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CONFIDENTIAL

Best Practice Guide

Management of Change Processes in Relation to

Pressure Equipment Integrity Management

BPG INSP-10-I

Revision 0

June 2008

Document Revision Log

Issue
Number Comments / Changes
Date:
Rev 0 June 2008 International version of BPG INSP-10.

This report has been classified as Confidential and is subject to US Export Control regulations and has been
classified as ECCN EAR 99.
This document is for use by the operating units constituting Shell Global Solutions and the companies with
which they have a licence or a service agreement only, and is provided subject to the terms of the relevant
licence or service agreements. It should not be applied in any specific situation without having obtained
further clarification and advice from Shell Global Solutions. No member of the Royal Dutch/Shell Group of
companies accepts any liability for the application of this document by anyone.
Copyright of this document and the accompanying documentation is vested in one or more companies of the
Royal Dutch/Shell Group of companies. All rights reserved.
© 2008 Shell Global Solutions International B.V. and Shell Oil Company.

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Table of contents
PAGE

1.0 PURPOSE ----------------------------------------------------------------------------- 3

2.0 SCOPE -------------------------------------------------------------------------------- 3

3.0 REQUIREMENTS ---------------------------------------------------------------------- 3

4.0 RECOMMENDED PRACTICE ---------------------------------------------------------- 4

APPENDIX A EXAMPLES OF PHYSICAL CHANGES IMPACTING PRESSURE

EQUIPMENT INTEGRITY ------------------------------------------------------------------ 6

APPENDIX B EXAMPLES OF PROCESS CHANGES IMPACTING PRESSURE

EQUIPMENT INTEGRITY ------------------------------------------------------------------ 7

APPENDIX C CHECKLIST OF TYPICAL MECHANICAL INTEGRITY ISSUES FOR

MANAGEMENT OF CHANGE AND PROCESS HAZARDS ANALYSIS ---------------------- 9

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1.0 PURPOSE

This Best Practice Guide (BPG) is intended to provide information regarding elements
necessary or suggested for inclusion in Management of Change (MOC) work processes.
This BPG is set forth in order to strengthen location MOC work processes specifically to
provide greater assurance of effective Pressure Equipment Integrity Management
(PEIM), and compliance with local Process Safety Management (PSM) regulations (for
example OSHA 1910.119 in the US).

2.0 SCOPE

Though other disciplines or entities may benefit from application of the information in
this document, this BPG focuses on MOC elements considered important for effective
maintenance of pressure equipment integrity. It is not intended to cover the
requirements or recommendations of any other discipline, or to be the sole source of
information for guidance in developing, reviewing and strengthening Management of
Change work processes.

3.0 REQUIREMENTS

For effective MOC, location personnel must be aware of all of the kinds of changes
which can impact pressure equipment integrity. Location MOC work processes must
ensure that all appropriate personnel are included in MOC review and approval for
these kinds of changes. The MOC work process must also provide training for all
affected personnel, and ensure review and updating of the MOC work process itself.
Further explanation is provided below.

1. Identifying Process-Related Changes:

The most basic requirement of a Management of Change work process is the inclusion
of all changes that may impact pressure equipment integrity. For the purpose of this
document, changes are classified as "physical" changes and "process" changes.

Physical changes: These are the most easily recognized changes, (often called Plant
Change) and are more often effectively handled by MOC work processes. These are
direct physical changes to both pressure equipment and associated structures, etc.
(see Appendix A for some examples of physical changes to consider)

Process changes: These are equally important for effective pressure equipment
integrity management, and can be easily overlooked since they normally involve some
"unseen" change to the process medium or to an operating practice or procedure,
rather than a direct physical change to the equipment. Process changes are also
overlooked when those initiating the changes do not recognize that the process
change may have an impact on pressure equipment integrity. The knowledge of
process technologists and operators regarding potential materials degradation issues
in their assigned process units is key to the success of this work process. This
knowledge can best be imparted when Corrosion Control Documents (CCDs), Risk
Based Inspection Manuals, Materials Engineer Philosophy (MEPs), Integrity Operating
Windows (IOWs), Key and Critical Operating Limits, Key Process Parameter Limits
(KPPLs) or equivalent are developed and the knowledge contained within them is
transferred to all operating personnel and process technologists; and when integrity
operating window process limits are established with the involvement of the
corrosion/materials engineer (see Appendix B for some examples of process changes
to consider).

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Organizational Change Roles: The roles in the case of organizational change are the
same as for the change of hardware, process or procedures. However, in the case of
organizational change, departmental managers are expected to fulfil a major role
which leads to a few exceptions to the role descriptions given in Table 2. Table 3
"Change" identifies the different staffing for these exceptions only.

