Developing a Mechanical Integrity Plan

By: Duane Edwards

Acuren Inspection
Presenter

Duane K. Edwards
Sr. Engineer / Div. Manager

Over 30 Years Experience in the Chemical,

Petrochemical, Pharmaceutical and Refinery
Industries.
 Member of OSHA’s Technical Advisory Committee in the
development of 29 CFR 1910.119(j); Mechanical
Integrity.
 Technical Consultant for the EPA (State Level).

Current responsibilities
 Support company and client operations in the field of
mechanical integrity, corrosion and material selections.
 Active in client RBI programs.
Setting the Tone

Purpose of Presentation
 Guidance for setting up a mechanical integrity
plan.

 How to get started.

 What is needed.

 Who is needed.

Sources
 OSHA 29 CFR 1910.119(j)

 Industry codes, standards and recommended

practices.
Why Establish a “Plan”

• Governmental Regulations
Federal, State and Local
Jurisdictions

• Corporate and Site Standards

Mechanical Integrity Plan

Federal Regulations
 OSHA 29 CFR 1910.119(j)

“Mechanical Integrity”
• Condition of Process Equipment
• To Help Prevent Disasters
• Protect Our Environment
• Protect Our Environment
• Protect Our Environment
• Mechanical Integrity

Process Safety Management

Application Definitions Employee Safety Process Operating Training Contractors

Participation Information Hazards Procedures
Analysis

Pre-Startup Hot Work Management Incident Emergency Compliance Trade

Safety Review Permit Of Change Investigation Planning Audits Secrets
Response
Mechanical
Integrity

Application Written Process Inspection Equipment Quality

Procedures Maint. Training & Testing Deficiencies Assurance
P&ID Drawings
Maintenance Inspection of
Vessels Repair Deficiencies New Cons’t.
Maintenance Personnel Safety Process Equip.
In a Safe & Timely Suitable for
Storage Tanks Procedures Training in Potential
Follow Recognized Manner to Assure Process
Hazards
Piping Systems And Generally Safe Operation Applications
Up-to-Date
Accepted Good
Pressure Relief P&ID’s
Engineering Practices Appropriate
& Vent System
Checks are
Devices Inspection Frequencies
Performed
Emergency Shutdown
Proper Documentation
Systems
- Inspection Methods
Controls - Date of Inspection
- Inspectors Names
Pumps - Inspection Results
• Mechanical Integrity

Mechanical Integrity

Application Process Inspection

Written Maint. Training & Testing
Procedures
Vessels P&ID Drawings
Maintenance
Storage Tanks Personnel Safety
Maintenance Training in Potential
Piping Systems Procedures Hazards
Pressure Relief
& Vent System Up-to-Date
Devices P&ID Drawings

Emergency
Shutdown
Systems

Controls

Pumps
• Mechanical Integrity

Mechanical Integrity

Process Inspection Equipment Quality

Maint. Training & Testing Deficiencies Assurance

Inspection of Repair Deficiencies

Process Equip. In a Safe & Timely New Construction
Manner to Assure Is Suitable for
Follow Recognized Safe Operation Process Applications
And Generally Accepted
Good Engineering Appropriate Checks
Practices are Performed

Proper Documentation
- Date of Inspection
- Inspection Methods
- Inspection Frequencies
- Inspection Results
- Condition Assessment
• Team Effort

• Management

• Engineering/Inspection

• Maintenance

• Production

• Safety
• Evaluation/Audit

• Proper Record Keeping

 Separate record file for each piece of equipment.

 Data management software system.

 Past inspection records.

 Past repair records.

 Resolution to conflicts and issues.

• Know What You Have

• Equipment design parameters.

• Equipment materials of construction.
• Equipment fabrication –vendor surveillance
(QA/QC).
• Process conditions – normal and upset.
• History of equipment, including past inspection
data.
• Used equipment – previous history.
• Know The Process Conditions

• Normal and min/max pressure, temperature, volume

and flow rate.

• Continuous or batch operation;

If batch, “batch process mixing”.

• Develop a matrix of materials of construction,

contents, operating conditions, failure mechanisms.

• Forms of corrosion that could be present.

• Mechanical failures that could occur.

• Can upset conditions change the mechanism and/or

location of failure?
• Know What To Do Ahead of Time

• Appropriate cleaning procedures for inspection.

• Appropriate NDT methods for expected failure

mechanism.

• Develop an inspection frequency (internal & external)

based on procedures, RBI, past history, codes and
regulations.

• May need to alter inspection method and frequency

with significant operational changes.
• Know What To Do Ahead of Time

• Develop appropriate repair procedures for each

material/failure mechanism.

• After repair procedures – inspection method,

frequency.

• Equipment lay-up procedures (out of service) for

future use.

• Safety.
• Continuous Improvement

• New technologies (and participation in industrial

societies.

 NDT methods.

 New materials.

 New insight into failure mechanism.

• New code and standard mandates.

• New site specific mandates.

• New governmental regulations.

• Required inspector certifications.

