Author of the API RP 578 2nd Edition PMI Certification Course. ➢ Certified API
Training .... 20 552 21 705 20 819 19 246 18 331 10 8%. Total Other-than-
Serious.
Training Course Explained on
API RP 578 By Don Mears Analytical Training Consultants October 2-6, 2011
Author Don Mears Confidential
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President of Analytical Training Consultants (ATC)
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30+ years of Oil and Gas industry experience
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Heavy involvement in API work groups
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Author of the API RP 578 2nd Edition PMI Certification Course
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Certified API Training Provider Certification TPCP # 0118
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G Industry I d C l f Thermo Th Fi h Scientific S i ifi Oil & Gas Consultant for Fisher
Author Don Mears Confidential
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pp Guidelines & Application Procedures For Positive Material Identification (PMI) with XRF & OES Technologies By Don Mears Analytical Training Consultants
Author Don Mears Confidential
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Introduction ¾ OSHA NEP-Directive CPL 03-00-004 for Refineries ¾ OSHA NEP-Notice CPL 02-00-148 for Chemical Plants ¾ OSHA Oil & Gas Industry “Process Safety Management” PSM Background ¾ Program Procedures ¾ Inspection Scheduling ¾ Proper Training and Refresher Training ¾ Compliance Guidance p ¾ Enforcement Inspection- Penalties and Results ¾ Conclusion ¾
Author Don Mears Confidential
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What is the Purpose of this API 578 PMI Certification Course ? Purpose of the Course is to certify and re-certify API inspectors, in understanding and applying API RP 578 through an approved API Training Course, that will qualify personnel in proper Guideline and A li ti procedures Application d utilizing tili i XRF and d OES ttechnologies h l i ffor PMI PMI.
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The course is covered in 2 day sessions and instruction on both classroom theory y and field testing g procedures. p Through Understanding API RP 578 Guidelines Through Application of proper PMI testing procedures
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The need and now requirement for Positive Material Identification (PMI) has dramatically grown in the past few years in refinery and petrochemical plant operations to 100% alloy material verification in today's risk-based QC environment.
Author Don Mears Confidential
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Occupational Safety and Health Administration (OSHA) Acts P Process Safety S f t M Managementt (PSM) 1910-119-Highly 1910 119 Hi hl Hazardous H d Chemicals Ch i l (HHC) 2/24/1992 Refinery National Emphasis Program (NEP) CPL 03-00-004 6/7/2007 Chemical National Emphasis Program (NEP) 09-06 (CPL 02) Notice – Pilot NEP 7/27/2009
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American Petroleum Institute (API)
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Recognized And Generally Accepted Good Engineering Practice” ((RAGAGEP))
Standard-API-570-Piping Inspection Code p Code Standard-API-510-Pressure Vessel Inspection Standard-API-653-Storage Tank Inspection Code Recommended Practice-API RP-578-Material Verification Program-MVP/PMI Recommended Practice-API 571 – HF Corrosion in CS Pipes ( REs, Cr, Cu, Ni ) R Recommended d d Practice-API P ti API 939-C-Guidelines 939 C G id li for f Avoiding A idi Sulfidation S lfid ti
Mechanical Integrity Needs in the Oil & Gas Industry Understanding HOW, WHY, & APPLYING: 9 ATC – API 578 PMI Certification Training Course 9 Data Management Software-PCMS, Ultra-Pipe, Meridian, Solid PMI
• According to OSHA’S refinery database: • 36 fatality/catastrophe (FAT/CAT) incidents • Related to Highly Hazardous Chemicals (HHC) since May 1992
• 52 employee deaths • Includes 250 employee injuries, 98 with hospitalization
• # of incidents surpass the combined total of the next 3 highest industries • Chemical Manufacturing Manufacturing-12 12 FAT/CAT • Industrial Organic Chemical Manufaturing-12 FAT/CAT • Explosive Manufacturing-11 FAT/CAT
Regional & Area Offices
Region 8
Region 7
Region 5
eg o 1 Region
Region 2 Region 10
Region 3
Region 4 Region 9
Region g 6
Author Don Mears Confidential
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OSHA Violation Statistics
FY2003 FY2004 FY2005 FY2006 FY2007
% Change 2003-2007
Total Violations
83,539
86,708
85,307
83,913
