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A

Agenda

American Petroleum InstituteSUBCOMMITTEE ON INSPECTION

TASK GROUP ON SCI CODES AND STANDARDS

8:30 am – 4:30 pm Monday Caesars PalaceApril 22, 2013 Las Vegas, Nevada

D. Wang, ChairmanJ. Krynicki, Vice Chair

1. OPENING/INTRODUCTIONS/ATTENDANCE SHEET/ROSTER

2. ANNOUNCEMENTS OF OTHER INSPECTION RELATED MEETINGS

NDE Task Group / NDE Qualification Mon, 4:30 pm – 6:00 pm Welcome Reception Mon, 6:00 pm – 7:00 pm Task Force on RP 581, Risk-Based Inspection Tue, 7:30 am – 11:00 am Task Group on RP 576 Tue, 7:30 pm – 11:30 pm RP 939-C Sulfidation Tue, 8:00 pm – 10:00 pm SCAST Fabrication SG – 653 Ballots Tue, 10:00 am Task Group on RP 580 Tue, 1:30 pm – 4:00 pm Manufacturers and Contractors Tue, 4:00 pm – 5:00 pm Task Group on RP 572 570/574? Wed, 7:30 pm – 9:00 am API 570/574 Task Group Wed, 9:30 am – 11:30 am Inspector Certification Task Group Wed, 10:00 am – 12:00 pmSubcommittee on Inspection – Joint Meeting Wed, 1:00 pm – 5:00 pmInspector Certification Exam Construction Thur, 7:00 am – 5:00 pmInspector Certification Exam Construction Fri, 7:00 am – 12:00 pm

D. Wang

D. Wang

3. APPROVAL OF AGENDA

4. APPROVAL OF MINUTES FROM NOVEMBER 2012

5. API 510 WRAP-UP BALLOTS

A. Ballot 2921, Inspection Due Dates

B. Ballot 2922, Integrity Operating Windows

C. Ballot 2923, Risk Based Inspection

D. Ballot 2924, Types of Inspection and Surveillance

D. Wang

D. Wang

M. Geisenhoff

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6. TECHNICAL INQUIRIES

A. 2013-570-01, Piping Service Classes

B. 2013-570-02, 6.3.4.1 & Table 2

C. 2013-570-03, RBI Assessment

D. 2013-570-04, RBI Assessment Intervals

7. PROPOSED NEW BALLOTS

A. Draft 510 Ballot: Management of Change

B. Draft 510 Ballot: Integrity Operating Windows

C. Draft 510 Ballot: Section 4.6 on Other Personnel Requirements

D. Draft 510 Ballot: 4.2.7 Self-Auditing Requirements

E. Draft 510 Ballot: Clarification of Inspection Plan Requirements

F. Draft 510 Ballot: Extent of Discussion of Damage Mechanisms in 5.4.1

G. Draft 510 Ballot: 5.4.4 Definition of Cyclic Service

H. Draft 510 Ballot: Clarification of the Role of On-stream and CML Inspections

I. Draft 510 Ballot: Clarification of 5.6.3.1

J. Draft 510 Ballot: Clarification of 5.8.1.1

8. RP 572 RE-AFFIRMATION

9. SCORECARD ITEMS

10. API 570/RP 574 REWRITES

11. NEXT MEETING

New Orleans, Louisiana, November 11, 2013

12. ADJOURN

D. Wang

D. Wang

R. Konet

D. Wang

D. Wang

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Technical Inquiry – 570-2013-01

Publication Type: API Publication Number: 570

Edition: 2nd Addendum/Errata: 4Number: Section Referenced: 6.2

Subject: Piping Service Classes

Background:

In the subject standard, section 6.2, guidelines for Piping Service Classes, operating temps above boiling point is referenced for Class 1 when illustrating a fluid that will rapidly vaporize. For class 2 and 3, operating temps above flash points only are referenced for fluids that will slowly vaporize (Class 2) and do not significantly vaporize (Class 3). It seems inconsistent to use flash points when referring to rate of vaporization for both Class 2 and 3.

Question: Would it be correct to say that a fluid operating below its boiling point, and above its flash point, meet the criteria intent for Class 2?

