Thermo Scientific NITON Analyzers

Seminar on ‘Positive Material Identification’ (PMI) TransCanada Calgary, Alberta, Canada July 9, 2014

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Presenter: Don Mears

• President of Analytical Training Consultants • Oil & Gas Industry Consultant • Author of API RP 578 2nd Edition PMI Certification Course • Certified API Training Provider Certification TPCP# 0118 • 30+ Years in the Oil & Gas Industry • API Member and Sub-Committee Member on API

Inspection Summit 2015 and Co-Chairman for the Re-write of API RP 578 PMI Recommended Practice

API/TPCP -0118

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What and How Important is Mitigating Corporate Risk for Safety & Environmental Issues ?

• Transcanada map.pdf • As we look ahead, our strategic focus remains

clear. In pursuing our vision to become the leading energy infrastructure company in North America, we strive to execute on our current portfolio of large, attractive projects and initiatives and to continue to work to cultivate a high-quality portfolio of future growth opportunities.

• In addition to our over $46 billion of assets, we

have a superior growth portfolio that will see us invest approximately $22 billion in a number of energy infrastructure projects throughout North America. The majority of these projects are under construction and are expected to be completed over the next three years.

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Goals for Canadian Association of Petroleum Producers ( CAPP) & American Petroleum Institute ( API) are very Similar

• Energy • Economy • Environment • Canadian Energy Development-

CAPP-4-7-2014.pdf • Environment, Health & Safety • www.API.Org

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“Codes and Specifications for Mitigating Corporate Risk” New Construction Projects

• You are very environmental & Safety conscience !

• But what are you currently doing to “Confirm that the Line Pipe” meets the correct “Material Chemistry” ?

• Keystone-XL-PHMSA-57-Special-Conditions.pdf

• http://www.phmsa.dot.gov/pipeline

Do you just Trust your Pipe Suppliers-Mill Test Reports ( MTR’S) ?

Look at Condition # 4-Program must Eliminate defects in “Chemistry as affecting pipe quality.”

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New Construction: Do Not Rely Solely on Supplier “Material Test Reports” (MTR’S)

• Experience has shown that you cannot rely on material test reports (MTR’S) alone; there can be significant errors.

• One customer site survey revealed as much as 20%-30% of material test reports (MTR’S) did not match actual chemistry. They also tend to loose the reports. They get separated from the existing material.

“Trust but Verify” - This is what PMI Does !!!

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New Construction: PMI Cycle Overview- Renewed & Now Required Emphasis

PMI Program needed to confirm the MTR Chemistry for QA/QC- Too Late in the field !!!!!

Residual Elements found in Carbon Steel

(i.e. Cr, Cu, Ni , Mo, V, Ti) MTR’s Normally do not test

for these Elements and should not be in the Carbon

Steel ! But They Are There!!!

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• Material Certifications: (7.2) Material Certifications, mill test reports, or Certificates of Compliance should not be considered a substitute for PMI testing, but may be an important part of an overall quality assurance program.

• Shop and Field PMI Test Documentation: ( 7.3) • Those individuals performing PMI testing should obtain and follow the PMI test

procedure approved by the owner/user. • This procedure should cover the techniques used , equipment calibration, the qualification

requirements of the PMI test personnel, the testing methodology, and documentations requirements.

• When documentation, such as drawings, is used in lieu of physical marking, the documentation should allow the owner/user to identify which components were tested.

• New and Existing Piping Systems Documentation: ( 7.4) • When PMI testing is conducted on new or existing piping systems, records of the results

should be kept as long as the piping system exists in its original location. • If a piping system or a portion of a piping system that has not received material verification

is relocated, the owner/user should consider the need for PMI testing prior to placing the relocated components into service.

Recording & Reporting PMI Test Results: API RP- 578

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Recording & Reporting PMI Test Results-API RP-578

Traceability to Field Components; the information listed in “PMI Test Records” should be reported in such a manner that they are traceable to the point of installation. The best way to tie the “Report Documentation” to the field P&ID or ISO drawings, is to mark the drawings ( Electronically or Manually) and enter this (drawing number) in the XRF/OES Analyzer. It is strongly suggested that you keep both paper and electronic files on this documentation.

