API RP 578 - Analytical Training Consultants

Jakob Armstrong | Download | HTML Embed
  • Aug 8, 2013
  • Views: 33
  • Page(s): 53
  • Size: 3.68 MB
  • Report



1 Understanding the Advantages and Limitations of a Comprehensive API-RP 578 Positive Material Identification (PMI) Program Don Mears Oil & Gas Industry Consultant & API/TPCP Certified Training Provider Downstream Refining Sector Downstream Petro Chemical Sector Upstream Offshore & Transportation Sector 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 1

2 Presenter Don Mears API/TPCP -0118 President of Analytical Training Consultants (ATC) 30+ years of Oil & Gas industry experience Heavy involvement in API work groups Author of the API RP 578 PMI Certification Course Certified API Training Provider Oil & Gas Industry Consultant for Thermo Fisher Scientific 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 2

3 Presentation Outline Technologies XRF & OES for Refining Solutions PMI Field Testing Methods (XRF) Old & New Technologies New Construction QA/MVP Programs Renewed & Required Existing Piping Systems (Retroactive PMI ) Programs & Applications Control of Incoming Materials & Warehouse Elements of Maintenance Systems for PMI Recording & Reporting PMI Test Results Why the USA Implemented OSHA NEP & API 578 PMI Why the USA implemented OSHA CHEM/NEP & BSEE, PHMSA/NTSB Conclusion (Questions & Answers) 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 3

4 Understanding the Advantages and Limitations of a Comprehensive API-RP 578 Positive Material Identification (PMI) Program Downstream Refining Sector Don Mears Oil & Gas Industry Consultant and API/TPCP Certified Training Provider 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 4

5 PMI Field Testing Methods ( XRF or OES ) Technologies: Two Primary Technologies for Portable Elemental Analysis: X-ray Fluorescence Spectroscopy (XRF) Technique of exciting and ejecting atoms inner shell electrons with x-ray radiation and analyzing the fluorescent x-rays emitted when the atoms return to a stable state. X-ray energies emitted correspond to the individual elements, while the intensity is a function of quantity Optical Emission Spectroscopy (OES) Technique of vaporizing sample surface and analyzing the emitted light spectra. The wavelength of the light corresponds to the elements present, while the intensity is a function of quantity of that element. 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 5

6 X-Ray Fluorescence (XRF) A Simple Overview - K x-ray - - - L x-ray 1.25% Cr 1. X-ray ejects K-shell electron 0.5% Mo - - - - - K - L M-shells Alloy 2. L-shell electron moves to replace ejected K-shell electron, M-shell - - - Grade P11 electron replaces L-shell, etc - 4. The x-ray energies and fluxes are interpreted by the analyzer into the 3. Reduced energy state is given off as a K, corresponding elements, L, etc. x-rays, the energies of which are read concentrations, and resultant alloy by the detector grade 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 6

7 PMI Field Testing Methods: How OES Works Emission-Radiated in form of Light!! Excitation- O uter Shell 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 7

8 PMI Field Testing Methods ( XRF or OES ) Technologies: Pros: Handheld X-ray Fluorescence Spectroscopy Accurate Portable the handheld XRF analyzer weighs approximately 1.3 kg (3 lbs.) and is transported in a belt holster at the users side Reduced sample preparation Completely nondestructive Simplicity XRF technology is much more user-friendly, allowing relatively unskilled operators to participate in the inspection process Cons: Can measure elements only down to Mg on the periodic table (cannot measure carbon) Stricter regulation and licensing requirements 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 8

9 PMI Field Testing Methods ( XRF or OES ) Technologies: Pros: Transportable Optical Emission Spectroscopy Accurate Gives visible clue that material has been tested (burn mark) Can measure more light elements than XRF (such as C) Cons: Difficulty of transport OES instruments tend to be large and unwieldy, posing access problems in hard- to-reach locations Sample preparation the OES testing requires careful preparation of the sample by grinding off the oxide layer and eliminating any pitting or inclusions in the test area prior to analysis Damage to the sample the OES test burns and vaporizes a small amount of the sample material, resulting in a heat-affected zone that in some cases must be re-heat treated User expertise OES instrumentation requires a high level of user sophistication to maintain calibration, recognize data anomalies, proper surface preparation, etc. 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 9

