Post Turnaround Inspection Documentation

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Post Turnaround Inspection Documentation

Postby arcpro » 06 Jan 2015, 03:30

A recently published article on Inspectioneering and worth reading:

Oil refineries and petrochemical plants conduct turnarounds for a variety of reasons, such as scheduled maintenance, facility upgrades, or code compliance. Many equipment items are inspected before, during, and after the turnaround to ensure safe, efficient and reliable operations. Without sufficient, high-quality inspection, damaged or failing equipment can be improperly inspected, documented, or overlooked completely. Inspection services should include proper pre-turnaround inspection planning, turnaround inspections, and post-turnaround activities and documentation. In the March/April 2014 and July/August 2014 issues of Inspectioneering Journal, I covered pre-turnaround planning and turnaround inspection roadmaps. This article completes the series with the third and final installment covering post-turnaround inspection activities.

Post-Turnaround Challenges
One of the major challenges inspectors and plant operators face after each turnaround is to ensure that all repair and scope work is and was completed in accordance with the client’s requirements. Sometimes that verification will be to ensure work was completed in conjunction with the applicable codes, and sometimes that it was completed in conjunction with the client’s own in-house specifications. As inspectors discover additional areas of deficiency that need to be repaired or replaced, they issue repair recommendations (such recommendations were covered in Part II of this series of articles).

During post-turnaround, inspectors and operators must be confident that necessary repairs that were identified and approved were, in fact, undertaken and completed in cooperation with the applicable requirements of the code and the client’s specifications by conducting ongoing monitoring throughout the entire duration of the turnaround. Because most turnarounds involve hundreds of pieces of equipment that have numerous parts and seals, facility managers must have the appropriate manpower and skill set on the job to monitor and carry out all inspections required by the code and client specifications.

Another challenge involves the potential for leaks. As operations bring down each unit, they create blind/isolation lists, which involve disassembling flanged connections, creating isolation points, draining lines and vessels, and de-inventorying and cleaning everything subject to maintenance and Inspection. All vessels, exchangers, heaters, bypasses, and piping are opened, inspected per the Turnaround work scope, and designated as either sufficient for continued operation, in need of repair, or in need of replacement. New gaskets are typically installed and valves might be repaired or replaced.

During these routine turnaround activities, each of these access locations and isolation points typically contain gasket and bolting assemblies at the connections, so the potential exists for mistakes to be made by using improper gaskets and improper bolt tightening (or torqueing). Any particular unit could have, on average, hundreds of bolted and flanged connections with gaskets that are broken apart for the purpose of drying them out for the cleaning and maintenance activities during the turnaround. Every single one of those that are broken apart have to be put back together correctly or upon unit start-up it can and will likely leak. For example, with regard to flanged connections, even if the bolting is replaced and tightened and torqued correctly, the likelihood of a leak is very high if the wrong piping specification or the wrong type of gasket is installed.

In the industry, most owner-users have implemented quality control checks (hold points) at each of the flanges that were separated, requiring inspection to verify that the appropriate gasket has been installed, and that all bolted connections have been tested to ensure that they are secure and tight; so replacement and testing is an inherent challenge. In the units of petrochemical and chemical facilities, particularly in certain hazardous units such as hydrofluoric acid alkylation, phosgene or similar units, due to inherent hazards, one leak can cause life-and-death dangers to the people in the unit, the facility and the surrounding neighborhood, so quality control checks of flanges and broken connections are a critical part of post-turnaround inspections.

Inspectors can help alleviate dangers by ensuring absolute adherence to connection specifications. Every pipe system and every vessel has a particular gasket type that is rated and deemed by design to be suitable for each particular service. In fact, most gaskets are color-coded. Inspectors and maintenance personnel need to verify that the appropriate gasket is in place, has been installed correctly, and that the connection has been made properly and is tight. The bolt makeup and the flange tightness are absolutely critical to avoid leaks and should be an integral part of every post turnaround (pre-start-up) process. Most owner-operators have implemented and utilize a PSSR or Pre Start-up Safety Review process that encompasses the Inspection department’s verification of the reassembled flange connections and line breaks throughout the entire unit and sign-off prior to start-up of the unit by operations.