First Name: KennethLast Name: UlrichEmail: [email protected] Company: PenfordPhone: (319) 398-1232

Response

Yes

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mailto:[email protected]



Edition: 3rd Addendum/Errata:Number: Section Referenced: 6.3.4.1, Table2

Subject: 6.3.4.1 & Table 2

Background:

Section 6.3.4.1 states "All process piping systems shall be categorized into different piping classes. Such a classification system allows extra inspection efforts to be focused on piping systems that may have the highest potential consequences if failure or loss of containment should occur. In general, the higher classified systems require more extensive inspection at shorter intervals in order to affirm their integrity for continued safe operation. Classifications should be based on potential safety and environmental effects should a leak occur. Owner/users shall maintain a record of process piping fluids handled, including their classifications.”

Question:If RBI assessment is used to determine inspection intervals and consequences of failure, does the requirement of 6.3.4.1 that “All process piping systems shall be categorized into different piping classes” still apply?

First Name: Michael Last Name: Farris Email: [email protected] Company: Huntsman Corporation Phone:

Response

Yes

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A user has submitted a RFI via the RFI website on 4/15/2013 at 5:37 PM Publication Type: API Publication Number: 570

Edition: 3rd Addendum/Errata: Number:Section Referenced: 5.2.4, Table 2

Subject: RBI Assessment

Background:

Section 5.2.4 states “When RBI assessments are used to set equipment inspection intervals, the assessment shall be updated after each equipment inspection as defined in API 580. The RBI assessment shall also be updated each time process or hardware changes are made or after any event occurs that could significantly affect damage rates or damage mechanisms. The maximum intervals between RBI assessments are outlined in 6.3.2, Table 2.”

Question:If the answer to question on Section 6.3.4.1 is "yes", does 5.2.4 require an RBI assessment be conducted at the maximum intervals listed in Table 2 for each piping class (i.e. Class 1, Class 2, etc.), respectively?


Response

Yes

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Edition: 3rd Addendum/Errata: Number: 570 Section Referenced: 6.3.4.1, Table2

Subject: RBI Assessment Intervals

Background:

Section 6.3.4.1 states “All process piping systems shall be categorized into different piping classes. Such a classification system allows extra inspection efforts to be focused on piping systems that may have the highest potential consequences if failure or loss of containment should occur. In general, the higher classified systems require more extensive inspection at shorter intervals in order to affirm their integrity for continued safe operation. Classifications should be based on potential safety and environmental effects should a leak occur. Owner/users shall maintain a record of process piping fluids handled, including their classifications.”

Question:

If the answer to previous question on 6.3.4.1 is "yes", if RBI assessment is used to determine inspection intervals regardless of the inspection interval or extent of inspection employed, does 6.3.2 require an RBI assessment be conducted at the maximum intervals listed in Table 2 for each piping class (i.e. Class 1, Class 2), respectively?


Response

Yes

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Draft 510 Ballot

Title: Management of Change

Date: 1/09/2013

Contact: Name: Leigh Klein

Company: BP

Phone: 360-371-1247

E-mail: [email protected]

Purpose: Convey the need for inspector and materials/corrosion engineer involvement in MOCs affecting pressure vessel integrity without setting the inspection organization up for regulator auditing issues.

Source: API 510 10th Ed., Draft 5 ballot resolution

Revision: 0

Rationale: Owner-User Inspection Organizations are held responsible by regulators for the implementation of API inspection Codes when those Codes are adopted as RAGAGEP. API should avoid inserting specific mandates and requirements in Inspection codes for activities beyond inspection, since they are outside the control of the O-U inspector, and are covered in other documents and standards.

The new section 4.1.2 on Management of Change starts off saying, "The owner/user is responsible for implementing and executing…." Although the terms are defined in Section 3, there isn’t always a clear distinction in their usage in the document between the "owner/user" and the "owner/user inspection organization." Any distinction will be lost on regulators. Furthermore, since this is a RAGAGEP inspection code, it is the inspection organization that is held responsible for implementing and following it, and any failure to meet the requirements of this paragraph will find its way back to the inspection group.

It’s clear the intent of putting this in API 510 is to help educate people to the need for including inspectors and materials/corrosion engineers in MOCs affecting pressure vessel integrity, and that’s appropriate. But given that the only people who read and use this document are inspector types, we need to be very careful about putting requirements for other refinery personnel in the inspection standard. The point can still be made in API 510 while avoiding potential regulatory/auditing traps by wording the paragraph as follows.