10 XRF Evolution in Performance Since late 1960s, XRF has evolved through 7 generations; each generation has added new measurement capabilities as indicated by the 3 groups below Smaller, faster, better performance, and easier to use Today, nearly all alloys can be tested with these powerful tools. This addresses PMI concerns in the upstream/downstream & transportation Sectors Measures (up to 30 ) Measured (1) element at a Measured (16 to18 ) elements at a time to: time to: elements at a time to: >/= 0.003% chemistry >= 1.00% chemistry in >= 0.10% chemistry in /= 1 to 2 minutes

11 New GOLDD Detector Technology Geometrically Optimized Improved system geometry to reduce the path length from sample to detector Allows ~2X more x-rays to reach the detector with the power Large-area Drift Detector Light element detection in air (Mg, Al, Si, P, S) Increased sensitivity for tramp and trace elements in alloys Doubling of the speed of alloy and metals testing Enhanced performance for difficult (nearly twin) alloy separations 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 11

12 How Filters in XRF Automatically Work the Element Range in the Periodic Table Light Filter engaged Low Filter engaged Automatically for : Automatically for : S, P, Si, Al, Mg Ti ,V , Cr Main Filter engaged Automatically for : All Elements 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 12

13 XL3t GOLDD + Limits of Detection in PPM (mg/Kg) Time 60s per filter w/out He AI-based Ti-based Fe-based Cu-based Matrix Alloys Alloys Alloys Alloys Sb 20 35 50 70 Sn 15 30 50 70 Pd 15 20 40 55 Ru 15 15 20 20 Mo N/A 15 15 15 Nb N/A 15 15 15 Zr N/A 15 15 15 Bi 15 15 15 30 Pb 15 15 40 35 Se N/A 15 20 20 W 20 75 120 100 Zn 15 20 40 220 Cu 25 40 70 NA Ni 30 75 100 110 Co 30 70 500 110 Fe 50 175 N/A 175 Mn 70 160 160 175 Cr 50 160 35 65 V 20 550 25 40 Ti 20 N/A 30 30 S N/A* N/A N/A* 90 60* N/A NI'A* P N/A* N/A N/A* 110 65* 110 75* Si 400 320* 900 350* 350 175* 350 200'" AI N/A N/A* 4750 1300* 2200 650* 2500 625* Mg 4000 1500" N/A N/A* N/A N/A* N/A N/A* 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 13

14 New Construction: PMI Cycle Overview Renewed & Now Required Emphasis Residual elements found in carbon steel (i.e., Cr, Cu, NI, Mo, V, Ti) MTRs normally do not test for these elements and should not be Asset Recovery in the carbon steel ! Asset Management But they are there!!! 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 14

15 New Construction: Do Not Rely Solely on Supplier MTRs Experience has shown that you cannot rely on material test reports (MTRs) alone; there can be significant errors. One customer site survey revealed that as much as 40% of MTRs did not match actual chemistry. They also tend to lose the reports. They get separated from the existing material. API RP-578-(7.2)-States; MTRs Should NOT be considered a substitute for PMI testing Trust but verify This is what PMI does !!! 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 15