Competency

HSE assurance of departmental managers is outside the scope of the CM process and
expected to be covered via the Shell Chemicals HSE assurance process.

It is vital to assure that MOC work processes address all types of process and physical
changes, from both integrity and a compliance standpoint.

As a further aid in identifying process changes, Appendix C, "Checklist of Typical

Mechanical Integrity Issues for Management of Change and Process Hazards Analysis",
provides a list of some potential issues to consider.

2. Involvement of appropriate personnel:

MOCs which may impact pressure equipment integrity must be reviewed and approved
by appropriate Pressure Equipment personnel.

3. Training:

Affected personnel shall be properly trained, including training in Management of

Change work processes. Once an MOC work process is revised and agreed upon, any
individual (including contract personnel) who has the ability or authorization to make
process-related changes (physical or process) must be trained on the details of the
MOC work process.

4. Updating:

The location MOC work process "owner" must assure that the work process and its
related procedures are reviewed, and updated as necessary, on some predetermined
frequency. Pressure Equipment personnel must be included in this review for Pressure
Equipment Integrity Management (PEIM) purposes. Affected personnel must be
retrained as necessary to assure they are knowledgeable regarding the updated work
processes and procedures.

4.0 RECOMMENDED OR SUGGESTED PRACTICE

In addition to the requirements above, this BPG recommends or suggests the

following:

• "In-kind" Replacement: Though in-kind replacements are excluded in the MOC

process, knowledge of such replacements are important to Pressure Equipment
personnel understanding of issues and potential reliability problems within their
assigned process units. Whether explicitly included in location MOC work
processes, or effectively covered by some other means, it is recommended that
location work processes assure that appropriate Pressure Equipment personnel are
at least advised of, and preferably included in, replacement-in-kind decisions.

• Identifying Changes: Location MOC work processes should include guidance and/or
examples for identifying change impacting pressure equipment integrity.

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• Involvement of appropriate personnel: One trained individual along with the

initiator is required to decide who reviews the MOC. It is strongly recommended
that location MOC work processes require review and approval by all engineering
disciplines to assure the proper level of review is achieved. Some organizations
allow the originator to determine the appropriate routing, leaving the decision
regarding the need for a specific discipline’s involvement to someone who may not
be very knowledgeable in that particular discipline. A process, which requires
review by all disciplines, forces the discipline to decide on its own level of
involvement.

• Emergencies: The MOC work process should contain specific guidance on how to
apply the process during (and following) emergency conditions, where immediate
action is required to avoid personnel hazard, equipment damage, environmental
exceedance or significant economic penalty.

• Responsibilities: The MOC work process should clearly define roles and
responsibilities for those who will participate in the process. Some of the roles may
include: originator, change owner, affected area management, operations
personnel, discipline personnel, and others.

• Compliance auditing: The MOC work process should be included in location

compliance audit activity to assure on-going compliance with any local regulations.

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APPENDIX A - EXAMPLES OF PHYSICAL CHANGES IMPACTING

PRESSURE EQUIPMENT INTEGRITY

NOTES:
1. This list provides examples to stimulate thought and is NOT intended to be all-
inclusive.
2. "Equipment" as used herein is intended to include any equipment which may
impact pressure equipment integrity. This would include not only items normally
considered to be "pressure equipment", but also piping, relief system equipment,
machinery, electrical systems, instrumentation and control systems, and any
other physical entity which may impact pressure equipment integrity.
EXAMPLES:
• Equipment replacement.
• Addition/removal/decommissioning of equipment.
• Equipment numbering changes (even "in-kind" replacements will require MOC if
equipment numbers change, necessitating updating engineering and operations
documents).
• Temporary equipment and piping installations and/or repairs, including the use of
repair clamps, boxes, wire wraps, and other enclosure techniques.
• Re-pumping of existing enclosures (clamps, boxes, wire wraps, etc) in process
service.
• Changes in materials of construction or specified heat treatment (e.g., non-PWHT
versus PWHT).
• Changes in equipment design (e.g., re-rating, change of equipment specification,
resetting of a relief device).
• Modification of equipment (e.g., addition/deletion/modification of nozzles,
pressure boundary, equipment internals).
• Addition/deletion/modification of corrosion barriers (e.g., coatings, linings).
• Addition/deletion/modification of an injection point or mix point in the process
system.
• Addition/deletion/modification or shutting off of cathodic protection systems.
• Addition/deletion/modification of insulation systems.
• Addition or deletion of tie-in points.
• Addition/deletion/revision of equipment-related structural support systems.
• Addition/deletion/modification of process bypasses (e.g., a bypass around an
exchanger).
• Addition/deletion/modification of physical process barriers (e.g., car seals, blinds,
process control interlocks).
• Hot tapping and/or welding on any pressure equipment and piping system while it
is in service.
• Addition/deletion/modification of equipment internals (e.g., demister pad or
coalescer removal, tray level modifications, size of hole in orifice tap, etc).
• Continued operation with changes that have occurred in piping and equipment
support systems (e.g., broken pipe hangers, pipe support lift off, pipe shoes
falling off a support, etc).