Notes:

Proposed change:

4.1.2 Management of Change (MOC) An effective management of change process that reviews and controls changes to the process and to the hardware is vital to the success of any pressure vessel integrity management program as it allows the owner/user inspector 1) to be able to address issues concerning the adequacy of the pressure equipment design and current condition for the proposed changes, 2) to anticipate changes in corrosion or other types of deterioration, and 3) to update the inspection plan and records to account for those changes. When pressure equipment integrity may be affected, it is important that the MOC process include the appropriate inspection, materials/corrosion and mechanical engineering experience and expertise in order to effectively identify pressure equipment design issues and forecast what changes might affect pressure vessel integrity. Involving the inspection group in the approval process for changes to the hardware and

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the process that may affect pressure vessel integrity will help assure the effectiveness of the MOC process.

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Draft 510 Ballot

Title: Integrity Operating Windows

Date: 01/09/2012


Company: BP

Phone: 360-371-1247


Purpose: Convey the need for IOW without setting the inspection organization up for regulator auditing issues. Reference the existing API document, API 584, in order to minimize redundant discussion in API 510.


Revision: 0


As written, section 4.1.3 on Integrity Operating Windows mandates things that are outside the control of the O/U inspection organization. Having it in API 510 places the responsibility for its implementation on the O/U inspection organization in the eyes of regulators. There are a number of "shalls" in this paragraph that make it problematic. It's fine to bring up the subject of integrity operating windows in API 510, because they're important to assuring the integrity of pressure vessels. But a better way to word it, especially since we have API 584, an entire document on IOWs would be as follows:

Notes:

Proposed change:

4.1.3 Integrity Operating Windows (IOW)Establishing and monitoring integrity operating windows are key to avoiding process parameter exceedances that may have an unanticipated impact on pressure equipment integrity. Monitoring IOW and notifying inspection and engineering personnel of deviations from, and changes of trends within established IOW enables them to modify or create new inspection plans depending on the seriousness of the situation. See API 584 for detailed information on the basis for and recommended practices for establishing IOW.

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Draft 510 Ballot

Title: Section 4.6 on Other Personnel Requirements

Date: 01/09/2012


Company: BP

Phone: 360-371-1247


Purpose: Convey the need for IOW without setting the inspection organization up for regulator auditing issues. Reference the existing API document, API 584, in order to minimize redundant discussion in API 510.


Revision: 0


Section 4.6 on Other Personnel says all those people outside the inspection department "shall be responsible for…." And what happens if they don't meet those responsibilities? The O-U organization can be held responsible. It's all useful information, but I don't think you should include mandates on people outside the inspection area in a pressure vessel inspection standard. This discussion is more appropriate for API 572 rather than API 510. However, in whichever document it resides, it should be worded as follows:

Notes:

Proposed change:

4.6 Other PersonnelOperating, maintenance, engineering (process and mechanical) or other personnel who have knowledge or experience related to pressure vessel integrity can play an important role in helping to assure pressure vessel integrity by notifying the inspector or engineer of potential issues that may affect vessel integrity. Examples include the following:

a. any action that requires management of change (MOC); b. operations outside defined integrity operating windows (IOW);c. changes in source of feedstock and other process fluids that could increase process related corrosion

rates or introduce new damage mechanisms; d. vessel failures, repair actions conducted and failure analysis reports; e. cleaning and decontamination methods used or other maintenance procedures that could affect

pressure vessel integrity; f. reports of experiences that may come to their attention that other plants have experienced with

similar or same service pressure vessel failures; g. any unusual conditions that may develop e.g. noises, leaks, vibration, movements, insulation

damage, external vessel deterioration, support structure deterioration, significant bolting corrosion, etc.

h. any engineering evaluation, including FFS assessments, that might require current or future actions to maintain mechanical integrity until next inspection.

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Draft 510 Ballot

Title: 4.2.7 Self-Auditing Requirements

Date: 1/09/2013


Company: BP

Phone: 360-371-1247


Purpose: To not impose additional auditing requirements directly via API 510


Revision: 0

Rationale: It is a mistake to add requirements for self-auditing into an API inspection standard. It is unnecessary and redundant, and it will provide regulators and others the opportunity to judge us on the quality and adequacy of our self-audits against the API 510 requirements. Inspection itself is an auditing function. We audit the effectiveness of the plant design and corrosion control measures to see how effective they are in controlling corrosion and other damage mechanisms. We already get audited by numerous groups, both internal and external, so they are already auditing the auditors. If we have to audit ourselves, the results of those audits will be reviewed by the other auditing groups, who will audit how well we did our audit, and will adopt whatever findings we came up with as their own. The end result is that we will have auditing of the audit of the auditors.