Post-Turnaround Documentation
After the turnaround, every vessel and every piece of pipe that falls within the turnaround scope that was predefined or defined during pre-turnaround activities, will have a report that has been issued or generated based on the activity that was conducted during the turnaround. These reports fall into three categories. The first category involves all equipment that was opened and inspected. In this category, everything that was found to be in suitable condition will require a report to be generated that documents what was found and what degree of corrosion or degradation exists, or the lack thereof. All of the particular variables that are documented should identify why the vessel is suitable to be placed back in service in its existing condition.

In the second category, equipment or parts that have been identified during the discovery phase of the inspections as needing repairs or replacement are covered. Such repairs requiring welding activities will require a litany of follow-up nondestructive examination (NDE) or supplemental NDE and subsequent documentation to maintain compliance with code and specification requirements. Examples of these NDE activities include, but are not limited to:

Conducting post-weld heat treatment
Determining the type of filler metal
Examining the welding procedures
Examining the welding processes
Examining the weld
Follow-up NDE statement of data following the repair that was done
Repairs or replacements of bolt-in type components such as internal piping or tray parts will require documentation as to the design and materials being used, as well as verification of bolt tightness of the newly installed components.

All of this data will be gathered throughout the course of that activity on that particular vessel, depending on what degree of repairs were conducted. Documentation should include the specifics and should be consolidated throughout the course of the turnaround so that at the end of the process, all of these different variables and activities will be captured in the final issued report (or at a minimum referenced). It is imperative that all activities are appropriately documented and supporting documentation is compiled and included within the final inspection reports and ultimately the owner operator’s equipment historical files for future use and planning, so that such data will be available to provide background and indicate corrosion/damage trending and the necessity for future inspections and future repairs.

The third category of post-turnaround inspection documentation includes equipment items or parts that were changed out that were not included in the turnaround discovery recommendations. Typically, these are vessels that had pre-planned work scheduled for them as part of the turnaround’s scope of work that required the same NDE, the same welding, the same or different variables to be tracked, monitored and consolidated during the course of the turnaround. These items should be packaged and documentation compiled in the same manner as described above so that all of that data can ultimately fall within the complete final report to be turned over and delivered to the owner-user at the end of the project for their retention.

Predictive Vs. Reactive
Typically, owner-users are utilizing one of two types of philosophies when it comes to evaluating inspection and corrosion monitoring (thickness) data gathered during turnaround inspection activities: reactive or predictive. The reactive model is typical of facilities that do not populate and evaluate the newly collected corrosion monitoring data on their equipment within their mechanical integrity database during the turnaround and most importantly prior to unit start-up. This happens for a variety of reasons, from shortage of inspection manpower to analyze the newly collected corrosion monitoring data in real-time during the turnaround, to an upper management and maintenance philosophy that prioritizes the shortest possible turnaround time in order to get the facility back up and running, which does not afford the necessary time to evaluate the data collected during the turnaround, which is meant to save time and money for the facility.

It is an unfortunate fact that in many facilities throughout the industry, equipment is unknowingly placed back into service pre-maturely, simply because the owner-operators could not or would not wait for the inspection data gathered to be appropriately analyzed. Subsequently, they must react to these possible corrosion problems that have been discovered in data analysis after the equipment has been placed back into service. This places undue burdens on the facilities’ inspection personnel who are then forced to closely monitor and manage the integrity of equipment in questionable condition, on-line, utilizing Risk Based Inspection analysis, Fitness for Service analysis, or Advanced NDE techniques to ensure their fitness for service.

For example, some corrosion cannot readily be seen with the naked eye. When an Inspector goes into a vessel, it can visually seem acceptable because he sees no pitting and no obvious localized corrosion or erosion locations. Therefore, the equipment can be initially approved visually to be returned to service. Yet, the equipment might contain aggressive corrosion that is very smooth and uniform in nature and simply cannot be easily seen through visual inspection alone.

During turnaround inspections, randomly and strategically acquiring thickness readings internally utilizing straight-beam ultrasonic testing can easily identify this type of accelerated corrosion and degradation. Moreover, performing these types of randomly and strategically selected thickness readings will serve to verify or validate the on-stream thickness data commonly being collected externally at CML’s while the equipment is in operation. But if that data is simply entered into paper folders, placed into hanging files, and stored in a filing cabinet until after the turnaround project is completed, a piece of equipment experiencing deterioration can be inadvertently placed into service, only to have to be removed from service shortly after because the data analyzed post turnaround revealed a corrosion problem that will not sustain the planned operation run of the unit.

