Reliability & Maintenance Conference & Exhibition

May 23-26, 2006

Henry B. Gonzalez Convention Center
San Antonio, TX 78205

RMC-06-88 Inspecting the Inspectors –

Facilities’ Inspection Program
Assessment

Presented By:

Robert Smallwood Abie Mathew

Principal Consultant Senior Consultant
Det Norske Veritas (USA) Det Norske Veritas (USA)
Houston, TX Houston, TX

National Petrochemical & Refiners Association 1899 L Street, NW 202.457.0480 voice

Suite 1000 202.429.7726 fax
Washington, DC www.npra.org
20036.3896
This paper has been reproduced for the author or authors as a courtesy by the National
Petrochemical & Refiners Association. Publication of this paper does not signify that the
contents necessarily reflect the opinions of the NPRA, its officers, directors, members, or staff.
Requests for authorization to quote or use the contents should be addressed directly to the
author(s)
Abstract: Due to various reasons, plant inspection programs have evolved into the
organizations that we know today. This evolution has resulted in numerous inspection
organizations requiring better process equipment condition assessment methods that are most
useful to business units. Successful inspection organizations have a clear understanding of the
equipment’s minimum mechanical integrity and service requirements. Inspection consists of
those techniques, procedures and management systems that can detect, measure and monitor
the various equipment damage mechanisms that may occur and clearly characterize the
present and future equipment serviceability to management. Inspection planning and execution
is an evergreen process, which must be adjusted as conditions warrant. Effective proactive
inspection programs excel in the subjects of equipment stewardship, communications,
knowledge management, damage mechanism assessments, inspection and monitoring, record
keeping, equipment evaluations and follow up of corrective actions. Each of these inspection
program concerns will be covered in more detail.

In response to various needs over time, refinery and petrochemical plant inspection groups
have evolved into the current organizations that exist today. The current inspection group’s
organizational structure was often dictated by what was perceived to be OSHA 1910.119 and
other regulatory requirements. Other influences on inspection group organizational structures
include budgetary constraints, inspection personnel qualifications and skills, engineering
technology, and the equipment to be inspected. As with most organizational evolutionary
processes, there are things that each plant inspection group does well and areas where
improvements are desirable. Organizations become comfortable with what they do well, but
these are not necessarily the actions that will be most useful to the plant. Thus it is prudent to
review inspection organizations and their functions frequently in order to achieve the maximum
benefit from such organizations.

Before any organizational review begins, one must first clearly define what is expected from that
organization. An inspection organization has the primary function of providing the plant
owner/operator with accurate and timely assessments of the current condition and future
serviceability of process equipment in the plant. The owner/user should be aware of the
limitations of the inspections and examinations conducted and the serviceability risks involved
under present and future process conditions. The inspection organization must also satisfy
jurisdictional and regulatory requirements, monitor the affects of process changes on
equipment, and determine that repairs, alterations and re-ratings meet the minimum plant
requirements.

Many plant inspection organizations are organized, staffed and tasked to just comply with
various jurisdictional and other regulatory requirements. Too many inspection programs only
blindly comply with such requirements and do not gain the benefits of a proactive inspection
program. Inspections are intended to provide the necessary data to most cost effectively
operate a process plant; this rarely happens when inspections are used to meet regulatory
requirements. The types and extent of inspections based on regulatory requirements are
sometimes more excessive than such inspections based on good engineering practice.
Regulatory authorities generally allow relaxation of strict and often capricious inspection
requirements where it can be demonstrated that a plant has and is utilizing a well engineered
inspection program. A comprehensive inspection program that includes a thorough engineering
analysis of the inspection results will meet all the intended goals of regulatory requirements.

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The tasks necessary for an effective and comprehensive inspection program are given below:

• Develop an inspection organization

• Identify and select the equipment to be inspected.
• Determine and define the minimum acceptable mechanical and process requirements
for each equipment item.
• Determine the possible damage mechanisms that may affect equipment serviceability.
• Choose examination, testing and monitoring methods to detect, quantify and monitor
damage mechanisms occurrences and progression.
• Develop inspection plans.
• Conduct the inspections, tests and examinations.
• Evaluate the results of the inspections, tests and examinations by comparing the results
with the minimum equipment requirements.
• Report and document the results in a timely manner.
• Review and monitor the results of corrective actions, process upsets and process
changes.
• Maintain effective communications with those parties whose actions may influence
equipment integrity.
• Evergreen each of the above as appropriate.

These items are listed separately for convenience of this paper’s organization, but in reality
many should be conducted concurrently.

