It’s horrific to read about fires in refineries. Granted, process safety management (PSM) principles, with a greater emphasis on mechanical integrity (MI), have been embraced across the globe, greatly reducing the number of incidents. However, citations remain high, with the U.S. having the highest number of them. What’s the problem? A consistent implementation and application of MI. This article attempts to simplify the MI program, with the hope that organizations can achieve 100 percent mastery in avoiding incidents.
It’s puzzling how refineries work for years without incident and then suddenly, a news report of an explosion or fire. Whether it’s in the U.S., China, Russia, Europe, or other South Pacific countries, the scenario appears to be the same. The latest one occurred on April 26, 2018, when a series of fires and explosions rocked the Husky Superior Refinery in Wisconsin. According to reports, at least 15 people were injured.
A Troubling Situation
Under the expertise gained from decades of PSM and expert guidance from thousands of experts using so many techniques, like risk-based inspection (RBI); reliability-centered maintenance (RCM); reliability, availability and maintainability analysis (RAM); and root cause analysis (RCA), many organizations have reached the pinnacle of success. Yet, they fail in mastering 100 percent incident avoidance.
Is it the knowledge that is lacking? Has a risk-taking habit increased disproportionately? Is it the grandeur of success that also must show the inevitable doom?
Finding the answer is difficult and perhaps not worthwhile for organizations to pursue in finding one. So, they continue along a path of modesty, consistency and adhering to basic principles. “COME WHAT MAY!!”
The Regulatory Take on MI
The U.S. Occupational Safety and Health Administration (OSHA) regulates mechanical integrity this way:
“OSHA believes it is important to maintain the mechanical integrity of critical process equipment to ensure it is designed and installed correctly and operates properly." PSM mechanical integrity requirements apply to the following equipment:
- Pressure vessels and storage tanks;
- Piping systems (including piping components such as valves);
- Relief and vent systems and devices;
- Emergency shutdown systems;
- Controls (including monitoring devices and sensors, alarms and interlocks); and
“The employer must establish and implement written procedures to maintain the ongoing integrity of process equipment. Employees involved in maintaining the ongoing integrity of process equipment must be trained in an overview of that process and its hazards and trained in the procedures applicable to the employee’s job tasks."
“Inspection and testing must be performed on process equipment, using procedures that follow recognized and generally accepted good engineering practices. The frequency of inspections and tests of process equipment must conform with manufacturers’ recommendations and good engineering practices, or more frequently if determined to be necessary by prior operating experience. Each inspection and test on process equipment must be documented, identifying the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test."
“Equipment deficiencies outside the acceptable limits defined by the process safety information must be corrected before further use. In some cases, it may not be necessary that deficiencies be corrected before further use, as long as deficiencies are corrected in a safe and timely manner, when other necessary steps are taken to ensure safe operation."
"In constructing new plants and equipment, the employer must ensure that equipment as it is fabricated is suitable for the process application for which it will be used. Appropriate checks and inspections must be performed to ensure that equipment is installed properly and is consistent with design specifications and the manufacturer’s instructions."
“The employer also must ensure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used.”
Figure 1: Developing the workforce for MI implementation
So, based on OSHA’s requirements, the MI program can be simplified so that its implementation and application with consistency would be undertaken with unwavering interest year after year without falling into the trap of, “Oh, I Missed It.”
The simple solution is to assign the jobs and develop the workforce for MI implementation, as indicated in the pyramid in Figure 1.
It is a top-down approach. Two fairly senior people are selected, one who is good in coordination and the other excellent in engineering. Both of them work together to develop the managerial and technical path for implementation.
Although MI requires both inputs, the fact of the matter is that only two people implementing the approach in today’s complex refineries is practically impossible. So, next comes one more crucial list of 10 people, possibly one from each plant. Now, these 12 MI stewards take the implementation to realization within a period of six to nine months.
To start any MI program, the first and foremost requirement is the critical equipment/item list, which will be covered under this program. It simply may be the list as proposed under OSHA’s mandate.
The 12 MI stewards are tasked with ensuring that within a two-week time frame, the list of equipment/items covered under MI is ready.
Having overcome the base hurdle, the strategy for MI implementation is now a two-prong attack: Decide what is required preinstallation and what is required post-installation from the plant.
For preinstallation checks, refer to OSHA’s directive for new equipment/installation, as well as as-built drawings, manufacturing record books (MRBs) for pressure equipment/machinery, various test packs/construction records, etc. Make sure these materials have been fully reviewed and certified to contain all the information that assures quality of the equipment/item. This step will require experts from mechanical – inspection/rotary, electrical, instrumentation, civil, etc. All it needs is a concerted effort by one or two experienced experts to review all available documents and specifically look for any remarks giving some concessions or repairs, if any were carried out!
It may be slightly difficult to dig out this information for older plants built, say, prior to the 1990s, but the effort will have rewards of its own as the team would lay hands on deficiencies noted and develop the liquidation plan for the same.
People in levels 2 and 3 of the MI pyramid help develop the deficiency list, but for liquidation, the full organization should be available.
The treatment for post-installation of the plant (i.e., the operating plant) requires level 3 and 4 teams to be in place. It is here where a time period of six to nine months may be required so that all concerned are trained in the basics of mechanical integrity and everyone is engrossed in implementing the MI program in letter and spirit.
So now, the larger team takes this forward by developing plans to assure the continued integrity of process equipment. Elements of this phase of the mechanical integrity program have been covered in the previously noted OSHA requirement.
Here, inspection, the rotary group, maintenance, instrumentation, electrical and the civil group need to develop their own plans based on applicable codes and standards. Staff in levels 2 and 3 of the MI implementation pyramid will be able to develop the first draft document on inspections, tests and frequencies within three months.
The plan’s execution requires that tests and inspections are conducted properly and that consistency is maintained even where different employees may be involved. The appropriate training should be provided to various inspection staff and engineering discipline maintenance personnel that covers procedures, safe practices, and the proper use and application of special equipment or unique tools that may be required. This training is part of the overall training program called for in the standards.
Employees performing maintenance activities must be trained in the activity, as well as the hazards associated with that activity or maintenance procedure.
The phase of training can be completed in six months if there is focused attention and conscious efforts. Most organizations are adept in developing training modules and providing 40 to 60 hours of planned training. This training should be made available to all those participating in the MI program – the list of level 3 and 4 staff should be made available by the end of the first month of launching the MI program.
The key to success of an MI program is written procedures and its implementation. This task should be performed by level 3 and 4 people in a time span of six months. Start with 500 procedures to be written and then decide the team and time per procedure. The expert planner in the company would know how much time to allocate.
The start of an MI program is important, but if it is backed by planning and encouragement provided by management, the controls will automatically be in place and success will be achieved.