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APPENDIX B - EXAMPLES OF PROCESS CHANGES IMPACTING

PRESSURE EQUIPMENT INTEGRITY

NOTE:

This list provides examples to stimulate thought and is NOT intended to be all-
inclusive.

EXAMPLES:
• Operation outside of the boundaries of agreed upon Integrity Operating Windows
(IOWs) (e.g. pressure, temperature, flow rate, pH, fluid composition, etc).
• Adding, deleting or modifying integrity operating window process limits.
• Operation outside of process or equipment design limits specified in the
equipment files, Process Flow Diagrams (PFDs), Engineering Flow Diagrams
and/or Process and Instrument Diagrams (P&IDs).
• Abnormal operation of equipment (e.g., choosing to continue operation with
known equipment leaks, such as heat exchanger bundle leaks, known air leaks
into systems operating under vacuum, storage tank leaks, etc).
• Moving to an operating range that the process technologist/engineer, through
his/her knowledge of the potential materials degradation issues in the unit,
suspects could lead to an equipment issue, even though the operating range is
still within the integrity operating window process limits (e.g., the tube limit for a
heater may be set based on creep failure potential, but in fact coking of the tube
may take place at a lower range than this and lead to a failure).
• Delay of maintenance on vital instrument devices (e.g., delaying
repair/replacement of a failed flow meter on a corrosion inhibitor injection system;
continuing to operate with a failed pressure or temperature indicating device).
• Continuing to operate with changes in equipment vibration levels (continuous or
intermittent).
• Continuing to operate with equipment and/or furnace tube hot spots.
• Continuing to operate with detected changes of the amount of, or type of,
neutralization, inhibitor chemical injection, or water wash (e.g., when water wash
pumps are out of service).
• Continuing to operate with steam tracing leaks that can cause external corrosion
or stress corrosion cracking.
• Changes in run length (e.g., postponing an equipment inspection or a unit
turnaround).
NOTE: This is not intended to include normal deferral activities, or the adjustment
of inspection intervals by Pressure Equipment personnel following an inspection.
• Changing the service of a piece of equipment.
• Changing the storage contents of a tank.
• Addition/deletion/modification of an injection stream (e.g., water wash, chemical
injection, etc).
• Addition/deletion/modification of a potentially corrosive mix point of process
streams.
• Altering the amount or composition of an injection/mix stream outside of identified
limits.

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• Altering process stream composition or properties outside of identified limits (e.g.,

acid strength, sulphur content).
• Adding a new process stream (e.g., an opportunity crude, other new feeds with
different contaminants).
• Revising process line-ups (e.g., such that "deadlegs" are created or deleted, or
relief paths are altered).
• Changing the operation of bypasses around heat exchange equipment in such
a manner that potential materials degradation issues become a concern (e.g.,
bypassing too much around an exchanger may lead to overheating of the stream
going to the next downstream exchanger, to the point that it may now be
operating in the range where high temperature hydrogen attack can take place).
• Bypassing installed equipment (e.g., desalters, knock out pots, coalescers, etc).
• Implementing or revising start-up or shutdown procedures (e.g., for hydrotreater
reactors).
• Implementing or revising decontamination, flushing and/or pressure testing
procedures (e.g., steaming out equipment containing caustics or other stress
corrosion cracking agents, utilization of chloride and/or sediment containing
waters in austenitic stainless steel equipment, brittle fracture concerns during
pressure testing).
• Changing a normally closed valve to a normally open valve and vice versa.
• Process changes resulting in significantly increased cooling or heating rates of
equipment in service, which could lead to brittle fracture, thermal fatigue, etc.
• Use of positive displacement pumps, or other high pressure source, to dislodge
a plug in process piping.
• Changing equipment from continuous operation to intermittent and vice versa.