Inspection Organization:

Numerous different inspection organizations exist at various plants; some of which are very
proactive and effective while others add little or no value to the plants. More effective
organizations have a senior inspector (usually an engineer), certified inspectors, Non-
Destructive Examination (NDE) examiners (either in-house or contract personnel) and have
ready access to and a good working relationship with in-house or outside subject matter
experts. In North America inspectors should be certified to the API or National Board Inspection
Codes (NBIC) since these codes are recognized as best practices. NDE examiners are most
often certified per ASNT SNT-TC-1A (usually level 2) and often have a Welding Inspector
Certification. Subject area experts include equipment engineers and designers, corrosion
engineers, welding engineers, metallurgy or materials engineers, NDE specialists and structural
engineers. The subject area experts are usually in a different organization than the inspectors.
The more effective inspection organizations report to the plant manager, a reliability group or to
the director of operations. Inspection organizations reporting to maintenance or engineering
departments tend to be less effective.

Most jurisdictions do not require the inspectors to be certified to one of the inspection codes or
require the plant adopt an inspection code. Effective process plant inspection organizations
almost always adhere closely to the API inspection codes in both spirit and detail, including
inspector certification, even when not required by the jurisdiction. The NBIC is less detailed than
the API Codes regarding piping, vessels and storage tank inspection requirements, but since
the API Inspection Codes do not address boilers the NBIC would apply.

To obtain an effective inspection system it is essential that the organization earns and maintains
the respect of management, engineering, maintenance and operations. This can only be
obtained by good leadership, clear and well defined goals, and working with the other plant

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organizations on a continuous and cooperative basis. It is desirable for a plant with several
units to have an individual inspector assigned to each unit. Continuity of knowledge about plant
equipment can’t be over emphasized and having the same inspector performing inspections
over many years for the same equipment is beneficial.

Equipment to Be Inspected:

Jurisdictional, other regulatory requirements and inspection codes usually identify the
equipment that requires inspection; this includes some but not all of the process equipment and
may or may not include utility equipment. Prudent mechanical integrity practices usually
necessitate that additional equipment also deserves inspections. If all equipment not required
to be inspected by a governmental authority is not included in the inspection plans, it is a strong
indicator that an inspection program is, at least, somewhat ineffective. Remembering that
effective inspections support the continued availability of process operations, one should ask
what equipment is necessary for effective process operations and include essential equipment
in the inspection program. In addition, equipment whose failures may adversely effect other
equipment should be considered for inclusion in the inspection plans. An example of such a
failure would be a cooler tube failure which might result in severe corrosion throughout a cooling
water system. Other items to be considered for inclusion in inspection programs are health,
safety and environmental issues.

Determine Minimum Equipment Requirements:

The minimum required mechanical and process design bases must be defined for both new
equipment and in service equipment. Unless the operating unit has detailed engineering
analysis indicating another design basis is more appropriate, the plant should comply with the
current minimum requirements of the ASME Construction Codes as the basis for new
equipment and the API Inspection Codes or API storage tank standards, including Fitness-for-
Service (API RP 579) calculations as appropriate, for in service equipment. The requirements
of state and federal regulations are more applicable when more stringent than the ASME or API
codes or standards. Generally recognized and accepted good engineering practices should be
used to validate the design of equipment not meeting the design criteria of the ASME Codes or
API standards, e.g. horizontal tanks or vessels with design pressure less than 15 psig.

Consideration must be given to the effects on equipment due to service conditions which have
changed since the original design assumptions. Refineries are now using heavier crudes of
different acidity and sulfur and cyanide contents than those assumed during the initial material
of construction selection. Production cycles, process volumes and fluid velocities have also
probably changed since the plant was constructed. In addition the intervals between plant
shutdowns have generally tended to increase over the years. All of these post construction
changes tend to result in increased equipment corrosion, erosion and fatigue. A basic question
to ask during inspection planning is: “Based on mechanical integrity concerns, would we build
equipment differently today due to the process changes that have occurred since construction?”
When the answer is yes, it indicates where and what kind of equipment damage is most likely to
occur.