88,846
6.4%
Total Serious Violations
59,861
61,666
61,018
61,337
67,176
12.2%
Totall Willful illf l Violations i l i
404
462
747
479
415
Total Repeat Violations
2,147
2,360
2,350
2,551
2,714
26.4%
20 552 20,552
21 705 21,705
20 819 20,819
19 246 19,246
18 331 18,331
-10.8% 10 8%
T t l Other-than-Serious Total Oth th S i
BP Texas City, Texas Fined $30.7 Million For 439 willful Violations On 10/30/09
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Chemical Safety Board ( CSB ) Report-BP Report BP Texas City Texas NY Times report on BP Texas City Fines Safety Bulletin-BP Texas City.pdf BP Faces Record Fine NY Times Times-10-30-09.pdf 10 30 09 pdf
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Safety Bulletin from U.S. Chemical Safety and Hazard Investigation Board (CSB)-Chlorine Transfer Hose Failure due to improper material braid construction (i.e., 316L and not the recommended braid of Hastelloy C-276). On August 14, 2002, a 1-inch transfer line ruptured p during g a railcar offloading g operation p at DPC Enterprises in Festus, Missouri and released 48,000 pounds of Chlorine into neighboring areas SafetyBulletin-ChlorineShutdown.pdf y p
Chemical Plant NEP effective on July 27 27,2009 2009 ¾ Extended through end of 2010 ¾ Outlines O tli a diff differentt approach h for f inspecting i ti PSM covered chemical facilities ¾ NOT comprehensive h i ¾ LESS resource intensive for both OSHA and Chemical Plants ¾
Author Don Mears Confidential
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Regions 1,7,& 10 Inspections for 5-10 facilities as Pil t Program Pilot P Regional & Area Offices
Region 8
Region 7
Region 5
Region 1
Region 2
Region 10
Region 3
Region 4
OSHA by Region Region 9
Region 6
In response to increasing industry safety demands, Analytical Training Consultants has p produced the API 578 PMI Certification Training g Course
www.ATC578.com ATC578
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Why Should this Course be Given ?
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“Recognized Recognized And Generally Accepted Good Engineering Practice” (RAGAGEP) – are engineering, operation, or maintenance activities based on established codes, standards, published technical reports or recommended practices (RP) or a similar i il document. d t RAGAGEPs RAGAGEP d detail t il generally ll approved ways to perform specific engineering, inspection or mechanical integrity activities activities, such as fabricating a vessel, inspecting a storage tank, or servicing a relief valve (See CCPS [Ref. 33]).
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Important information is found in APPENDIX A regarding the “Static Static List of” of Inspection Priority Items (IPI) and contains questions that the Compliance Safety and Health Officer (CSHO)’s are to address in their compliance evaluation of an employer’s l ’ refinery fi “Process “P Safety S f t Management” M t” (PSM) program. It should be noted that both PMI and proper OPERATOR TRAINING programs are QUESTIONS that the (CSHO) will address to the Owner/Operator as to compliance with their Process Safety Management (PSM) program.
Author Don Mears Confidential
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Positive Material Identification (PMI) ¾
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Does the employer ensure that replacement piping is suitable for its process application? Yes, No, N/A If no no, possible violations include: The employer did not follow RAGAGEP when it failed to conduct positive material identification (PMI) testing to ensure that construction materials of replacement/repaired piping were adequate for process conditions (An example RAGAGEP for PMI testing for existing piping systems includes but is not limited to, API RP 578, Material Verification Program for New and Existing Alloy Piping Systems, Section 4.3), and CSB, Safety Bulletin – Positive Material Verification: Prevent Errors During Alloy Steel Systems Maintenance, BP Texas City, TX Refinery Fire);
¾ Author Don Mears Confidential
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Proper Operator Training ¾
Have operating employees been trained on the procedures they are expected to perform? If NO, Possible Violations Include:
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The employer did not provide initial operator training on each specific procedure operators are expected to perform; or 1) The employer did not document the training, training 2) The employer did not document the means used to verify the training, or 3) The employer did not verify that the operator understand the training.