Unfortunately, this happens far too often because many owner-operators simply do not believe they have the time or money to bring in additional staff to keep up with the corrosion monitoring data evaluation through the course of the turnaround. Therefore, such precise inspection data is not analyzed until after the turnaround has been essentially completed. Ironically, it can cost the owner-operator millions of dollars to shut one of these units down, to de-inventory it, and to make a piece of equipment available for inspection, repair, or replacement. To avoid such costs, the managers should strive to know about any potential corrosion problems that can be identified with the simple evaluation of the supplemental thickness measurements prior to unit start-up.

Conversely, the predictive model tends to be utilized by those owner-operators whose core of management, from the upper management down, want to find, evaluate, and fix everything that warrants repair during a turnaround, to ensure their equipment will run reliably through the entire duration of the planned operational cycle. This is true for most of the larger owner-operators and some of the smaller operators that have developed procedures that require all of the inspection data collected to be entered and evaluated within their corrosion monitoring databases and updated corrosion monitoring reports generated before each piece of equipment is signed-off for closure to be put back into service, and therefore before the turnaround is completed.

In fact, some owner-operators have well defined procedures within their mechanical integrity programs that require that any thickness monitoring data or any corrosion monitoring data that is collected during the turnaround be populated and updated within the corrosion monitoring database prior to a final inspection report for that vessel being generated. The final report should state, “This vessel is suitable for continued service,” or “This piping system is suitable for continued service.” Many facilities require this or a similar statement to be documented before the equipment is closed and turned back over to operations to be placed back in service.

Also, to appropriately manage the reliability of their equipment, they put thresholds and hold-points in place that will not allow the equipment to be turned back over to operations until the corrosion monitoring data has been updated, the reports of the corrosion monitoring program have been run, and the piece of equipment has been validated as suitable within the corrosion monitoring program. They ensure that their data is always entered into the database before the turnaround is over and equipment is placed back into service.

As a general rule, all refineries and petrochemical companies should operate their facilities with a predictive and reliability-minded philosophy and methodology.

Standardized Reports
Standardized reports are a benchmark that should be maintained by the owner-user. Yet unfortunately, many facilities have not established a minimum criteria for reporting, leaving this critical element solely at the discretion of the inspection contractor performing the work. Minimum criteria refers to the minimum acceptable technical information that should be captured in every single report—whether a repair was made or whether an inspection was done and nothing was found that warranted repair. Either way, every single report should have an established minimum acceptable level of technical content that is provided and a level of detail that will help the facility manage the future reliability of that equipment or piping. Yet within the industry today, there exists a large degree of variation in the technical completeness of reports that are generated from the various inspection providers. In fact, the same API 510 equipment inspector can work for 3 different inspection providers and generate 3 completely different levels of reports, each with varying degrees of technical completeness, depending on what level of reporting expectation has or conversely has not been set by each different inspection provider the inspector worked for. This is a significant gap that exists within the reporting aspect of turnaround inspection. At this point, the only sound and logical resolution is for the owner-operators’ inspection and reliability departments to establish a detailed and comprehensive reporting “minimum criteria”.

Management of Change
Management of change (MOC) is required when equipment is changed on a vessel or piping that is outside the original design or operating parameters of the vessel, and documenting such MOC activities is an important task during the post-turnaround process. For example, if corrosion is discovered in a vessel, and it is fairly aggressive, operators will need to mitigate that corrosion before it gets too thin for the design conditions that exist for that vessel. Two options are available:

First, the owner-operator can de-rate the vessel, or change its operating nature, by using engineering calculations to determine how thin they can allow a vessel to corrode at a reduced PSV (pressure safety valve) setting, a reduced operating pressure and/or a reduced operating temperature. For that change to be made from a vessel’s original design, it requires an MOC be conducted, typically requiring signatures from engineering, operation, maintenance, and inspection, and usually all the way up to some level of upper management. The MOC document typically contains a variety of specific operating, maintenance, inspection, testing, engineering and design calculations and includes everything necessary to validate the change that is needed.