• Governing Documents

• Applicable Codes, Standards, Recommended

Practices and Regulations
 API – American Petroleum Institute

 ASME – American Society for Mechanical

Engineers

 NBIC - National Board Inspection Code

 NACE International

 ASTM International (testing and materials)

• Governing Documents

 ANSI – American National Standard Institute

 ASNT – American Society for Nondestructive

Testing

 STI – Steel Tank Institute

 UL – Underwriters Laboratories, Inc.

 Governmental Regulations / Local Jurisdictions

• Getting Underway
“Three Phase Approach”

• Phase One
 All equipment used in government regulated hazardous
chemical & flammable processes.

• Phase Two
 All remaining process critical equipment.

• Phase Three
 Miscellaneous non-critical equipment.
• Inspection Plan

• Field Sketches/CAD Drawings

Tanks, vessels, piping systems.

• Establish Testing Locations

 Vessels - Heads, Shell, Nozzles
 Tanks - roof, shell, floor, apertures.
 Piping – vertical, horizontal, elbows, tees, reducers, deadlegs, etc.
 Pumps – vibration analysis, oil sampling.

• Proper Test Methods

VT, UT, RT, ET, MT, PT, AE, LT, PMI, etc.
• Field Sketching
• CAD Drawing
• Proper Test Method

• Material of construction.
• Surface condition.
• Operating condition (insulation, temperature).
• Accessibility.
• Knowledge and past experience of potential, or
existing problems (what’s and where’s).
• Previous and/or expected problem locations.
• Service specific.
• Potential for safety and environmental emergencies.
• Complexity of design.
• Corrosion Damage
• Corrosion Damage
• Corrosion Damage
• Corrosion Damage
• Corrosion Damage
• Mechanical Damage
• Mechanical Damage
• Mechanical Damage
• Mechanical Damage
• Mechanical Damage
• Mechanical Damage
• Mechanical Damage
• Two of the Most Common Problems Found

Lack of Maintenance
• Two of the Most Common Problems Found

Maintenance/Inspection Damage
• Documentation

• Static Information
• Inspection Data
• Calculations
 Minimum thickness (internal, external and differential
pressure).
 Corrosion Rate (long & short term).
 Remaining Life.
 API-579 (Fitness-for Service).
• Repair Records (Welding, Materials).
• Certification/Calibration Records (Inspection).
• Static Information
• Static Information
• Static Information
• Static Information
• Inspection Data
• Inspection Data

• Review Data
 Does collected data meet the code and regulations?

 Is more data needed?

 Was “suspicion” data verified? (static or collected)

 Should additional test locations be added?

 Should other test methods also be performed?

 Is there sufficient data to determine condition?

• Data Analysis

• Perform Required Calculations

 T-min.

 Internal pressure?

 External pressure?

 Differential pressure?
 MAWP
 Corrosion Rates (continuous or batch service?)
 Long term
 Short term
 Expected Remaining Life
• Data Analysis
• Data Analysis
• Eddy Current
• Radiography
• Radiography
• Radiography
• Reports

• Equipment identification.

• Inspections conducted and the results.

• Date of inspection.

• Who performed the inspection (certifications on file).

• Data analyzed.

• Calculations performed.

• Required and/or recommended actions.

• Choice of Actions

• Vessels (heads, shell courses, nozzles/Manways,

internal piping).

 Does it need to be repaired, replaced or re-rated?

 If re-rating is chosen, can production continue using

it?

• Tanks (roof, shell courses floor, apertures, internal

piping).
 Repair or can it continue to be used at a lower fill level?

• Piping
 Should a different material of construction it be used or
can it be replaced “in-kind” with a heavier scheduled wall?
• Repairs

• Required or recommended?

• Permanent repair
 Does it meet code?

 Was the proper material used?

 Was it inspected and found acceptable?

 Was it documented?

• Temporary repair
 Length of time????

 Often become forgotten and become permanent.

• Temporary ?
• Repair Documentation
• Repair Documentation

• Welding
 Were proper welding procedures used?

 Were welders certified to the procedures used?

• Inspection
 Were the repairs inspected?

 Were the proper inspections performed?

 Were the findings acceptable?

• In Summary

• Must get full support.

• Develop a team.
• Decide who is responsible for what.
• Decide if risk-based inspections (RBI) API-580 will be used.
• Decide what process equipment (Phases 1, 2 & 3).
• Collect all static data, drawings and historical records.
• Decide on the testing methods to be used.
• Decide how information will be stored and inspections reported (electronic,
hardcopy).
 If electronic; what software to use (engineer, data management,
CAD).
 If hardcopy; how and where to store the information.
• Knowledge of Federal, State and Local Regulations.
• Stay up-to-date with applicable codes, standards and company
engineering practices.
• Resource Contact

Duane Edwards
Sr. Engineer/Division Manager
Acuren Inspection
Newark, Delaware
Office Phone: 302-836-0165
Mobile Phone: 302-750-6335
FAX: 302-836-0166
Email: dedwards@acuren.com