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Author Don Mears Confidential
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Proper Operator Training ¾
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Based on the employer’s explanation of their management of operator refresher training g ((See document request in Section X.E.3.o.), have the five randomly selected operating employees received, completed, and understood the refresher training (See document request in Section X.E.3.n.)? For each employee who operates a process, has the employer ensured that the employee understands and adheres to the current operating procedures and that the refresher training is provided at least every three years-- more often if necessary? YES, NO,N/A Author Don Mears Confidential
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Proper Operator Refresher Training ¾
If no, no possible violations iolations include: incl de
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1)) The employer p y did not p provide operator p refresher training g at least every three years or more often, if necessary (e.g., on a frequency consistent with that determined through consultation with employees); or 2) The employer did not document the training; 3) The employer did not determine that the operator understood the training it received; or 4) The employer did not document how it verified the training
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Author Don Mears Confidential
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Incident Investigation Report ¾
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The CSHO must document in the INCIDENT INVESTIGATION REPORT the number of “Actual” and a “Near-Miss” incident which has occurred in you plant. A very important part of this is the “Factors Factors that contributed to the incident” incident . In section Q of Appendix A OSHA list examples and PMI and Training are a part of this list: Examples of "Factors that contributed to the incident”/“causal factors” can include, but are not limited to:
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Author Don Mears Confidential
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Incident Investigation Report ¾
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Examples of "Factors that contributed to the incident”/“causal factors” can include, but are not limited to: The employer did not design, operate, maintain, inspect, or change c a ge ((MOC) OC) equipment equ p e t or o equipment equ p e t systems syste s pe per RAGAGEP; The employer did not train its employees in its procedure for transferring product from the Chemical X intermediate tank to Reactor 23; The 3-inch reactor transfer line was replaced without conducting a PMI, as a result, the replaced piping that was constructed of an off-specification material failed in a short period of time;; p Author Don Mears Confidential
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launched 6/7/07 ¾ Updated U d t d 8/18/09 to t extend t d timeframe ti f for f completion ¾Region ¾R i VI only l region i with i h iinspections i still ill to open (4) ¾Completion by end FY2011 ¾ The
approach/content of the inspections has not changed ¾ Combines C bi “static” “ t ti ” and d “d “dynamic” i ” question ti lists li t with guidance for compliance officers (CSHOs)
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1,000 OSHA hours per inspection ¾ Typically use full statutory 6 months available ¾ Also resource intensive for employers ¾ Compliance found to be highly uneven ¾ Substantial issues identified ¾ Average penalties/inspection ~$166,000 $166 000 ¾ Average penalty/violation ~$9,560 ¾ Average violations/inspection ~17.4
Refinery NEP Most Frequently Cited PSM Elements Element
Description
% of Citations
Cumulative %
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Mechanical Integrity
19.4%
19.4%
d
Process Safety Information
17.5%
36.9%
f
Operating Procedures
17.1%
53.9%
e
Process Hazard Analysis
17.0%
70.9%
l
Management of Change
8.2%
79.1%
m
Incident Investigation
6.7%
85.8%
o
Compliance Audits
3 8% 3.8%
89 6% 89.6%
h
Contractors
2.8%
92.5%
g
Training g
2.7%
95.2%
n
Emergency Planning & Response
1.5%
96.7%
c
Employee Participation
1.4%
98.1%
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Pre-startup Review
1.1%
99.2%
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Hot Work Permit
0.8%
100.0%
¾ Chemical
Plant NEP effective July 27, 2009 ¾ Extended through end of FY2010 ¾ Outlines a different approach pp for inspecting PSM covered chemical facilities ¾ Not comprehensive ¾ Less resource intensive for both OSHA and employers