Interface with “Data Management Software” (i.e. PCMS, Ultra-Pipe, Meridian, Solid AIM & RBI Software & PCIMS)

Enter data into Analyzer

PMI PMI

PMI PMI

PMI

PMI

API RP 578 2nd Edition for PMI Certification Course

“Codes and Specifications for Mitigating Corporate Risk”

Training Course Advantage Explained on

API RP-578 by

Don Mears Analytical Training Consultants

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Introduction to API 578 PMI Certification Course

• Purpose of the API Course • To certify and re-certify (every 3 years) API inspectors, NDT Technicians and

designated key personnel in understanding and applying API RP 578 in the proper Use and Application of procedures for utilizing XRF and OES technologies for PMI.

• TWO (one-day sessions) • Classroom instruction on API RP 578 2nd Edition guidelines • Hands-on PMI field testing procedures. • Understanding of API RP 578 Guidelines & Applications in the Field • Application of proper XRF and OES PMI testing procedures • Testing both Written on Academic's and Examination on Testing of Metals • American Petroleum Institute (API) Certification

In today's risk-based QC environment, the need for positive material identification (PMI) has grown dramatically in refinery and petrochemical plant operations, requiring 100% alloy material verification for designated critical components. Meets RAGAGAP requirements for OSHA,BSEE,NTSB,DOT,PHMSA

“Codes and Specifications for Mitigating Corporate Risk”

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API 578 PMI Certification Course

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QA QC for New Construction Projects, Need PMI

API RP 578 PMI (Downstream Document) Don Mears – Co-Chair for Re-Write. Setting up task force. Invited: Upstream and Midstream Sectors to participate: Mike Childers, SW Gas and Scott Boker, TransCanada

“Codes and Specifications for Mitigating Corporate Risk”

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PHMSA's Proposed Pipeline Penalties Hit All-Time High; Serious Pipeline Incident Count Hits All-Time Low

• Agency Proposed Largest-Ever Collective Civil Penalties in 2013; Tougher Penalties Helping Contribute to Increased Pipeline Safety

• (PHMSA) announced that in 2013, it proposed more than $9.7 million in civil penalties against pipeline operators who violate safety regulations. The figure is the highest yearly amount of proposed penalties in the agency's history.

• Since 2009, PHMSA has proposed more than $33 million in civil penalties against pipeline operators, $10 million more than the amount proposed in the previous five years combined. It has also issued 544 enforcement orders over the past five years, constituting more than half of all orders issued by the agency since 2002.

• PHMSA also reports 45 percent less serious pipeline incidents, those resulting in fatalities or major injuries, since 2009. The count has declined each year since 2009.

• The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 doubled the maximum civil penalty amount PHMSA is able to impose against pipeline operators for violating pipeline safety regulations from $100,000 to $200,000 for each violation, and from $1,000,000 to $2,000,000 for a related series of violations.

• Information taken from: PHMSA 02-14 Monday, April 7, 2014 Contact: Jeannie Shiffer Tel: 202-366-4831

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“Codes and Specifications for Mitigating Corporate Risk” Vintage Pipeline

• Mike Childers to explain what he is doing “Key hole” technology with SW Gas. • Explain: “Plains Justice Report “- Defective Steel traced back to Steel Mills had

improper “Material Chemistry”. Low levels of (Mg, V ,Nb, Mo),PHMSA-Low Chemistry-Plains Justice report on 2009 Bulliton.pdf

• Explain: “ Alternative Yield Strength Test Method”-Oregon Public Utility Commission, (OPUC) on 12/11/2012 -Granting the “Avista Utilities of Spokane” , Washington-Phase 2 “ Establishment of Yield Strength Using Sub-size Samples with out Gas Line Shutdown”-Waiver Request -Portion of the requirements found in CFR title 49, Part 192.1 07(b) and, by reference, Part 192, Appendix B, Section II, Paragraph D.

• To allow Utilities Company to determine the yield strength of these segments without taking the lines out of service or utilizing a bypass system by using an accepted and commonly used specimen removal technique. Further, the alternative test method will provide yield strength values that are likely to be conservative compared to full-size specimens. The alternative yield strength test method and the smaller specimens are therefore consistent with pipeline safety.

• Oregon_2013.pdf

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Vintage Pipeline Inspection needs: Keyhole Technology

• Locating-The first step in the keyhole process is pipe location. Precise location of facilities is important due to the reduced size of excavations through keyholes .GTI researchers are developing new, advanced technologies for locating plastic pipe, cast-iron joints, and pipe leaks.

