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Mechanical
Integrity
19()
 | What the regulation says:
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(j)(1) Application.
Paragraphs (j)(2) through (j)(6) of this section
apply to the following process equipment:
(j)(1)(i) Pressure
vessels and storage tanks;
(j)(1)(ii) Piping
systems (including piping components such as
valves);
(j)(1)(iii) Relief
and vent systems and devices;
(j)(1)(iv) Emergency
shutdown systems;
(j)(1)(v) Controls
(including monitoring devices and sensors,
alarms, and interlocks) and,
(j)(1)(vi) Pumps.
(j)(2) Written
procedures. The employer shall establish and
implement written procedures to maintain the
on-going integrity of process equipment.
(j)(3) Training
for process maintenance activities. The employer
shall train each employee involved in
maintaining the on-going integrity of process
equipment in an overview of that process and its
hazards and in the procedures applicable to the
employee's job tasks to assure that the employee
can perform the job tasks in a safe manner.
(j)(4) Inspection
and testing.
(j)(4)(i) Inspections
and tests shall be performed on process
equipment.
(j)(4)(ii) Inspection
and testing procedures shall follow recognized
and generally accepted good engineering
practices.
(j)(4)(iii) The
frequency of inspections and tests of process
equipment shall be consistent with applicable
manufacturers' recommendations and good
engineering practices, and more frequently if
determined to be necessary by prior operating
experience.
(j)(4)(iv) The
employer shall document each inspection and test
that has been performed on process equipment.
The documentation shall identify the date of the
inspection or test, the name of the person who
performed the inspection or test, the serial
number or other identifier of the equipment on
which the inspection or test was performed, a
description of the inspection or test performed,
and the results of the inspection or test.
(j)(5) Equipment
deficiencies. The employer shall correct
deficiencies in equipment that are outside
acceptable limits (defined by the process safety
information in paragraph (d) of this section)
before further use or in a safe and timely
manner when necessary means are taken to assure
safe operation.
(j)(6) Quality
assurance.
(j)(6)(i) In
the construction of new plants and equipment,
the employer shall assure that equipment as it
is fabricated is suitable for the process
application for which they will be used.
(j)(6)(ii) Appropriate
checks and inspections shall be performed to
assure that equipment is installed properly and
consistent with design specifications and the
manufacturer's instructions.
(j)(6)(iii) The
employer shall assure that maintenance
materials, spare parts and equipment are
suitable for the process application for which
they will be used.
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| What it means:
| Employers
will need to review their maintenance programs and
schedules to see if there are areas where
"breakdown" maintenance is used rather than an
on-going mechanical integrity program. Equipment used to
process, store, ammonia
needs to be designed, constructed, installed and
maintained to minimize the risk of release. This requires that a mechanical integrity
program be in place to assure the continued integrity of
process equipment. Elements of a mechanical integrity
program include the identification and categorization of
equipment and instrumentation, inspections and tests,
testing and inspection frequencies, development of
maintenance procedures, training of maintenance
personnel, the establishment of criteria for acceptable
test results, documentation of test and inspection
results, and documentation of manufacturer
recommendations as to meantime to failure for equipment
and instrumentation.
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| The
first line of defense an employer has available is to
operate and maintain the process as designed, and to
keep the ammonia contained. This line of defense is
backed up by the next line of defense which is the
controlled release of chemicals through venting to diffusion
or overflow tanks which
are designed to receive ammonia. These lines
of defense are the primary lines of defense or means to
prevent unwanted releases. The secondary lines of
defense would include fixed fire protection systems like
sprinklers, water spray, or deluge systems, monitor
systems, etc. These primary
and secondary lines of defense are what the mechanical
integrity program needs to protect and strengthen these
primary and secondary lines of defenses where
appropriate.
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| The
first step of an effective mechanical integrity program
is to compile and categorize a list of process equipment
and instrumentation for inclusion in the program. This
list would include pressure vessels, storage tanks,
process piping, relief and vent systems, fire protection
system components, emergency shutdown systems and alarms
and interlocks and pumps. For the categorization of
instrumentation and the listed equipment the employer
would prioritize which pieces of equipment require
closer scrutiny than others. Meantime to failure of
various instrumentation and equipment parts would be
known from the manufacturer’s data or the employer's
experience with the parts, which would then influence
the inspection and testing frequency and associated
procedures. Also, applicable codes and standards such as
the National Board Inspection Code, or those from the
American Society for Testing and Material, American
Petroleum Institute, International Institute of Ammonia
Refrigeration, American National Standards Institute,
American Society of Mechanical Engineers, and other
groups, provide information to help establish an
effective testing and inspection frequency, as well as
appropriate methodologies.
|
| The
applicable codes and standards provide criteria for
external inspections for such items as foundation and
supports, anchor bolts, concrete or steel supports, pipe hangers, grounding
connections, protective coatings and insulation, and
external metal surfaces of piping and vessels, etc.
These codes and standards also provide information on
methodologies for internal inspection, and a frequency
formula based on the corrosion rate of the materials of
construction. Also needs to consider corrosion effects for
piping and valves. Where the corrosion rate is not
known, a maximum inspection frequency is recommended,
and methods of developing the corrosion rate are
available in the codes. External inspections need to
cover items such as vessel shell, bottom and head;
metallic linings; nonmetallic linings; thickness
measurements for vessels and piping; inspection for , corrosion, cracking and
bulges.
Some of these inspections may be performed by state or
local government inspectors under state and local
statutes. However, each employer needs to develop
procedures to ensure that tests and inspections are
conducted properly and that consistency is maintained
even where different employees may be involved.
Appropriate training is to be provided to maintenance
personnel to ensure that they understand the preventive
maintenance program procedures, safe practices, and the
proper use and application of special equipment or
unique tools that may be required. This training is part
of the overall training program called for in the
standard.
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| A
quality assurance system is needed to help ensure that
the proper materials of construction are used, that
fabrication and inspection procedures are proper, and
that installation procedures recognize field
installation concerns. The quality assurance program is
an essential part of the mechanical integrity program
and will help to maintain the primary and secondary
lines of defense that have been designed into the
process to prevent unwanted ammonia releases or those
which control or mitigate a release. "As
built" drawings, together with certifications of
coded vessels and other equipment, and materials of
construction need to be verified and retained in the
quality assurance documentation. Equipment installation
jobs need to be properly inspected in the field for use
of proper materials and procedures and to assure that
qualified craftsmen are used to do the job. The use of
appropriate gaskets, packing, bolts, valves, lubricants
and welding rods need to be verified in the field. Also,
procedures for installation of safety devices need to be
verified, such as the torque on the bolts on ruptured
disc installations, uniform torque on flange bolts,
proper installation of pump seals, etc. If the quality
of parts is a problem, it may be appropriate to conduct
audits of the equipment supplier's facilities to better
assure proper purchases of required equipment which is
suitable for its intended service. Any changes in
equipment that may become necessary will need to go
through the management of change procedures. |
| 5-year
Mechanical Integrity inspections must be
performed by an independent, non-biased party.
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