“Codes and Specifications for Minimizing Corporate Risk” NDT MGMT SESSION 11
February 13, 2014
Las Vegas, Nevada
• Positive Material Identification (PMI) For: • Downstream Refining Sector • Downstream Petro Chemical Sector • Upstream Offshore & Transportation Sector
Don Mears GE M&C Inspection Technologies, Consultant &
API/TPCP Certified Training Provider
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Presenter: Don Mears
President of Analytical Training Consultants Oil & Gas Industry Consultant for GE Oil & Gas-Inspection Technologies
Author of API RP 578 2nd Edition PMI Certification Course
Certified API Training Provider Certification TPCP# 0118
30+ Years in the Oil & Gas Industry
API Member and Sub-Committee Member on API Inspection Summit
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Presentation Outline: • Introduction- Why Implement PMI According to API RP 578 • Downstream Sector-Refining-OSHA NEP • Downstream Sector-Petrochemical-OSHA CHEMNEP • Upstream Sector- Off Shore & Transportation-BSEE, DOT/
PHMSA,NTSB • API RP 578 –Testing Suggestions-Explained
– New Construction- QA/MVP Programs – Existing Piping Systems ( Retro-Active PMI ) Programs – Control of Incoming Materials & Warehouse – Elements of Maintenance Systems for PMI – Recording & Reporting PMI Test Results
• API 578 PMI Certification Course Advantage • Conclusion (Questions and Answers)
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Introduction: “Why should you implement PMI according to API 578 ?”
• Note: The leading insurance industry statistics indicating that the US refining sector has more than three times the rate of property losses of refineries overseas. • Dr. Moure-Eraso with USA Chemical Safety Board (CSB) urges companies to take action to prevent accidents, including:
– Implement a robust “mechanical integrity” programs with an emphasis on thorough inspections of critical equipment
– Monitor process safety performance using appropriate leading and lagging indicators to measure process safety “before major accidents” occur
– Maintain an open and trusting safety culture where near-misses and loss of containment incidents are reported and investigated
Close-up of ruptured heat exchanger
Aerial view of the damaged heat exchangers following the April 2, 2010 fire
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Introduction: “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. • OSHA’s 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” – 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
� Second International Symposium on the Mechanical Integrity of Process Piping January 1996, Houston, TX, USA
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Why OSHA Establish 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
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, & APPLYING:
ü ATC – API 578 PMI Certification Training Course ü AIM- Asset Integrity Management ü MI- Mechanical Integrity Requires, “ Data Management” Software
Don Mears
Oil & Gas Industry Consultant
Handheld X-ray Fluorescence for PMI & OSHA’s (NEP)-”National Emphasis Program” Downstream Refining Sector
“Codes and Specifications for Minimizing Corporate Risk”
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• According to OSHA’S refinery database:
• 36 fatality/catastrophe (FAT/CAT) incidents • Related to 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-12 FAT/CAT • Industrial Organic Chemical Manufaturing-12 FAT/CAT • Explosive Manufacturing-11 FAT/CAT
Why Did OSHA Establish the NEP Program in USA ?
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Hazards Identified: Total Violations Rise; Serious and Repeat Violations Increase
OSHA Violation Statistics FY2003 FY2004 FY2005 FY2006 FY2007 % Change 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 !
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Refinery NEP Enforcement Summery from 2007-20012
• Comprehensive-(151 Refineries in USA) • Average 1,000 OSHA hours per inspection
• Typically use full statutory 6 months available
• Also resource intensive for employers
• Compliance found to be highly uneven
• Substantial issues identified
• Average penalties/inspection ~$166,000
• Average penalty/violation ~$9,560
• 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% 89.6% h Contractors 2.8% 92.5% g Training 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%
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OSHA’S Reasons Why – RAGAGEP “Recognized And Generally Accepted Good Engineering Practice” (RAGAGEP):
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]).