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Changes to the ASME Codes or API standards may have been made since in-service
equipment was originally constructed. Subject matter experts should review the original and
current design practices and determine if there are mechanical integrity concerns arising from
obsolete design practices. As an example, prior to the 1980’s fracture toughness at ambient
and low temperatures of carbon steels were not adequately addressed in the ASME and API
Codes and standards for pressure vessels, piping and tanks. Consequently, many heavy wall
carbon steel vessels are being operated at temperatures under pressure where there is a
significant probability of brittle fracture

Based on industry experience, from five to ten percent of the equipment delivered to plants have
significant design or construction deficiencies even though they were “built to Code”. Some of
these deficiencies are due to manufacturing errors but most are caused by not considering all of
the loads imposed on the equipment. Inspectors usually use as the equipment’s minimum
thickness for retirement or repairs, the nominal thickness less corrosion allowance, the minimum
thickness calculated by thickness data storage software programs based only on internal
pressure considerations or some arbitrary thickness (common for piping). If however, loads
other than internal or external pressure are the governing factor in determining minimum
thickness and were not considered in the original design then these approaches may
compromise mechanical integrity. Even when the equipment was designed, constructed and
installed to the best current practices there may be additional loads that develop over time due
to structural settling, operating conditions or maintenance practices that can impose excessive
loads on nozzles and other attachments. For these reasons, inspectors and appropriate subject
matter experts, after appropriate engineering analysis, should concur on the minimum
mechanical and process requirements for serviceability.

During the past thirty years much of the materials used for process equipment construction have
come from offshore sources. Much of this offshore material is equal to the quality of material
obtained from domestic suppliers. However, some offshore material, particularly piping
components, is of lesser quality than required by new construction codes and in a few cases is
actually “counterfeit material”. The potential problems that might result from use of substandard
materials must be considered in inspection planning.

Damage Mechanisms:

Once the minimum equipment serviceability requirements have been established it is then
necessary to determine those mechanical, wear, chemical and thermal mechanisms that can
damage or degrade the equipment and the likelihood of these mechanisms occurring.
Inspectors should consult with the appropriate subject matter experts, process engineers,
maintenance personnel and operators to determine those damage mechanisms that are most
likely to happen and where they might occur on the equipment. Experienced corrosion and
materials engineers are essential for this appraisal. Process Flow Diagrams (PFD), P&IDs,
Management of Change (MOC) documents, equipment files, historical records, root cause
failure investigations, industry experiences and reports of damage to similar equipment at other
locations are invaluable for these assessments. Possible damage for both the process side and
non-process side must be considered. The possible equipment damage due to shutdowns,
start-ups, abnormal operating conditions, maintenance procedures (including cleaning) and long
term out of service must be considered along with normal service conditions.

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This damage mechanism assessment is identical to that required for Risk Based Inspection
(RBI). A RBI program considers both the damage mechanisms and the consequences that
might result should failures (leakage) occur to calculate risk. The equipment which has the
greatest risk and where these risks can be lowered by inspection are given priority for
inspection. RBI analyses are very beneficial for plants with good inspection organizations but
have considerably less or no value for plants with ineffective inspection organizations. In the
latter case it is better to postpone RBI until the inspection organization efficiency improves so
that RBI can be a useful planning tool.

Examination, Testing and Monitoring Methods Selection:

Once the damage mechanisms have been identified and the desirability of detection and
monitoring of these mechanisms has been established, the inspection organization must
determine the best methods for damage mechanism detection, quantification and monitoring.
Subject area experts such as non-destructive examination specialists and materials engineers
should be consulted for this stage of the inspection process.

Several damage mechanisms are very difficult if not impossible to detect and monitor by NDE
methods especially in the developmental early stages. Damage may also occur at places on
the equipment that are difficult or impossible to inspect or examine by NDE methods. Some
forms of damage can only be detected and monitored by metallographic techniques or
destructive testing. Ideally, designers would design equipment constructed of materials that
would not suffer difficult to detect damage mechanisms, is designed so that all locations are
accessible for inspection or can be inspected by common NDE methods. It would be helpful if
equipment designers had more input from inspectors and subject area experts concerning
equipment inspections.

Process fluids can be analyzed for corrosion products or wear particles where these damage
mechanism are possibly active. Various corrosion probes, corrosion coupons and other
process chemistry monitoring instruments, such as pH meters, are useful indicators of corrosive
process conditions. Water treatment service companies usually monitor cooling waters and
boiler waters for control of corrosion. The results of these tests should be provided to the
inspector but quite frequently aren’t.

All parties involved in the inspection processes should be aware of the various limitations and
strengths inherent in inspection, monitoring and examinations methods. Many inspection
organizations spend considerable effort using NDE methods that are useless for the damage
mechanisms that are most probable. Conversely these organizations spend perhaps even
more effort using inspection practices suitable only for damage mechanisms that are highly
unlikely to occur.