• Coring-Common keyhole methods involve creating a pavement opening only 12 to 18 inches in diameter, usually made with a circular-drill core-hole cutter, allowing for remote access to the facilities. Restoration is accomplished by replacing the cut pavement coupon after repairs are made.

• Vacuum Excavation-Once the core has been cut and removed, vacuum excavation is used to excavate down to the pipe. Debris removed from the hole is stored in a tank on the vacuum truck, and, ideally, the debris can be re-used to backfill the keyhole.

• Construction & Maintenance Activities-With the help of specialized, long-handled tools, construction and maintenance can be conducted through a keyhole opening. Activities currently performed through keyholes include: potholing/depth checks, valve box cleanouts, meter guard installations, plastic pipe squeeze-offs, service installation and abandonment, catholic protection, and cast-iron joint sealing.

• Backfill & Pavement restoration-Backfill and soil compaction are integral to the effective replacement of the cut core. Using the proper materials during backfill and core replacement will prolong the life of the pavement. To improve the process, GTI is conducting studies on measurement devices to assure proper soil compaction.

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Key Hole Technology-Vacuum Excavate to Expose the Buried P/L then Back Fill the hole

Long-handled tools used to grind away the pipe coating, to do PMI on the pipe !!!

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Use Key Hole Technology for Metal Chemistry PMI

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“Codes and Specifications for Mitigating Corporate Risk” New Construction & Vintage Projects-Benefits Summarized

• “Trust but Verify” MTR’S by checking the “Material Chemistry” with XRF • Compare the MTR’S per Line Pipe and Component's to confirm the “Heat

Number” for the Mill’s MTR ( Random per Heat Number) • Provide complete records of “ Material Chemistry Verification” for your

Construction Quality Program, and Operations • Verify we are using the correct materials to “ Mitigate Corporate Risk” • Improve & Insure the Quality & Performance of the XRF operator with

applying the API 578 PMI Certification to requirements • Cost/Loss-”Benefit Ratio”-By increasing pipeline safety and reducing the

chance of incorrect material entering the construction process or finished product

• Provide Proof to Regulators that pipe MTR Chemistry is being verified as required by project quality programs and owner requirements

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Questions & Answers

• Don Mears • Analytical Training Consultants & Oil & Gas Consultant • 1719 Burning Tree, kingwood, Texas ( USA) 77339 • Web: www.ATC578.Com • Don@ATC578.Com or Don.Mears@Thermofisher.com • Phone: +1 (281) 684-8881

API/TPCP -0118

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Positive Material Identification (PMI) XRF Technology Explained

“Codes and Specifications for Mitigating Corporate Risk”

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Kα x-ray

Lα x-ray

X-Ray Fluorescence (XRF) – A Simple Overview

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-

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-

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K L M-shells

1.25% Cr

0.5% Mo

………

1. X-ray ejects K-shell electron

2. L-shell electron moves to replace ejected K-shell electron, M-shell electron replaces L-shell, etc…

3. Reduced energy state is given off as a “Kα”, “Lα”, etc. x-rays, the energies of which are read by the detector

4. The x-ray energies and fluxes are interpreted by the analyzer into the corresponding elements, concentrations, and resultant alloy grade

Alloy Grade P11

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How the XRF Works

Each individual element produces its own set of characteristic x-rays; the basis for qualitative analysis

By counting the number of

characteristic x-rays of a given element we can determine its concentration; the basis for quantitative analysis

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XRF Spectrum

qualitative

quantitative

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How Filters in XRF Automatically Work the Element Range in the Periodic Table

“ Low Filter “engaged Automatically for : Ti ,V , Cr

“ Main Filter“ engaged Automatically for : All Elements

“ Light Filter “engaged Automatically for : S, P, Si, Al, Mg

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Fundamental Parameters Calibration

• Iterative mathematical calculations estimating and correcting for inter-element effects on element excitation and fluorescence.

• Automatically compensates for wide range of alloy concentrations, where inter-element effects can be substantial.

• From detection limit to 100% • Versatile, non-matrix specific. • Standardless; no on-site empirical calibration • Most robust calibration method for handheld XRF

• All alloy groups and concentration ranges covered • No user involvement or expertise required.