16 Existing Piping Systems (Retroactive PMI ) Programs: API RP 578 Material Verification Program for Existing Piping Systems Responsibilities The owner/user is responsible for determining if a retroactive material verification program is appropriate for each existing piping system, for prioritizing the piping systems to receive retroactive PMI testing, and for determining the extent of PMI testing required. Prioritizing piping systems for retroactive PMI testing If owner/user elects to prioritize piping systems for the material verification program or needs to determine whether PMI testing is needed at all, the owner/user should consider the following: Likelihood of a material mix-up during previous project and maintenance activities. Consequences of a failure. Some factors to be considered include: flammability, fire potential, toxicity, proximity to other equipment or community, temperature, pressure, mode of failure, and size of release. Reason for alloy specification (i.e., corrosion resistance or product purity). Historical data relating to inadvertent material substitution. This may be related to previous experience with material nonconformities in the process unit or within the operating plant. 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 16

17 Existing Piping Systems (Retroactive PMI) Programs : API RP 578 CIU High Temperature Remote Access (450F /232C to 900F/482C) Retroactive PMI Retroactive PMI PMI Valves, Pipes, Fittings, & CCD Camera with Small Weld Dilution Instruments Spot for Welds Retroactive PMI 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 17

18 Existing Piping Systems (Retroactive PMI) Programs Priority for API 578 2nd Edition: Residual Elements in Carbon Steels in Hydrofluoric Acid Alkylation Units Note: Carbon steels in HF acid service have been reported to suffer increased corrosion rates based on the residual elements (RE) in steels. In general, it has been reported that steels with a high RE content are likely to suffer enhanced corrosion attack. Operators should review the potential impact of this in HF service. A guideline is that for base metal of C> 0.18% wt% and Cu + Ni + Cr, 0.15% wt % is optimum. These values are critical as the type and concentrations to be measured will directly affect the analytical methods operations need to adopt. API RP 571 Pages 12,38 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 18

19 Existing Piping Systems (Retroactive PMI) Programs Priority for API RP 578 2nd Edition High Temperature Sulfidic Corrosion API RP 939-C Process units susceptible to sulfidation: Carbon steels with low silicon (0.10%) content can corrode at an accelerated rate Assets at risk from this type of degradation should apply PMI control to determine silicon levels. (Retroactive PMI is suggested and to follow API 578.) See API 571 and API RP 939-C See Section 7.1.4 & 5 Low Si-33%, PMI-18%,Specification Break-17% 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 19

20 API RP-939-C shows Corrosion rate of Low Si in Carbon Steel 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 20

21 Measuring Low Si in the field has some Requirements Current Technologies both ( XRF/OES) have limits for the Process Temperature Range. Proper Sample preparation is required. Most material of concern for Sulfidation is Carbon Steel piping installed before 1985. This material was usually double/tripled stamped ( A53/A106/API 5LB,& A285 Plates ) Typically, fittings have higher Si content where piping straight runs have less Si. Specification breaks are also a contributing factor ( 5Cr welded to 9Cr ) Other Concerns for high temperature process ( 650 F and greater ) is using 5 Cr and 9Cr with both low Cr & Si. 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 21

22 Sample Preparation for Low Si Measurement Typical metal alloys used in the petrochemical industry will oxidize when exposed to atmospheric conditions. This oxide coating can affect the accuracy of the reading when performing an XRF analysis and must be removed. Sample contamination can occur if you prepare with the wrong abrasive disc. It is recommended to use grinding discs made from zirconium aluminum oxide. Zirconium is a metal not commonly found in steel alloys, so trace amounts found on the surface will not negatively affect test results. As a recommended starting point, the following grit sizes are suggested: Stainless Steel 120 grit Cr/Mo Steel 80 grit Carbon & Low Alloy Steel 60 grit. Rubber backing wheel Abrasive discs Handheld, right angle grinder 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 22

23 Control of Incoming Materials & Warehouse: API RP 578 MVP should be associated with receiving alloy materials PMI testing may be performed as part of the receiving function PMI could be performed at suppliers location as a condition of release of shipment MVP should provide proper documentation & methods for indicating which materials have been tested and re-approved for use. MVP should be regarded as a quality assurance practice PMI testing in the warehouse should not be regarded as alternative to field PMI testing 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 23