Probably no plant has the tools and skills in-house necessary to conduct valid NDE
examinations for all the damage mechanisms possible at that site. Outside contractors are
necessary for NDE examinations that the plant inspectors are not qualified to perform.
Contractors only get paid when they do the examinations or tests and many are most willing to
conduct examinations even if their NDE methods are worthless; using inappropriate NDE
methods for heat exchanger tubes is fairly common. A more common problem with contractors
is that the technician conducting the test or examination is not qualified. Inspectors with
assistance from NDE specialists should carefully review the suitability of NDE methods selected
and qualifications of the technicians conducting the examinations.

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Develop Inspection Plans:

Inspection planning is a continuous process that involves the collective knowledge of inspection,
subject matter experts, maintenance and operations. Once the inspector knows what damage
mechanisms may occur and how to detect and monitor the extent of damage then planning for
inspection is required. Usually assistance is required from maintenance and/or operations to
prepare the equipment for inspection, provide scaffolding and other means for the inspector to
examine difficult to reach locations and provide other assistance so that the equipment can be
safely inspected. NDE contractors, especially those using special NDE techniques, often must
be scheduled in advance. Inspections and examinations that can be performed while the
equipment is in service should be completed prior to shutdowns. No matter how extensive
shutdown planning is, the possibility exists that something will be found during shutdown
inspections that requires additional examinations and repairs; contingency planning for such
occurrences should be part of the shutdown plans.

Perhaps the highest equipment life cycle costs are the expenses of preparing equipment for
intrusive inspections; the actual inspection and examination expenses are usually much less
especially for large storage tanks and vessels. When tank or vessel entry is required it is
prudent to do additional inspections and examinations if some future intrusive entry can be
avoided.

Conduct the Inspections, Tests and Examinations:

Inspections tests and examinations are usually started at the first opportunity even if the
inspection planning stage has not been completed. Consideration should be given to
measuring baseline thickness and use appropriate surface flaw detection techniques prior to
placing the equipment into operation. Obtaining these results prior to service provides the most
reliable methods to detect and confirm excessive corrosion, erosion or stress cracking at the
next inspection or examinations.

During shutdowns, schedules usually allow little time for inspectors to conduct additional
examinations other than those originally planned or to evaluate the inspection and examination
results. Non-intrusive examination methods should be used while the equipment is in service
whenever practical. Sometimes equipment has to be opened up for cleaning or repairs prior to
a planned inspection; it is often advisable to conduct intrusive inspections at such times
especially if intrusive inspections can be avoided during a scheduled shutdown.

Inspectors and examiners should always receive the budget and support necessary to conduct
inspections and examinations of high risk equipment. It should be recognized that during
shutdowns and other maintenance actives that suitable inspections are of equal importance to
equipment repairs, cleaning and other maintenance. The time and actions necessary for
appropriate equipment inspection should be defined by the inspection organization and not by
maintenance or operations.

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Evaluate Inspections, Tests and Examinations Results:

Perhaps the most neglected action in the inspection process is failure to adequately review the
inspection results. Too often plants depend on the guidance provided by inspection thickness
data computer programs to judge the suitability of equipment for continued service. As
discussed earlier, these programs only provide a limited assessment of mechanical integrity but
even more limiting they fail to adequately highlight many significant problem areas. All
inspection data and results should be examined and reviewed by inspectors and appropriate
subject matter experts. A suitable engineering analysis of the inspection results determines the
equipment’s present and future mechanical integrity. The analysis should quantify degradation
trends, locations and rates. When degradation is a concern, the analysis should also develop a
plan to better define those service conditions that are causing the damage and how to monitor
future degradation.

During shutdowns, the time and effort required to inspect equipment frequently does not allow
time for detailed analysis of most equipment. Equipment considered critical or where extensive
damage was found should receive at least a Fitness-for-Service, Level 1 (API 579) assessment
prior to preparing the equipment for start-up. During the shutdown planning phase, specialized
NDE firms, equipment assessment engineers and outside subject area experts should be put on
notice that their services might be required during the shutdown.

The evaluation must not only determine the equipment’s present and future status but also
directly and indirectly measure the engineering, operating and maintenance practices that affect
suitable equipment integrity.

Reports and Documents:

Reports should always be written and filed in the equipment files. When significant damage is
noted that might affect the continued equipment operations the owner/operator should be
verbally notified immediately. The reports should be in a form that conveys accurately and
unequivocally an equipment condition to operations but in sufficient detail for a thorough
analysis by subject matter experts in the future. The owner/operator must have a clear
understanding from the reports and plant inspection practices of what was and what was not
inspected, examined or tested. Where appropriate, the reports should indicate those damage
mechanisms that could have been missed by special inspection and examination techniques
used. It is often necessary to brief operations on the limitations of inspection and examinations
techniques used.