• Allows point-and-shoot for all alloy groups with no method choosing or switching required

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• API 5L-Line Pipe inspection for chemical elements for weld pre-heat and post heat treatment (PWHT-Stress Relief). Elements affect the hardenability, which affects the depth & distribution of hardness induced by quenching. The heat affected zone (HAZ). Leads to delayed hydrogen cracking, and loss in ductility and toughness.

• PSL 1 Welded Pipe-API 5L Table 4 (X42 to X70 Welded Pipe) • PSL 2 Welded Pipe-API 5L Table 5 (X42M to X120M Welded Pipe)

• Maximum Carbon Equivalency-Table 5 (two formulas)

• Maximum on elements that affect the carbon equivalency (CE) are:

• Mn, Cr , Mo , V , Ni , Cu (V, Si & B for CEpcm) • XRF analyzer can put these formulas (less carbon) in the software and give you an

equivalency factor (EQF) with all other elements and download them to an Excel spreadsheet.

Inspection Program – Pipeline Material Compatibility when Welding

Use when “Carbon Mass Fraction” is: </= 0.12%

Use when “Carbon Mass Fraction” is: >/= 0.12%

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XRF Example of Equivalency Factor (EQF)

Carbon Equivalency CE = 0.345 %

Don Mears

Oil & Gas Industry Consultant

Handheld X-ray Fluorescence for PMI & BSEE,PHMSA, & NTSB- Upstream Offshore & Transportation Sector

“Codes and Specifications for Mitigating Corporate Risk”

Let’s Learn and Profit from the Mistakes of Others !!!!

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Also on October 1, 2011, the new Bureau of Safety and Environmental Enforcement (BSEE) was created to enforce safety and environmental regulations. Functions include: All field operations including Permitting and Research, Inspections, Offshore Regulatory Programs, Oil Spill Response, and newly formed Training and Environmental Compliance functions

WWW.BSEE.GOV

The Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMER) Changed to (BSEE)

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PMI Inspection Program for Deep Water Sub-Sea Equipment – Important Before Installation

• Confirm with PMI that your material is in specification before Fabrication.

• Confirm all supply parts (valves, flanges, pipes, welds, etc.) are what is specified for application.

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Pipeline and Hazardous Material Safety Administration

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PHMSA issued Advisory Bulletin 09-01 on May 21, 2009 • This bulletin advises pipeline operators of material problems – inconsistent chemical ( PSL 2 specifications ) and material properties ( Yield Strengths, & Tensile Strengths) that have been found in micro alloyed high-strength line pipe grades, generally grade X-70 and above. • Some pipe material did not meet the requirements of the American Petroleum Institute,

Specification for Line Pipe—5L, (API 5L), 43rd edition for the specified pipe grade even though the pipe supplier provided documentation that the pipe met these minimum standards ( MTR’S)

• It suggests that pipeline operators closely review manufacturing specifications for the production and rolling of steel plate. ( Trust by Verify with PMI )

• PHMSA-Low Chemistry Plains Justice report on 2009 Bulliton.pdf

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Pacific Gas and Electric Company Natural Gas Transmission Pipeline Rupture and Fire

The released natural gas ignited, resulting in a fire that destroyed 38 homes and damaged 70. Eight (8) fatalities, many were injured, and many more were evacuated from the area.

San Bruno, California September 9, 2010

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Pipeline Fracture Origin and Failure • Based on this analysis, which was progressively weakened due to ductile

crack growth and fatigue crack growth. • Deficiencies in fabrication of accident pipe segment

• Owing to the lack of documentation • The girth weld contained a lack of fusion/lack of penetration defect, the size and shape of which

concentrated the stresses at the weld. In addition, pup 4 contained phosphorous and copper, which are known to cause brittle welds. (This could have been found with PMI)

• Deficiencies in quality control associated with 1956 relocation project • Given the identified weld and pipe deficiencies, NTSB investigators sought to understand how the

substandard pipe piece could have been installed and remain in service undetected until the accident 54 years later.

• The investigation revealed no records of radiography for the 1956 relocation project, nor were there records of hydrostatic testing, which might have ruptured the pipe at the time of installation.

