MECHANICAL INTEGRITY UPDATE

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Everett Hunt
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1 2012 RESEARCH & TECHNOLOGY FORUM Madison, WI MECHANICAL INTEGRITY UPDATE AT THE IRC AND BEYOND Daniel Dettmers Industrial Refrigeration Consortium University of Wisconsin - Madison

2 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

3 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 ) Pilot renewed for a second year into 2011 Extended administratively until fully national program became effective on November 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, followup, and monitoring

4 CHEM NEP INSPECTIONS NOVEMBER 2011 (COMPLETION OF PILOT) 259 inspections attempted, 229 opened 59% Programmed (NEP) 41% Unprogrammed, includes complaints, referrals, followup, 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 41% of selected facilities were ammonia refrigeration Cl Contrcr NH 3 Refrig Credit: George Yoksas, OSHA, Region V Program Manager for PSM

5 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

6 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

7 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

8 29 CFR (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

9 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

10 WHAT IS OUR RAGAGEP?

11 RAGAGEP FOR NH 3 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)? CGA (Compressed Gas Association)? Applicability to ammonia systems is suspect

12 IIAR BULLETIN 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.

13 IS NDT REQUIRED? 110: : The independent person should carry out such examinations and tests required to determine if the equipment is safe and recommend and necessary action : : 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 pressureretaining items after they have been placed in service by providing rules for

14 NB-23 Introduction: A05 purpose of the National Board Inspection Code (NBIC) is to maintain the integrity of pressureretaining 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.

15 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

16 SOON TOO ARRIVE? IIAR 5 - Start-up and Commissioning of Closed-Circuit Ammonia Mechanical Refrigerating Systems IIAR 6 Inspection and Maintenance of Closed-Circuit Ammonia Mechanical Refrigerating Systems?

-for-service Derived in part from ASME B31G Manual

17 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

18 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

19 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

20 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.

21 WHAT S NEW WITH NDT? New competitor to the radiometric profiler Portable x-ray imaging Both good at finding ice/water Lixi Profiler TM OpenVision TM 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

22 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

23 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

24 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

25 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

26 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

27 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

28 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

29 QUESTIONS? Innovation Knowledge Progress

30 VISUAL INSPECTION PROGRAM PIPING & VESSELS

31 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

32 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

Fundamentals - Chapter 2 SSPC-VIS 2: Standard Method of Evaluating Degree of Rusting on Painted Steel Surfaces Gather

33 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

tagged valve, vessel, evaporator) Mark with flag or other tag that includes tag number that can be

34 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

35 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

36 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

The Electronic Newsletter of The Industrial Refrigeration Consortium Vol. 11 No. 4, 2011

chan The Electronic Newsletter of The Industrial Refrigeration Consortium Vol. 11 No. 4, 2011 PERSONNEL QUALIFICATIONS FOR PRESSURE AND LEAK TESTING In the last edition of The Cold Front, we discussed