Notes:

Recommended Change: Remove 4.2.7 from API 510.

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Draft 510 Ballot

Title: Clarification of Inspection Plan Requirements; 5.1 and 5.5.1

Date: 1/09/2013


Company: BP

Phone: 360-371-1247


Purpose: To further clarify the meaning of “inspection plan” so that it is not open to mis-interpretation, and to avoid regulatory traps while not diluting the meaning or effectiveness of the document


Revision: 0

Rationale: Section 5.1 needs clarification. The current wording in several places in API 510 leaves open the possibility of regulators or others not conversant in the subject matter, deciding that API 510 requires us to have separate, complete, stand-alone inspection plans for each and every vessel. An attempt was made to address this concern in the Ninth Edition when the last sentence was added to 5.1.2, but it needs to be moved to the top of the discussion in 5.1 and stated clearly and unequivocally.

In addition, there are also too many "shalls" in 5.1.1.1 through 5.1.2. Every "shall" opens the possibility of a regulator asking for the written documentation in your "inspection plans" to prove you considered everything listed for every vessel. By the same token, 5.5.1 should leave out the words "for each vessel."

Notes:

Proposed changes:

5.1 Inspection PlansAn inspection plan shall be established for all pressure vessels and pressure-relieving devices within the scope of this code. The inspection plan need not be a single document containing all the provisions and required components of the plan. Many owner/user inspection organizations have the various components that make up the plan located in a number of different information repositories (databases, files, electronic documentation, inspection and maintenance schedules, etc.) This is acceptable and satisfies the requirements for an inspection plan as long as all the required information is readily available and accessible to the inspector. Generic inspection plans based on industry standards and practices may be used.

In 5.1.1.1, the second sentence regarding consulting a corrosion specialist should be a "should."

In 5.1.1.2, revise the sentence before the list to say "Examination intervals should consider the following, as applicable," or, “The following can effect and help determine inspection intervals.”

In 5.1.1.3, the second sentence should use a "should." ("Inspection plans should be reviewed and amended….")

In 5.5.1, the first sentence after "f" should end at the word "plan," i.e., "Inspections shall be conducted in accordance with the inspection plan," and leave out the words "for each vessel."

Draft 510 Ballot

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Title: Extent of Discussion of Damage Mechanisms in 5.4.1

Date: 01/09/2012


Company: BP

Phone: 360-371-1247


Purpose: Simplify 5.4.1. Avoid regulatory traps. Make use of information in other API documents by reference rather than repetition in API 510.


Revision: 0

Rationale: Avoid conflict and redundancies by referencing other appropriate API documents that cover the material more effectively rather than inserting it in API 510.

Don't say, "Pressure vessels are susceptible to various types of damage…." Until you’ve lived through it you can’t imagine the aggravation this will cause when dealing with regulators. Say, "Pressure vessels can be susceptible to …."

In the Tenth Edition revision of API 510, the list of potential damage mechanisms in 5.4.1 was expanded to include almost everything in API 571. The second sentence, where it states, "Inspection techniques for each of the potential damage mechanisms that exist for each pressure vessel should be part of the inspection plans," will lead regulators to expect to see us document where we considered each of these damage mechanisms and either ruled them in or ruled them out, and why, for each vessel. I think we can reduce this exposure if we change the wording, and then not list all the mechanisms here, but simply refer to API 571. It repeatedly refers to API 571 in the list anyway, and since we have a complete API document addressing corrosion mechanisms (API 571), we don't need to repeat it all in API 510.

Also, 5.4.1 and 5.4.3 could be combined so that we're not repeatedly referencing API 571 and API 572.

Notes:

Proposed changes:

1. Rewrite 5.4.1 as follows

5.4.1 Pressure vessels can be susceptible to various types of damage by a number of mechanisms. Pressure vessel inspections should take into account the potential damage mechanisms that may exist under the conditions to which the vessel is exposed. Detailed information on common damage mechanisms including corrosion, cracking, high temperature damage, and metallurgical changes, as well as critical factors, appearance, and inspection and monitoring techniques to identify them, are found in API RP 571. Additional recommended inspection practices for various damage mechanisms are described in API RP 572.