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“Recognized And Generally Accepted Good Engineering Practice” (RAGAGEP): API RP 578

Engineering, operation, or maintenance activities based on established

codes, standards, published technical reports, or recommended practices (RP) or a similar document. RAGAGEPs detail generally approved ways to perform specific engineering, inspection, or mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or servicing a relief valve (See CCPS [Ref. 33]).

Reasons Why – RAGAGEP?

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• Occupational Safety and Health Administration (OSHA) Acts • Process Safety Management (PSM) 1910-119-Highly Hazardous Chemicals (HHC) 2/24/1992 • The Bureau of Ocean Energy Management, Regulation and Enforcement-(BSEE) 10/1/2011 • USA (DOT) Pipeline & Hazardous Materials Safety Administration (PHMSA) Title 49: CFR title

190-199 updated currently: P/L is 192 (Gas) and 195 ( Liquids) • National Transportation Safety Board (NTSB ) Accident Investigation Reports –”On Going”

• American Petroleum Institute (API) • API RP 75: Recommended Practice for Development of a Safety and Environmental

Management Program for Offshore Operations and Facilities (adopted by BOEMER) • Standard API 5L-Specification for Line Pipe 44th editon-10/1/2007 (45th Edition Completed) • Recommended Practice API RP 578: Material Verification Program-MVP/PMI( needs input from

Upstream and Midstream in Re-write for 3rd edition as Annex's for Sectors needs.

• Where does PMI fit in the Offshore & Transportation sectors • ASTM PMI Designation: E 147-97 “is intended for Tutorial Purposes only” • MSS SP-137-2007: Quality Standard for PMI of Metal Valves, Flanges, Fittings & Other Piping • API 1104: Welding of Pipelines and Related Facilities • ASME section IX, Boiler and Pressure Vessel Code, Section IX: Welding and Brazing

Qualifications • AWS D1.1: Structural Welding Code - Steel

Why Did USA Establish the Regulation & Enforcement Programs for Off Shore and Transportation?

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API 5 L-(44th Edition) for Line Pipe • Currently API 5L “Does NOT” stress Confirming the Chemical Analysis for

Elements with Positive Material Identification (PMI) with either XRF or OES field Analyzers !!!! The Question is Why NOT?????: May be the need for PMI should be mentioned in API 1104, where knowing the“Material Chemistry” is very important for proper welds ????

• We have already shown you that the “ End User” can no longer rely only on ---Material Test Reports ( MTR’s)----

• OSHA has a “Nation Emphasis Program” (NEP) to Enforce (RAGAGEP ) for the Market Segments in the Oil & Gas Downstream both Refining & Petro Chemical facilities and found that Mechanical Integrity (MI) is the number one Violation ( 19.4% to 23.8%) of “Process Safety Management” (PSM)- Process Safety Management (PSM) 1910-119-Highly Hazardous Chemicals (HHC). “Trust but Verify” - This is what PMI

Does !!!

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Element Percentage Min or Max

Copper (CU) = 0.50% Max

Nickel (Ni) = 0.50% Max

Chromium (Cr) = 0.50% Max

Molybdenum (Mo) = 0.15% Max

Sum (Nb + V) </= 0.06% Max

Sum (Nb + V + Ti) </= 0.15% Max

Boron (B) </= 0.001% Max

Do you confirm these elements are within these limits ???

Table 4 – Chemical Composition for PSL 1 Pipe with t ≥ 25,0 mm (0.984 in.)

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Table 5 – Chemical Composition for PSL 2 Pipe with t ≥ 25,0 mm (0.984 in.)

Element – Table 5 Percentage Min or Max Table 5 Annex-N – adopted ISO 3183 – for Europe Addendum 3 effective date 1/1/2012

Copper (CU) = 0.50% Max No Change

Nickel (Ni) = 0.30% Max Ni = 1.00%

Chromium (Cr) = 0.30% Max Cr = 0.55%

Molybdenum (Mo) = 0.15% Max Mo = 0.80%

Sum (Nb + V) </= 0.06% Max No Change

Sum (Nb + V + Ti) </= 0.15% Max No Change

Boron (B) </= 0.001% Max B </= 0.004%

PMI/XRF analyzers can confirm these (except boron) min/max, specs

“Codes and Specifications for Mitigating Corporate Risk”

• Positive Material Identification (PMI) For: • Downstream Refining Sector • Downstream Petro Chemical Sector

Don Mears Oil & Gas Consultant &

API/TPCP Certified Training Provider

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Introduction: “Why should you implement PMI according to API 578 ?”