24 Elements of Maintenance Systems for PMI: API RP 578 Temporary removal of spool pieces needs to be managed in such a way that material mix-ups cannot occur. Consideration shall be given to a firm control system A verification prior to re-Installation to prevent mix-ups occurring Tagging spools as they are removed to ensure correct replacement should be considered PMI after the repair procedures to confirm proper alloys were used PMI may also include components used Consulting with the inspector prior to commencement of work can ensure good material control was enforced 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 24

25 Elements of Maintenance Systems for PMI: API RP 578 Carbon steel elbow in a resid hydrotreater unit (RHU) heat exchanger outlet pipe (Elbow 1) ruptured after operating only 3 months in high-temperature hydrogen service. NO PMI performed and elbows removed without marking or tagging ! 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 25

26 API 560-Refractory Anchors Refractory metal is available in hex steel grid, special grid and expanded metal. All material is available in stainless steel and grades T304, T316, T310, T330 as well as all of the standard grades. Other refractory insulation and refractory lining products include wire mesh, expanded metal mesh and hex steel grid. Refractory anchors and related materials are used for anchoring and assembling refractory ceramic fibre linings or for reinforcing monolithic linings of castables, plastics or ramming mixes 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 26

27 API 560-Table 11 - Maximum temperatures for anchor tips Anchor material Maximum anchor temperature 'C (OF) Carbon steel 455 850 TP 304 stainless steel 760 1400 TP 316 stainless steel 760 1400 TP 309 stainless steel 815 1500 TP 310 stainless steel 927 1700 TP 330 stainless steel 1038 1900 Alloy 601 (UNS N06601) 1093 2000 Ceramic studs and washers > 1093 > 2000 PMI Confirms the Correct Material is Installed for the Correct Temperature. 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 27

28 Refractory Fiber PMI Inspection Possibilities What are you doing currently to confirm the correct Refractory Material is being use? How do you confirm on Turn- a-rounds and Maintenance the correct Refractory Material is properly replace ? 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 28

29 Recording & Reporting PMI Test Results: API RP 578 Material Certifications: (7.2) Material Certifications, mill test reports, or Certificates of Compliance should not be considered a substitute for PMI testing, but may be an important part of an overall quality assurance program. Shop and Field PMI Test Documentation: (7.3) Those individuals performing PMI testing should obtain and follow the PMI test procedure approved by the owner/user. This procedure should cover the techniques used , equipment calibration, the qualification requirements of the PMI test personnel, the testing methodology, and documentations requirements. When documentation, such as drawings, is used in lieu of physical marking, the documentation should allow the owner/user to identify which components were tested. New and Existing Piping Systems Documentation: (7.4) When PMI testing is conducted on new or existing piping systems, records of the results should be kept as long as the piping system exists in its original location. If a piping system or a portion of a piping system that has not received material verification is relocated, the owner/user should consider the need for PMI testing prior to placing the relocated components into service. 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 29

30 Recording & Reporting PMI Test Results: API RP 578 Traceability to field components-(7.7)-the information listed in PMI Test Records-(7.5) should be reported in such a manner that they are traceable to the point of installation. The best way to tie the Report Documentation to the field P&ID or ISO drawings, is to mark the drawings (electronically or manually) and enter this (drawing number) in the XRF/OES analyzer. It is strongly suggested that you keep both paper and electronic files on this documentation. PMI PMI Enter data into analyzer Interface with Data Management Software PMI (i.e., PCMS, Ultra-Pipe, Meridian, Solid AIM & RBI software) PMI PMI PMI 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 30