2. Delete 5.4.3.

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Draft 510 Ballot

Title: 5.4.4 Definition of Cyclic Service

Date: 01/09/2012


Company: BP

Phone: 360-371-1247


Purpose: To provide a better definition of cyclic service in order to avoid mis-interpretation


Revision: 0

Rationale: We need a better definition of vessels in cyclic service, because all vessels undergo temperature/pressure cycles in some peoples' minds, e.g. after years of ups and downs for turnarounds, etc.

Notes:

Proposed change:

Vessels designed for cyclic service (cycles of pressure, temperature, or a combination of both), e.g., pressure swing absorbers, or with a known history or expectation of fatigue cracking, e.g. coke drums and mole sieves, should be evaluated for potential fatigue cracking failures and have appropriate inspections planned. The following considerations should be evaluated where applicable for such vessels.

The list (a through d) can remain as it is.

Then delete the last sentence, “Typical examples of….”

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Draft 510 Ballot

Title: Clarification of the Role of On-stream and CML Inspections;

Date: 01/09/2012


Company: BP

Phone: 360-371-1247


Purpose: To reduce the confusion on the role of external NDE


Revision: 0

Rationale: Sections 5.5.3, 5.5.5, 5.6.2, and 6.5.2, taken together, are confusing. As currently written, API 510 is not clear on the distinctions between an external visual inspection, external NDE to supplement external and internal visual inspections, and a (potentially) more rigorous external NDE examination in lieu of an internal visual inspection. 5.5.3, “On-stream Inspection of Pressure Vessels,” describes a rigorous external-NDE type of inspection that might be used in lieu of an internal inspection. 5.5.4 is about external visual inspection. 5.5.5 is on thickness measurements that are normally taken when the vessel is on-stream, 5.6.2 is about CML examinations, for which it’s not clear how this is differentiated from 5.5.3, and then 6.5.2 discusses on-stream inspections again, focusing primarily on requirements for substituting an on-stream inspection for an internal inspection. This material can be confusing, particularly for someone who hasn’t been involved in the evolution of API 510 as it’s been modified and added to over subsequent editions, and therefore doesn’t know what it intends to mean.

The first sentence of 5.6.2.1 is especially confusing or misleading. In 5.5.3.1, it says, “The on-stream inspection may be required by the inspection plan.” But then 5.6.2.1 says under CML examinations that, “Each pressure vessel shall be monitored by conducting a representative number of examinations at CMLs to satisfy the requirements for an internal and/or on-stream inspection. I think it’s the intent of API 510 to require external UT thickness measurements to be taken as the minimum for satisfying the “CML examination” requirements.

Notes:

Proposed change:

End the first sentence of 5.6.2.1 after "CMLs," i.e., "Each pressure vessel shall be monitored by conducting a representative number of examinations at CMLs," and leave out the words "to satisfy the requirements for an internal and/or on-stream inspection."

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Draft 510 Ballot

Title: Clarification of 5.6.3.1

Date: 01/09/2012


Company: BP

Phone: 360-371-1247


Purpose: To help clarify what we intended to say


Revision: 0

Rationale: Reduce ambiguity and potential for misuse and misinterpretation. Saying "More CMLs should be selected……" for the first set of criteria, and then, "Fewer CMLs can be selected…" for the second set, can cause confusion and misinterpretation. It's not clear what is meant. More than what? Less than what?

Notes:

Proposed change:

A relatively few CMLs will suffice for pressure vessels with a) low potential for creating a safety or environmental emergency in the event of a leak, b) relatively noncorrosive contents, or c) generally uniform corrosion rates. A greater number of CMLs should be selected for vessels with a) higher potential for creating an immediate safety or environmental emergency in the event of a leak (unless the internal corrosion rate is known to be relatively uniform and low), b) higher expected or experienced corrosion rates, or c) higher potential for localized corrosion.

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Draft Ballot 2013-510-10

Title: Clarification of 5.8.1.1

Date: 01/09/2012


Company: BP

Phone: 360-371-1247


Purpose: To clarify what we intended to say


Revision: 0

Rationale: Avoid ambiguity and misinterpretation. In 5.8.1.1, I think the intent is to distinguish between pressure test requirements for alterations or major repairs, where a pressure test is normally required, versus repairs not considered major repairs, where the pressure test is optional and at the discretion of the Inspector. But the way it's written is not clear.

Notes:

Proposed change:

After completion of repairs that are not classified as major repairs, a pressure test is at the discretion of the inspector and shall be applied if required by the inspector and specified in the repair plan.

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