Mechanical Integrity Programs for RMP and SPCC

Midwest Environmental Compliance Conference

May 11, 2016

Agenda

• Purpose of Mechanical Integrity Programs

• RMP

• SPCC

• Tank/Vessel testing options

• Summary

Purpose of Mechanical Integrity Programs

• Ensure that the process stays as close to the original design and installed condition as possible by maintaining proper preventative maintenance practices and regular inspections

• Maintaining the physical integrity of the system and safety devices is the first line of defense against unwanted releases

RMP

Regulatory Requirements

• EPA does NOT dictate the inspection method or inspection frequency, they simply require that testing be performed.

• Develop written procedures designed to maintain the ongoing integrity of process equipment

• Training for personnel tasked with performing maintenance activities.

Regulatory Requirements

• What is covered?

– Pressure vessels and storage tanks

– Piping systems and common components such as valves

– Relief and vent systems

– Emergency shut down systems

– Controls (monitoring devices and sensors, alarms, interlocks, etc)

– Pumps

Regulatory Requirements

• Documentation shall include:

– Date of inspection/test

– Name of the person conducting the inspection/test

– Serial # or other equipment ID

– Description of the inspection/test

– Results of the inspection/test

Regulatory Requirements

• Inspections and testing of process equipment

• How? – Inspection and testing procedures should follow recognized and

accepted good engineering practices

• How Often? – Use manufacturer’s recommendations and good engineering

practices as a baseline

– Adjust as your testing and experience dictates but document reasons for deviations from manufacturing recommendations or standards

Regulatory Requirements

• Deficiencies which are outside of acceptable limits must be corrected before further use or in a safe and timely manner provided that measures have been taken to assure safe operation

– Document all corrective action taken

Developing a Mechanical Integrity Program

• Identify and categorize equipment and instrumentation to be included in the program – Be sure to include auxiliary systems or components,

• Determine the inspections and tests that are required to be performed on

each component – PM activities, scheduled rebuilds, routine replacement of parts, etc – Refer to manufacturers specifications and relevant codes and standards

• Determine the recommended testing and inspection frequencies – Use Mfg specifications as a starting point – May be adjusted based on your practical experience

• Outline the specific procedure required for each inspection and test. – Identify acceptable alternatives such as which NDT methods may be used

Developing a Mechanical Integrity Program

• Identify criteria for acceptable test results

• Train personnel who will be performing each test and inspection. – If outsourced, identify qualified contractors and ensure

they have received the proper training

• Documentation of inspection and test results – Be sure documentation includes all elements required by

regulation – date, name of person conducting, Equipment ID, Description of inspection or test and the results

Developing a Mechanical Integrity Program

• Documentation of manufacturer’s recommendation as to mean time to failure – Include other sources as well such as plant

experience, codes and standards, ANSI, ASME, ASTM, API, NFPA, etc

• Documentation to ensure that equipment installations met quality standards and used proper materials

Mechanical Integrity Common Questions

• We utilize a computerized maintenance system to track all PM activity, is the closed PM in the system enough documentation to support that the work was done?

– It depends…

• If system is very robust and contains ALL required info, it may suffice

• Be wary of electronic pencil whipping

Mechanical Integrity Common Questions

• Is it acceptable to conduct inspections/tests less frequently than recommended by manufacturer?

– Yes, provided you have functional data and evidence to support

Mechanical Integrity

Common Questions

• I utilize contractors to perform my maintenance activity, does that affect my documentation needs?

– NO, The same documentation needs to be kept, including the procedure that is followed for the inspection/test and verification that the contract employee performing the work has been properly trained to do that work

– Documentation must be kept on site

Mechanical Integrity Common Issues

• Regular PMs and inspections not very well documented

• Computer generated PMs lack detail describing tasks to be performed and acceptable equipment conditions

• No documented basis for frequency of inspections/tests

Mechanical Integrity Common Issues

• Corrective actions not well documented if at all

• Inspections/test not performed at required frequencies due to budget and resource constraints

• Stretching equipment beyond its recommended useful life without proper documentation to show continued operation is safe

• maintenance work is contracted and contractor retains the records

Mechanical Integrity Best Practices

• Computerized maintenance systems that generate very detailed work order for each required inspection/test, including checklist of procedures and tasks and indicating safe operating conditions and limits for applicable step/task

• Maintain hardcopy of field notes with employee signature verifying that the work was completed as prescribed

Mechanical Integrity Best Practices

• File for each component spelling out each activity performed on the equipment and detailed description of findings from each inspection, test and incident investigation pertaining to that component. Files also included detailed reasons for changes if any to the frequency or type of maintenance activities

Mechanical Integrity What Does EPA Look For?