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Inspection Scheduling by OSHA’s NEP – All Refineries Section E-10-Question on PMI
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
Don Mears
Oil & Gas Industry Consultant
Handheld X-ray Fluorescence for PMI & OSHA’s CHEM NEP- Downstream Petro Chemical Sector
“Codes and Specifications for Minimizing Corporate Risk”
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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.
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CSB Releases Case Study on Fatal 2008 Accident at Goodyear Tire and Rubber Plant in Houston, Texas
“Recognized And Generally Accepted Good Engineering Practice” (RAGAGEP): Is what OSHA/CSB require from our Petro Chemical Companies !!!!
The accident occurred on June 11, 2008, when an overpressure in a heat exchanger CSB identifies gaps in facility emergency response training and calls for increased adherence to existing industry codes. CSB Investigations Supervisor Robert Hall said, “We found the accident likely would not have happened had operators followed the ASME code” CSB investigations look into all aspects of chemical accidents, including physical causes such as equipment failure as well as inadequacies in regulations, industry standards, and safety management systems.
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XRF Analyzers in Downstream Process-Petro Chemical Plants
Phillips Petroleum Company’s chemical plant in Houston in 1999-OSHA said that failure to train workers properly was a key factor in the explosion and fire Pesticide Chemical Runaway Reaction Pressure Vessel Explosion (Two Killed, Eight Injured) Bayer Crop Science, facility in Institute, West Virginia , August 28,2008 CSB Conducting Assessment of Ammonia Release at Millard Refrigerated Services South of Mobile, Alabama, August 27,2010
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 1 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
• As of August, 2010, 112 inspections opened • 38 Un-programmed (34%) • 74 Programmed (66%) • 9 resulted in no inspection occurring because there was no PSM covered
process • 62 inspections have issued citations
• Average 9.0 citations per inspection • Average $3,500 per citation
• Over 60 different standards cited
• 44% of all citations were other than PSM • Therefore: OSHA Released :Chemical National Emphasis Program
(CHEMNEP) (CPL 03-00-014)-Nationwide 11/29/2011
Chemical Plant NEP Inspections for Pilate Program in Regions (1,7,10)
Chemical Plant NEP Citations by PSM Element
Element Descrip.on % of PSM Cita.ons Cumula.ve %
j Mechanical Integrity 23.8% 23.8% d Process Safety Informa1on 20.2% 44.0% e Process Hazard Analysis 19.0% 63.0% f Opera1ng 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 Inves1ga1on 2.6% 97.6% i Pre-‐startup Review 1.4% 99.0% k Hot Work 1.0% 100.0%
Don Mears
Oil & Gas Industry Consultant
Handheld X-ray Fluorescence for PMI & BSEE,PHMSA, & NTSB- Upstream Offshore & Transportation Sector
“Codes and Specifications for Minimizing Corporate Risk”
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Also on October 1, 2011, the new Bureau of Safety and Environmental Enforcement (BSEE) was created to enforce safety and environmental regulations. Functions include: All field operations including Permitting and Research, Inspections, Offshore Regulatory Programs, Oil Spill Response, and newly formed Training and Environmental Compliance functions
WWW.BSEE.GOV
The Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMER) Changed to (BSEE)
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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.
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Pipeline and Hazardous Material Safety Administration
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PHMSA issued Advisory Bulletin 09-01 on 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 Pipe—5L, (API 5L), 43rd edition for the specified pipe grade even though the pipe supplier provided documentation that the pipe met these minimum standards. ( MTR’S) It suggests that pipeline operators closely review manufacturing specifications for the production and rolling of steel plate. ( Trust by Verify with PMI )
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API 5 L-(45th Edition) for Line Pipe Currently API 5L “Does NOT” stress Confirming the Chemical Analysis for Elements with Positive Material Identification (PMI) with either XRF or OES field Analyzers !!!! The Question is Why NOT?????: We have already shown you that the “ End User” can no longer rely only on ---Material Test Reports ( MTR’s)---- OSHA has a “Nation Emphasis Program” (NEP) to Enforce (RAGAGEP ) for the Market Segments in the Oil & Gas Downstream both Refining & Petro Chemical facilities and found that Mechanical Integrity (MI) is the number one Violation ( 19.4% to 23.8%) of “Process Safety Management” (PSM)- Process Safety Management (PSM) 1910-119-Highly Hazardous Chemicals (HHC).