An equipment file should exist for each vessel, tank and piping circuit. These files should
include all of the design, construction, installation, maintenance, testing, inspection, engineering
assessments, operating history and other records possibly required by subject area experts or
inspectors. The equipment file should be current and kept in a known location with all of the
documents and records assessable on short notice. A paper copy should be kept of all records
and documents since electronic files might not be readily accessible several years in the future.
When critical documents such as design calculations are not available and obtainable they
should be created through reengineering. Some records such as mill test reports and prior
inspection history can not be reengineered; thus it is essential that these documents are
obtained and filed immediately upon task completion.

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Those reporting inspection and evaluation results and conclusions should be sensitive to cases
where human error may have resulted in equipment degradation. Facts and valid engineering
conclusions must always be included in the reports. Unless inspection is part of a root cause
failure investigating team, no conclusions should be drawn indicating or insinuating who was at
fault for the damage found.

Monitor Changes:

Any planned or unplanned changes in the process including what are expected to be “corrective
actions” could have some influence, either positive or negative, on damage mechanisms.
Changes that may affect equipment include fluid velocities, process stream compositions,
temperatures, pressures, equipment alterations, modifications in structural supports and
changes in materials of construction. Inspectors should be aware that changes in temperature
may result in changes in both internal and external corrosion rates. Such changes can affect
the corrosion or erosion rates, but in some cases may cause a different type of corrosion other
than general corrosion or other damage. In addition, a corrosive attack might occur at locations
in the equipment at different locations than previously found. The inspectors should consult with
subject matter experts to determine how these changes might distress the equipment.
Inspection plans may require modification to monitor such changes.

The inspector should be provided information on various corrosion monitoring programs being
conducted by corrosion engineers, water treatment contractors and shift operators. The results
of monitoring programs should be considered in inspection planning.

Maintain Effective Communications:

An inspection organization should have continuous, accurate, timely and effective

communications with all parties who can influence or have knowledge concerning equipment
integrity. Most organizations outline various communication avenues in management system
documents, organization charts and other procedural documents. Successful inspection
programs are observed to also have intangible communication aspects that are rarely
delineated in procedural documentation. Essentially these intangible aspects involve the
interpersonal relationships that exist between various plant organizations and how each
individual approaches his/her responsibilities. In ideal cases, operation and maintenance
personnel inform the unit’s inspector of all events that could affect plant integrity often by very
informal means. At the other extreme the inspector is told very little since “it is the inspector’s
job to figure out what is going on”.

All operations outside of the “normal” operating envelope should involve a mechanical review.
There are many monitoring programs to help organizations enforce this. Even if the inspection
organization is not a participant in these reviews, the details and conclusions of these
mechanical reviews should be communicated to the inspectors.

The importance of effective communications becomes evident when it is recognized that the
inspector, based on what is known, develops and implements a plan to determine what is
unknown. The less an inspector knows the more likely he is to develop plans that miss some
equipment degradation or that result in expensive and unnecessary inspections.

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Evergreening:

The inspection process including all its elements must be an evergreen process. As things
change and new events occur they must be accounted for and included in inspection planning,
execution, evaluation and reporting. Effective inspection programs continuously look for new
ways to inspect and monitor equipment and are knowledgeable about events pertaining to their
equipment that occur throughout the industry. Information gathered must be maintained and
used for the life of the equipment even though it may be thirty years old or may only be
applicable many years in the future. When unusual events occur or inspection results indicate
that current inspection plans are inadequate, the plans should be modified accordingly. After
each inspection (and evaluation) the inspection plan should be reviewed, updated as necessary
and implemented.

Conclusions:

Inspection is not a task conducted by a single group within a facility. It involves many personnel
with various jobs and responsibilities working together to determine the present and future
status of process equipment. The inspection organization not only inspects equipment but it
also gathers and assimilates the necessary information to perform a valid inspection while
coordinating the efforts of subject area experts and equipment engineers to determine
equipment status. Process changes, repairs, alterations and other corrective measures must be
monitored to determine their suitability and effectiveness in mitigating equipment degradation.
Inspection organizations may not have the formal authority and responsibility for equipment
integrity, but to be world-class they must assume a high degree of equipment stewardship.

In today’s society accountability for good cost effective mechanical integrity lies with the entire
plant team. Operations, technical, engineering and maintenance have an ever increasing
responsibility to ensure that the qualified inspectors have all of the information, tools and
funding required to help achieve optimum plant availably while minimizing health, safety and
environmental incidents. Inspection is Team Accountability.

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