition of water or ice under the insulation
• Move quickly through a plant
• What it can’t do:
• Give accurate thickness
(unless calibrated)
• Deliver a “picture” like
traditional radiography
 PORTABLE X-RAY IMAGING

• Self generates an x-ray source

to image pipe insulation
• What it can do:
• Produces realtime visible image &
x-ray image
• Clearly show areas of moisture
intrusion and visible corrosion/pitting
• What it can’t do:
• Provide thickness measurements
• Can’t tell pit depth
• Quantify the amount of water
 THERMOGRAPHY
• Video camera that measures the
passive infrared radiation emitted by
target
• More facilities are experimenting with
the technology to see what is possible
• Very easy to be “tricked” by the camera
and/or lack of experience
 VISUAL INSPECTION

• Thorough Routine and Annual inspection should be

a part of your MI/PM program
• Routine inspection – look at pipe/vessels as part of
operators daily/weekly rounds
• Annual inspection – a thorough examination of all piping
and vessel surfaces by trained maintenance staff
• Benefits of proper visual inspection
• Catch corrosion/defects before they
require NDT inspection
• Catch problems before they become
sources of production downtime
• Catch problems when repair is less expensive
 VISUAL INSPECTION PROGRAM

Establishing Your Inspection Plan

• Layout a roadmap for the inspection
• All In
• Geographic
• Pressure/Temperature Level
• Functional
• * Risk Based Inspection
• Document the inspection plan or scope
• Develop inspection record documents
• Develop document management system for
inspection results
 VISUAL INSPECTION PROGRAM

Inspection Preparation
• Identify qualified inspector or inspectors
• Review training on expected defects
• Company developed material
• IRC’s Nondestructive Testing Methods for Mechanical Integrity;
Volume 1: MI Fundamentals - Chapter 2
• SSPC-VIS 2: Standard Method of Evaluating Degree of Rusting
on Painted Steel Surfaces
• Gather inspection documentation
• IIAR 109 “Checklist”
• Develop custom forms
• Gather inspection equipment
• Provide a list of recommended equipment
 VISUAL INSPECTION PROGRAM

Inspection
• Perform inspection
• Document
• Type of defect
• Location of defect
• Distance from landmark (e.g. tagged valve, vessel, evaporator)
• Mark with flag or other tag that includes tag number that can be
referenced in documents
• Photograph significant defects
• Use ruler to show scale
• Use pit gauge to show depth
• Store documents
• Store all documents developed using method for easy retrieval
 QUESTIONS?

Innovation – Knowledge – Progress

www.irc.wisc.edu
VISUAL INSPECTION
PROGRAM
PIPING & VESSELS
 VISUAL INSPECTION PROGRAM

• Visual Inspection Program –

Piping & Vessels
• Tab 8 of handout
• 7 page draft copy
• 4 appendix
• A: RAGAGEP Inspection
Requirements
• B: Mechanical Integrity Risks and
Typical Failure Modes for Piping
and Vessels
• C: Typical Failure Mechanics
• D: Tips for Performing a Visual
Inspection
 VISUAL INSPECTION PROGRAM

Establishing the Inspection Plan

• Layout a roadmap for the inspection
• All In
• Geographic
• Pressure/Temperature Level
• Functional
• * Risk Based Inspection
• Document the inspection plan or scope
• Develop inspection record documents
• Develop document management system for
inspection results
 VISUAL INSPECTION PROGRAM

Inspection Preparation
• Identify/qualified inspector or inspectors
• Review training on expected defects
• Appendix B, C & D
• IRC’s Nondestructive Testing Methods for Mechanical Integrity;
Volume 1: MI Fundamentals - Chapter 2
• SSPC-VIS 2: Standard Method of Evaluating Degree of Rusting
on Painted Steel Surfaces
• Gather inspection documentation
• IIAR 109 “Checklist”
• Develop custom forms
• Gather inspection equipment
• Provides a list of recommended equipment
 VISUAL INSPECTION PROGRAM

Inspection
• Perform inspection
• Document
• Type of defect
• Location of defect
• Distance from landmark (e.g. tagged valve, vessel, evaporator)
• Mark with flag or other tag that includes tag number that can be
referenced in documents
• Photograph significant defects
• Use ruler to show scale
• Use pit gauge to show depth
• Store documents
• Store all documents developed using method for easy retrieval
 VISUAL INSPECTION PROGRAM

Appendix A: RAGAGEP Inspection Requirements

• Provides a brief summary of VISUAL inspection requirements
found in industry documents
• IIAR 109 & 110
• IRC MI Guidebook
• NB-23 (Vessel Inspection)
Appendix B: Mechanical Integrity Risks and Typical
Failure Modes for Piping and Vessels
• Divides piping and vessels into High Risk, Moderate Risk &
Lower Risk
• Provides typical failure mechanisms for each component
• Will update with results from this workshop
 VISUAL INSPECTION PROGRAM

Appendix C: Typical Failure Mechanics

• Outlines the probable failure methods for various types of
piping
• Includes tell-tale signs of many defects
• Provides pictures illustrating defects
Appendix D: Tips for Performing a Visual Inspection
• Advise from ASM, ASNT and other inspection standards on
visual inspection
• Advice on the process
• Methods to “supplement” visual inspection
• Lighting • Borescope
• Magnifier • Video