As a typical example, a piping system within a crude unit might require 150-pound spiral-wound, Grafoil-filled gaskets. Yet, maintenance might want to use a spiral-wound gasket with no Grafoil-filler, or just a spiral-wound gasket or a Garlock type paper gasket. A change of this nature that affects the design of that joint that is different than what is designated within the pipe specification requires an MOC because the pipe specifications are basically the design criteria of a piping system. If personnel make a gasket change that is different than the requirements of the pipe specification, they must complete an MOC document.

Another typical example is when certain types of fittings, valves, vessels, and piping systems are not allowed by the pipe specifications for that system to be connected with socket-welded fittings. Yet, maintenance might determine that butt-welding will take too much time. Socket welds can be completed in one-third of the time because socket-welded joints are easier weldment to complete and the work can be completed quicker.

Another example is when the planning department was supposed to order specific gaskets for an exchanger, but ordered the wrong ones and the gasket manufacturer’s delivery time is four to six weeks. Management would ask engineering to determine if they can use a different type of gasket to put the equipment back together because the facility does not want to keep the unit down an extra four weeks waiting on $1200 in gaskets. A change like that requires an MOC. Sometimes hundreds of MOC’s are required, depending on what’s being done in the scope of work, while other turnarounds may result in little to no MOC’s being completed.

PSSR Requirements
A Pre-Startup Safety Review (PSSR) should be undertaken at the end of each turnaround where significant repairs or modifications to the unit were made to re-assess any potential hazard due to changes during the turnaround. The PSSR is completed prior to equipment being placed back into service. In recent years, this PSSR process has become a more prevalent part of the turnaround close-out process of most operators as a result of more interaction from jurisdictional regulators, such as the OSHA NEP audits. These documents require similar reviews and sign offs as those required by an MOC. If any MOCs were conducted during the turnaround, those MOCs are required to be completed and signed off by the appropriate operations, maintenance, inspection, and engineering personnel and the completed MOC package usually becomes part of the PSSR process for a unit. The PSSR is the final walk-down of the unit before the unit is delivered back to operations for startup.

A typical example is when a PSSR is needed for a crude unit. After all MOC packages are completed and all other work is finalized, a PSSR team of personnel with specific knowledge of the unit in question will go out and literally walk the unit to verify that all blinds were pulled that were put in place, every flange that was disassembled was properly reassembled and that all the appropriate gaskets are in place, and that all connections are bolted up accordingly. Specific attention will be given to changes in piping system design, configurations, modifications, and new equipment installed.

It is typically a very long process to get the PSSR for a unit done, from a half day to as much as a whole day or two, depending on the size of the unit and what was done to the unit during the turnaround. Once the PSSR is completed, then management has all of the documentation that is needed to complete a process hazard analysis (PHA), which is the final step for a turnaround project. The PHA document is one of the requirements of OSHA 1910.119, Part E for Process Safety Information. A PHA has to be revalidated every five years because it must include any changes to operations. Such changes might include adding a piece of equipment like a heat exchanger for a combined feed to get more cooling, or anything that would change the overall design and operation of the unit.

The measures of a successful turnaround inspection process are:

During the turnaround, every discovery inspection that was conducted identified all corrosion and other damage phenomenon that are occurring.
Everything that was inspected is appropriately documented and contains the minimum acceptable amount of technical content that should be provided so that the owner-user can manage the integrity of their equipment going forward.
All inspection data is entered into a database, is analyzed, and is approved before any equipment is placed into service.
While these three concepts seem self-evident, putting them into practice can be complex. Owner-users who strive to optimize inspection practices during turnarounds can find best practices for these activities by attending national conferences such as the API Inspection Summit, American Society for Testing and Materials (ASTM), the ASME, and other technical symposiums. During such events, engineers discuss troubleshooting dilemmas, lessons learned, and the trials and tribulations that they’ve been experiencing within their facility. Such conferences often include think-tank sessions where new ideas and solutions are reached and shared by the industry.

Inspection providers, as well as owner-operators, should embrace new technology, new tools and new software applications that, while perhaps costly, can create standardization and efficiency. It is never too late to teach an old dog new tricks, especially in an industry where safety and reliability are of the highest priority.
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