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year pilot program for planned inspections in 3 OSHA Regions: Region I – CT, CT MA, MA ME ME, NH NH, RI Region VII – Nebraska, Kansas, Missouri Region X – Idaho
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Plans urged to participate voluntarily
Some states are doing Chemical NEPs
As you know, know Voluntary Participation Program (VPP) sites are not subject to programmed inspections ¾ However, the NEP applies OSHA-wide for unprogrammed PSM related inspections: ¾
Accidents Complaints Referrals Catastrophes p
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Selected from list of:
EPA Risk Program (RMP) P Program 3 ffacilities Ri k Management M P ili i OSHA database (previous PSM citations) Explosives Manufacturing Facilities identified by local (Area and Regional Office) knowledge
Chemical Plant NEP Inspections ¾ As A
off A August, t 2010 2010, 112 iinspections ti opened d
38 Unprogrammed (34%) 74 P Programmed d (66%) 9 resulted in no inspection occurring because there was no PSM covered process ¾ 62
inspections have issued citations ¾ Average 9 9.0 0 citations per inspection ¾ Average $3,500 per citation ¾ Over 60 different standards cited ¾ 44% of all citations were other than PSM
Chemical Plant NEP Citations by PSM Element Element
Description
% of PSM Citations
Cumulative %
j
Mechanical Integrity
23.8%
23.8%
d
y Process Safety Information
20.2% %
44.0% %
e
Process Hazard Analysis
19.0%
63.0%
f
Operating Procedures
13.9%
76.9%
g
Training
4.8%
81.7%
h
Contractors
3.8%
85.6%
o
Compliance Audits Compliance Audits
3 4% 3.4%
88 9% 88.9%
l
Management of Change
3.1%
92.1%
n
Emergency Planning & Response
2.9%
95.0%
m
Incident Investigation
2.6%
97.6%
i
Pre‐startup Review
1.4%
99.0%
k
Hot Work Hot Work
1 0% 1.0%
100 0% 100.0%
Training Course Explained on
API RP-578
By Don Mears Analytical Training Consultants
Author Don Mears Confidential
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THROUGH UNDERSTANDING API RP 578 GUIDELINES ( DAY 1 ) Scope of the Course General Alloy Substitutions in Carbon Steel Systems Roles and Responsibilities Industry References Terms and Definitions Extent of Material Verification Program Explain use of Material Verification Program Test Methods Field Evaluation of PMI Test result procedures P M ki and d Record R d Keeping K i Proper Marking Review and Testing on Academic Material of API-RP-578
Author Don Mears Confidential
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THROUGH APPLICATION OF PROPER PMI TESTING PROCEDURES ( DAY 2 ) Using XRF Technology- (Hands-on Application/Demonstration) Review of XRF Technology Who should use it? What is XRF – Technology Explained When should XRF be used? Where should XRF be used—Types used Types of Alloys How should XRF be used—PMI methods and Procedure Guidelines
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Why should XRF be used-Percent of PMI needed?
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Author Don Mears Confidential
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THROUGH APPLICATION OF PROPER PMI TESTING PROCEDURES ( DAY 2 )
Using OES Technology-(Hands on application/Demonstration) Review of OES Technology Who should use it? What is OES-Technology Explained? When should OES be used? Where should OES be used—Types of Alloys How should OES be used—PMI Methods and Procedure Guidelines Why should OES be used--Percent of PMI needed?
Author Don Mears Confidential
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Summary Comments for Presentation: ¾ ¾
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“Reasons Why! This Course should be given ! ” OSHA INSTRUCTION for Both Refining and Chemical Plants Uses Examples: API RP 578 Operation Training and Refresher Training Safety Bulletin from U.S. Chemical Safety and Hazard Investigation Board (CSB)—BP Texas City Safety Bulletin form U.S. Chemical Safety and Hazard Investigation Board (CSB)--Chlorine Transfer Hose Failure All the Reported and Unreported “Near Misses” the Oil and Gas Industry has experienced. This is true with all Global Oil & Gas Petro Chemical Companies !
Joint US and Mexico Efforts to Ensure Safe and Healthful Working Conditions for Workers from Mexico and other Latin American Countries. True also with North America, Europe & China http://www.osha.gov/international/index.html Author Don Mears Confidential
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Q Questions i ?
Author Don Mears Confidential
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