31 Why OSHA Established the NEP Program in USA? Occupational Safety and Health Administration (OSHA) Acts Process Safety Management (PSM) 1910-119-Highly Hazardous Chemicals (HHC) 2/24/1992 Refinery National Emphasis Program (NEP) CPL 03-00-004 6/7/2007 Chemical National Emphasis Program (NEP) 09-06 (CPL 02) Notice Pilot NEP 7/27/2009 Chemical National Emphasis Program ( CHEMNEP) (CPL 03-00-014)-Nationwide 11/29/2011- ( Replaced Pilot NEP) American Petroleum Institute (API) Standard-API 570 Piping Inspection Code Standard-API 510 Pressure Vessel Inspection Code Standard-API 653 Storage Tank Inspection Code Recommended Practice-API RP-578 Material Verification Program-MVP/PMI Recommended Practice-API 571 HF Corrosion in CS Pipes ( REs, Cr, Cu, Ni ) Recommended Practice-API 939-C Guidelines for Avoiding Sulfidation Mechanical Integrity Needs in the Oil & Gas Industry Understanding HOW, WHY, and APPLYING: ATC API 578 PMI Certification Training Course AIM Asset Integrity Management MI Mechanical Integrity Requires Data Management Software 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 31

32 API 578 RP 578 PMI Certification Course Guidelines & Application Procedures for Positive Material Identification (PMI) with XRF & OES Technologies Analytical Training Consultants Don Mears, Author API/TPCP -0118 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 32

33 Why?: Corrosion Failures in Process Piping 41% of the largest losses in the hydrocarbon processing industry resulted from failures in piping systems. Corrosion is one of the leading causes of piping failures. OSHAs National Emphasis Program (NEP) includes positive material identification (PMI) as a part of Mechanical Integrity (MI) Recognized And Generally Accepted Good Engineering Practices or RAGAGEP RAGAGEP example for PMI: API RP 578, Material Verification Program for New and Existing Alloy Piping Systems, Section 4.3 CSB, Safety Bulletin Positive Material Verification: Prevent Errors During Alloy Steel Systems Maintenance, BP Texas City, TX Refinery Fire Second International Symposium on the Mechanical Integrity of Process Piping January 1996, Houston, TX, USA 8/8/2013 33 API Beijing-Don Mears-ATC-9/13/213

34 Reasons Why RAGAGEP Is Required by OSHA Recognized And Generally Accepted Good Engineering Practice (RAGAGEP): API RP 578 Engineering, operation, or maintenance activities based on established codes, standards, published technical reports or recommended practices (RP) or a similar document. RAGAGEPs detail generally approved ways to perform specific engineering, inspection or mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or servicing a relief valve (See CCPS [Ref. 33]). 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 34

35 Hazards Identified: Total Violations RiseSerious and Repeat Violations Increase % 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% Total Willful Violations 404 462 747 479 415 2.7 Total Repeat Violations 2,147 2,360 2,350 2,551 2,714 26.4% Total Other-than-Serious 20,552 21,705 20,819 19,246 18,331 -10.8% BP Texas City, Texas: Fined $30.7 million for 439 willful violations on 10/30/09-Resolved 409 citations in July 2012 and paid $13 million by end of year ! 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 35

36 Hazards Identified: Total Violations Increase 2010 The significant increase over previous fiscal years is partly attributed to the large number of willful violations that were issued to BP North America and BP Huskey in FY 2010 %Change OSHA Violation Statistics FY2006 FY2007 FY2008 FY2009 FY2010 2006- 2010 Total Violations 83,913 88,846 87,687 87,663 96,742 15.3% Total Serious Violations 61,337 67,176 67,052 67,668 74,885 22.1% Total Willful Violations 479 415 517 401 1,519 217.1%6 Total Repeat Violations 2,551 2,714 2,817 2,762 2,758 8.1% Total Other-than-Serious 19,246 18.,331 17,131 16,615 17,244 -10.4% 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 36

37 Inspection Scheduling by OSHA All Refineries Section E-10 Positive Material Identification (PMI) Does the employer ensure that replacement piping is suitable for its process application? Yes, No, N/A If no, possible violations include: The employer did not follow RAGAGEP when it failed to conduct positive material identification (PMI) testing. Example RAGAGEP for PMI: API RP 578, Material Verification Program for New and Existing Alloy Piping Systems, Section 4.3) CSB, Safety Bulletin Positive Material Verification: Prevent Errors During Alloy Steel Systems Maintenance, BP Texas City, TX Refinery Fire 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 37