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APPENDIX C - CHECKLIST OF TYPICAL MECHANICAL INTEGRITY

ISSUES FOR MANAGEMENT OF CHANGE AND PROCESS HAZARDS
ANALYSIS

If process conditions in the equipment exceed the established Integrity Operating

Window variable range is there any potential for....
1. Temperature changes that might cause brittle fracture of any equipment from
materials with low toughness due to thermal shock or from transient conditions
experienced in start-up or shutdown of heavy wall vessels?
2. Setting up vibration (continuous or intermittent) that could lead to fatigue fracture
of vibrating piping, over-stressed threaded connections, unsupported over-hung
weight, or exchanger tubes?
3. Contamination from chemical species that could cause stress corrosion cracking
(e.g., wet H2S, caustic, amines, chlorides, polythionic acids, ammonia) or
corrosion fatigue cracking of deaerators?
4. Exceeding the temperature or hydrogen partial pressure limits that might lead to
high temperature hydrogen attack in hydroprocess environments or accelerated
creep or other aging or embrittlement phenomena?
5. Rapid corrosion at or near an injection point due to addition or deletion of an
injection point, changes in flow rate, changes in flow patterns or other failure of
the injection system to perform as required?
6. Thermal fatigue cracking due to sudden or severe swings in temperature?
7. Severe corrosion downstream of alloyed equipment due to process upsets that
cause unneutralised corrosive species or contaminants to be present in systems
with materials not specified for corrosive conditions?
8. Freezing temperatures causing rupture of piping deadlegs containing water,
especially in light hydrocarbon systems?
9. Excessive temperatures or hot spots that could cause rupture from short term
over-heating of furnace tubes, transfer lines, or catalyst containing vessels?
10. Liquid slugging in piping or flare lines that could cause hydraulic shock and
transient over-stress conditions?
11. Hot spots from improper tracing installation that could cause accelerated localized
corrosion?
12. Localized corrosion or cracking of heat-affected zones in sensitized stainless
steels?
13. Fouling or plugging of inlet or outlet piping of relief devices?
14. Increased temperatures or increased sulphur and H2S concentrations accelerating
corrosion rates in sour hydrocarbons service?
15. Hydrogen embrittlement or hydrogen blistering from increased concentrations of
H2S or cyanides?
16. Accelerated corrosion from increased concentrations of naphthenic acids in crude
oils or various distillation cuts?
17. Ammonium hydrosulphide or ammonium chloride salt deposition and resultant
corrosion rate acceleration with increased concentrations of ammonia, sulphides,
or chlorides or insufficient water washing?

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18. Sulphuric acid concentrations falling below critical limits due to process upsets or
changes causing accelerated corrosion?
19. Caustic cracking of bolted connections from small leaks of boiler feed water or
other caustic containing solutions? Caustic cracking of non-stress relieved
equipment from heat exchanger tube leaks or caustic carryover?
20. Temperature, pressure or other process changes that cause shifts in dew point
and therefore shifts in areas where corrosive compounds condense and accelerate
corrosion rates?
21. Introduction of moisture during process upsets or shutdowns that causes
increased corrosion rates in otherwise dry systems? Or the deletion of moisture in
systems otherwise dependent on moisture for protection against corrosion or
cracking?
22. Presence of molten salts or liquid metals that could cause very high rates of
corrosion or cracking?
23. Liquid carryover into gas streams or velocity changes of mixed phase streams
accelerating corrosion-erosion of elbows, tees and other areas subject to
turbulence (e.g. downstream of control valves)?
24. Accelerated corrosion by the activation or deactivation of a piping segment or the
installation of temporary facilities?
25. Changes in operating capacity or throughput that have not considered the impact
on relief capacity?
26. Changes in operating flow rates by adding or reducing pumping or compressor
rates that lead to accelerated corrosion?
27. Changes in process temperatures or idling of normal hot equipment that might
lead to accelerated corrosion under wet insulation?
28. Changes in pH or corrosion control measures that could lead to accelerated
corrosion or cracking?
29. Changes in feed compositions where trace amounts of certain species previously
provided corrosion inhibition?
30. Changes in water treating chemistry or procedures that accelerate water side
corrosion.
31. Steam cleaning of equipment containing caustics or amines that might lead to
cracking?
32. Changes in the monitoring or maintenance of cathodic protection systems that
could lead to accelerated corrosion of buried piping or storage tank bottoms?
33. Overstressing piping systems not designed with sufficient flexibility if higher
temperature fluids are introduced?
34. Overstressing or shocking brittle materials such as cast iron and aged or
embrittled steels?
35. Introduction of oxygen contamination in systems that are otherwise non-corrosive
in the absence of oxygen?
36. Changes in erosion rates due to catalyst carryover or changes in process flow
rates where solid phases are present?
37. Accelerated corrosion or cracking beyond piping spec-breaks that result from
process changes or upsets?
38. Overpressuring equipment or piping when using high pressures or positive
displacement pumps to unplug a line?

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