“Trust but Verify” -‐ This is what PMI Does !!!
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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]).
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API RP 578 –Testing Suggestions • API RP 578 –Testing Suggestions-Explained
– New Construction- QA/MVP Programs – Existing Piping Systems ( Retro-Active PMI )
Programs – Control of Incoming Materials & Warehouse – Elements of Maintenance Systems for PMI – Recording & Reporting PMI Test Results
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New Construction- QA/MVP Programs
• New piping systems-Lay Down Yards
• Pipe fittings, valves & flanges • Welds & welding
consumables • Longitudinal pipe and weld
fittings • Weld overlays or cladding • Low Si in H & S Service • Components from distributors • Forgings • Instruments • Bolting • Expansion joints and bellows • HF Alky- Residual Elements
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Existing Piping Systems ( Retro-Active PMI ) Programs :
CIU Retro -Active PMI
Valves, Pipes, Fittings, & Instruments
CCD Camera with Small Spot for Welds
High Temperature (450F /232C to 900F/482
C ) PMI
Remote Access Retro -Active PMI
Weld Dilution Retro -Active PMI
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Control of Incoming Materials & Warehouse
– Should have a MVP 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 Quality Assurance Practice
– PMI Testing in Warehouse Should Not be Regarded as Alternative to Field PMI testing
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Elements of Maintenance Systems for PMI
– Temporary Removal of Spool Pieces Need 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
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Recording & Reporting PMI Test Results
Project No. Client: Report New ConstructionSupplier PO No. Report Existing PipingDistributor Contact Report Date:Visit Date Phone No. Shop Ref No.Draw ing No. OES Item Tag No.Model No. XRF Performed By:
R eading NoMaterial
D es c riptionG rade o f Material H eat No .
Material Verific ationE lement %
Material Verific ationE lement %
Material Verific ationE lement % A ccept R ejec t R emarks
Action Iterms for Non-Conformance Material:
API RP 578PMI REPORT FORM Traceability to Field Components; the information
listed in “PMI Test Records” 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.
Interface with “Data Management Software” (i.e. PCMS, Ultra-Pipe, Meridian, Solid AIM & RBI Software,Rythem)
Enter data into Analyzer
PMI PMI
PMI PMI
PMI
PMI
API RP 578 2nd Edition for PMI Certification Course & OSHA’s National Emphasis Program (NEP)- Adopted Internationally
“Codes and Specifications for Minimizing Corporate Risk”
Training Course Advantage Explained on
API RP-578 by
Don Mears Analytical Training Consultants
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Introduction to API 578 PMI Certification Course
Purpose of the API Course • To certify and re-certify (every 3 years) API inspectors, NDT Technicians and
designated key personnel in understanding and applying API RP 578 in the proper Use and Application of procedures for utilizing XRF and OES technologies for PMI.
TWO (one-day sessions) • Classroom instruction on API RP 578 2nd Edition guidelines • Hands-on PMI field testing procedures. • Understanding of API RP 578 Guidelines & Applications in the Field • Application of proper XRF and OES PMI testing procedures • Testing both Written on Academic's and Examination on Testing of Metals • American Petroleum Institute (API) Certification
In today's risk-based QC environment, the need for positive material identification (PMI) has grown dramatically in refinery and petrochemical plant operations, requiring 100% alloy material verification for designated critical components. Meets RAGAGAP requirements for OSHA,BSEE,NTSB,DOT,PHMSA
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Questions & Answers?
Don Mears Analytical Training Consultants & Consultant for: GE Oil & Gas, MC-Inspection Technologies. 1719 Burning Tree, kingwood, Texas ( USA) 77339 Web: www.ATC578.Com [email protected] or [email protected] Phone: +1 (281) 684-8881
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