38 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% 89.6% H Contractors 2.8% 92.5% G Training 2.7% 95.2% Emergency Planning & N 1.5% 96.7% Response C Employee Participation 1.4% 98.1% I Pre-startup Review 1.1% 99.2% K Hot Work Permit 0.8% 100.0% 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 38

39 Understanding the Advantages and Limitations of a Comprehensive API-RP 578 Positive Material Identification (PMI) Program Downstream Petro Chemical Sector Don Mears Oil & Gas Industry Consultant and API/TPCP Certified Training Provider 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 39

40 Chemical Safety Board (CSB) Established in1990 After the deadly 1989 explosion of Phillips Houston Chemical Complex that claimed the lives of 23 people in Pasadena, Congress setup a system designed to reduce the number of chemical accidents by forming the investigative board, known for short as CSB. Congress established the board to overhaul the Clean Air Act and to create an independent agency designed to keep tabs on the chemical and petroleum industry. According to the findings of the U.S. Chemical Safety and Hazard Investigation Board, since 1998 an average of five plant workers have been killed every month in the United States by explosions or leaks of chemicals that have become integral to modern industrial life. 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 40

41 Thermo Scientific Niton XRF Analyzers in Downstream Process-Petro Chemical Plants CSB Chairperson Rafael Moure-Eraso said, "We are seeing too many ammonia releases in our daily incident reviews. Based on the CSB's monitoring of media reports there were four high consequence incidents involving the release of anhydrous ammonia which led to a total of six fatalities in 2009: May 14, 2009: American Cold Storage, Louisville, KY 2 fatalities June 20, 2009: Mountaire Farms, Lumber Bridge, NC 1 fatality July 15, 2009: Tanner Industries, Swansea, SC ? fatality November 16, 2009: CF Industries, Rosemount, MN 2 fatalities Therefore; OSHA Released :Chemical National Emphasis Program ( CHEMNEP) (CPL 03-00-014)-Nationwide 11/29/2011 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 41

42 OSHA-PSM Covered Chemical Facilities National Emphasis Program-CPL-03- 00-014, 11/29/2011 This instruction cancels-OSHA 10-05( CPL 02 ) Pilot Program of 7/27/2009 It has 2 facility Categories: 1) Ammonia/Refrigeration, 2) All other Chemical Plants with Highly Hazardous Chemical ( HHC)-CPL-02-02-045, PSM Guidelines and Enforcement Procedures. ( excludes: VPP and SHARP Facilities). Emphasis on Process Safety Management (PSM)- Implementation Enforcement Facility Documentation will be required by the inspection team of OSHA. The inspection will contain the following : Initial Walk around-Looking for differences in PSM document and has discussion with operation Inspection of Selected Units or Plants to observe operations, inspection, MI, construction , Contactors, etc. Compliance Guidelines, review inspection History & Abatement for previous 6 years to see if hazard still exist. You Say you practice PSM Show me you Do it!!!! Implementation 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 42

43 OSHAS Inspection Comes for a Dynamic List This list-based evaluation is a gap analysis formatted in a series of questions that have been developed to assess and verify the employers PSM compliance with specific issues such as design, fabrication, installation, start-up, operation, maintenance, change, controls (engineering and administrative), safe work practices, contractor safety, etc., at the facility by examining a Selected Unit. Abatement Requirements include the following: Management system/program requirements e.g., the employer must develop mechanical integrity program procedures that include piping inspection procedures,1910.119(j)(2), and Specific employer action/task abatement requirements - e.g., the employer must inspect the piping, 1910.119(j)(4).(Inspections and tests shall be performed on process equipment.) and (Inspection and testing procedures shall follow recognized and generally accepted good engineering practices-RAGAGEP RAGAGP according to OSHA includes PMI inspection according to API578 Procedures 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 43