• All documentation to indicate that system integrity is maintained properly and according to manufacturer specs or good engineering practices

• Physical appearance of equipment • Training records to verify those performing

maintenance work are competent • Documentation of PM findings and corrective

actions • Will verify competency and frequency through

employee interviews

SPCC

Regulatory Requirements

• Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance with industry standards, the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which take into account container size, configuration, and design (such as containers that are: shop-built, field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or partially buried).

SPCC Requirements

• Applies to bulk storage tanks

• Facility must determine appropriate testing frequency and document that in SPCC Plan

• Regulations guide you to follow good engineering practices and applicable codes and standards

– STI SP001

– API

SPCC

• All tank testing should be documented in report format

• Reports should identify the standard the inspection was conducted to

• Facility should properly document that recommendations identified in testing reports were properly addressed

Options for tank testing

• Steel Tank Institute SP 001

– Applies to smaller, shop fabricated tanks

– Frequency and type of inspection determined by tank size, containment and release detection

SP001 Requirements AST Type and Size (U.S. gallons) Category 1 Category 2 Category 3

Shop-Fabricated ASTs

0-1100

(0-4164 liters) P P P, E&L(10)

1101-5000

(4168-18,927 liters) P P, E&L(10)

[P, E&L(5), I(10)]

Or

[P, L(2), E(5)]

5001-30,000

(18,931-113,562 liters) P, E(20)

[P, E(10), I(20)]

Or

[P, E(5), L(10)]

[P, E&L(5), I(10)]

Or

[P, L(1), E(5)]

30,001-50,000

(113,566-189,271 liters) P, E(20) P, E&L(5), I(15) P, E&L(5), I(10)

Portable Containers P P P**

P-Periodic AST inspection E-Formal external inspection by certified inspector I-Formal internal inspection by certified inspector L-Leak test by owner or owner’s designee (Yrs.)-Indicates maximum inspection interval in years Category 1-AST’s with spill control, and with continuous release detection method Category 2-AST’s with spill control and without continuous release detection method Category 3- AST’s without spill control and without continuous release detection method

API 653

• API 653

– Applies to larger field erected tanks

– General requirements are 10 year external and 20 year internal inspections

– Schedule may be adjusted based on recommendations of inspector

– API 653 is more stringent than SP001

– Many SPCC Plans default to API 653 which is the more stringent standard – This is NOT necessary!

API 510

• API 510

– Applies to pressure vessels, regardless of size.

– Pressure vessel defined as having operating pressure greater than 14.7 psi

– Requires 5 year external inspections and 10 year internal inspections

API 570

• API 570 – Standard for piping inspections

– Requires that piping be inspected “periodically”

– Frequency of testing determined by facility owner and/or inspector

– Generally conducted in conjunction with other tank/vessel testing

– Primarily concerned with areas where corrosion may be prevalent (elbows, bends, connections, etc)

Summary

• RMP and SPCC do NOT indicate specific testing, they merely require THAT testing be performed

• Regardless of regulation, the onus is on facility owner to establish acceptable mechanical integrity procedures

• Knowledge of the applicable codes and standards is essential to establishing a proper, cost effective approach

• As with anything else, documentation is key

Pictures

Insulation Damage

Corrosion under Insulation

Valve Corrosion

Hole in weld seam connecting pipe leg

Biological growth on tank shell

Dent on tank floor

Excessive bird droppings can lead to corrosion

Missing Bolt on manway

Pit on shell wall

QUESTIONS??

Shawn Zablocki, P.E.

szablocki@oaconsulting.com

Office 402-938-2414 Cell 402-350-7101