44 Chemical Plant NEP Citations by PSM Element % of PSM Element Description Citations Cumulative % j Mechanical Integrity 23.8% 23.8% d 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 3.4% 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 1.0% 100.0%

45 Understanding the Advantages and Limitations of a Comprehensive API-RP 578 Positive Material Identification (PMI) Program Upstream Offshore & Transportation Sector Don Mears Oil & Gas Industry Consultant and API/TPCP Certified Training Provider 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 45

46 PMI Inspection Program for Deep Water Sub-Sea Equipment Important Before Installation Confirm with PMI that your material is in specification before Fabrication. Confirm all supply parts (valves, flanges, pipes, welds, etc.) are what is specified for application. 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 46

47 Portable XRF Analyzers in Upstream Process Hard Banding Applications Re-applying hard band-test with XRF 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 47

48 Bureau of Safety and Environmental Enforcement BP/Transocean/Halliburton Macando Well on 4/20/2010 (11) Fatalities and Gulf Coast PollutionStill ongoing court cases! 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 48

49 PHMSA Issued Advisory Bulletin 09-01 May 21, 2009 This bulletin advises pipeline operators of material problems inconsistent chemical (PSL 2 specifications) and material properties (yield strengths & tensile strengths) that have been found in micro alloyed high-strength line pipe grades, generally grade X-70 and above. Some pipe material did not meet the requirements of the American Petroleum Institute, Specification for Line Pipe5L, (API 5L), 43rd edition for the specified pipe grade even though the pipe supplier provided documentation that the pipe met these minimum standards. ( MTRs) It suggests that pipeline operators closely review manufacturing specifications for the production and rolling of steel plate. Trust by Verify with PMI 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 49

50 API 5L-Table 5 Chemical Composition for PSL 2 Pipe with t 25,0 mm (0.984 in.) Element Table 5 Percentage Min or Max Table 5 Annex-N adopted ISO 3183 for PMI/XRF analyzers can confirm these (except Europe Addendum 3 effective boron) min/max, specs date 1/1/2012 Copper (CU) = 0.50% Max No Change Nickel (Ni) = 0.30% Max Ni = 1.00% Chromium (Cr) = 0.30% Max Cr = 0.55% Molybdenum (Mo) = 0.15% Max Mo = 0.80% Sum (Nb + V)

51 Reasons Why RAGAGEP? Recognized And Generally Accepted Good Engineering Practice (RAGAGEP): API RP 578 Engineering, operation, or maintenance activities based on established codes, standards, published technical reports, or recommended practices (RP) or a similar document. RAGAGEPs detail generally approved ways to perform specific engineering, inspection, or mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or servicing a relief valve (See CCPS [Ref. 33]). 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 51

52 The Department of Labor of the United States of America (USDOL) and The State of Administration of Work Safety of the Peoples Republic of China (SAWS) https://www.osha.gov/international/index.html China May 27, 2011 Memorandum of Understanding between the Department of Labor of the United States of America and the State Administration of Work Safety of the People's Republic of China Regarding Cooperation on Work Safety and Health [PDF*] Enforcement of laws and regulations on workplace safety and health; Emergency response procedures generally applicable to workplace accidents and incidents; The role of private insurance programs in the promotion of workplace safety and health; Public awareness raising of workplace safety and health laws and regulations; Effective collection and analysis of workplace safety and health data; and Regulation and inspection relating to the production, handling and distribution of hazardous chemicals. 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 52

53 Questions & Answers? Don Mears Analytical Training Consultants & Thermo Scientific Portable XRF Analyzers 1719 Burning Tree, kingwood, Texas ( USA) 77339 Web: www.ATC578.Com [email protected] or [email protected] Phone: +1 (281) 684-8881 Portable XRF Analyzers API/TPCP -0118 8/8/2013 API Beijing-Don Mears-ATC-9/13/213 53

Load More