• Note: The leading insurance industry statistics indicating that the US

refining sector has more than three times the rate of property losses of refineries overseas.

• Dr. Moure-Eraso with USA Chemical Safety Board (CSB) urges

companies to take action to prevent accidents, including: –Implement a robust “mechanical integrity” programs with an

emphasis on thorough inspections of critical equipment –Monitor process safety performance using appropriate leading

and lagging indicators to measure process safety “before major accidents” occur

–Maintain an open and trusting safety culture where near-misses and loss of containment incidents are reported and investigated

Close-up of ruptured heat exchanger

Aerial view of the damaged heat exchangers following the April 2, 2010 fire

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Introduction: “Corrosion Failures in Process Piping”

• 41% of the largest losses in the hydrocarbon processing industry resulted from failures in piping systems.

• Corrosion is one of the leading causes of piping failures. • OSHA’s National Emphasis Program (NEP) includes positive material

identification (PMI) as a part of Mechanical Integrity (MI)

• “Recognized And Generally Accepted Good Engineering Practices” or “RAGAGEP”

–Example RAGAGEP for PMI: • API RP 578, Material Verification Program for New and Existing

Alloy Piping Systems, Section 4.3 • CSB, Safety Bulletin – Positive Material Verification: Prevent

Errors During Alloy Steel Systems Maintenance, BP Texas City, TX Refinery Fire

Second International Symposium on the Mechanical Integrity of Process Piping January 1996, Houston, TX, USA

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Why OSHA Establish the NEP Program in USA? • Occupational Safety and Health Administration (OSHA) Acts

• Process Safety Management (PSM) 1910-119-Highly Hazardous Chemicals (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 • Chemical National Emphasis Program ( CHEMNEP) (CPL 03-00-014)-Nationwide 11/29/2011

• American Petroleum Institute (API) • Standard-API-570-Piping Inspection Code • Standard-API-510-Pressure Vessel Inspection Code • 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 ) • Recommended Practice-API 939-C-Guidelines for Avoiding Sulfidation

• Mechanical Integrity Needs in the Oil & Gas Industry • Understanding HOW, WHY, & APPLYING:

ATC – API 578 PMI Certification Training Course AIM- Asset Integrity Management MI- Mechanical Integrity Requires, “ Data Management” Software

Don Mears

Oil & Gas Industry Consultant

Handheld X-ray Fluorescence for PMI & OSHA’s (NEP)-”National Emphasis Program” Downstream Refining Sector

“Codes and Specifications for Mitigating Corporate Risk”

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• According to OSHA’S refinery database:

• 36 fatality/catastrophe (FAT/CAT) incidents • Related to 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-12 FAT/CAT • Industrial Organic Chemical Manufaturing-12 FAT/CAT • Explosive Manufacturing-11 FAT/CAT

Why Did OSHA Establish the NEP Program in USA ?

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Hazards Identified: Total Violations Rise; Serious and Repeat Violations Increase

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% Total Willful Violations 404 462 747 479 415 2.7

Total Repeat Violations 2,147 2,360 2,350 2,551 2,714 26.4%

Total Other-than-Serious 20,552 21,705 20,819 19,246 18,331 -10.8%

BP Texas City, Texas: Fined $30.7 million for 439 willful violations on 10/30/09-Resolved 409 citations in July 2012 and paid $13 million by end of year !

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Refinery NEP Enforcement Summery from 2007-20012

• Comprehensive-(151 Refineries in USA) • Average 1,000 OSHA hours per inspection • Typically use full statutory 6 months available • Also resource intensive for employers • Compliance found to be highly uneven • Substantial issues identified • Average penalties/inspection ~$166,000 • Average penalty/violation ~$9,560 • Average violations/inspection ~17.4

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Refinery NEP Most Frequently Cited PSM Elements

Element Description % of Citations

Cumulative %

j 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% 89.6% h Contractors 2.8% 92.5% g Training 2.7% 95.2% n Emergency Planning & Response 1.5% 96.7% c Employee Participation 1.4% 98.1% i Pre-startup Review 1.1% 99.2% k Hot Work Permit 0.8% 100.0%

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Inspection Scheduling by OSHA’s NEP – All Refineries Section E-10-Question on PMI

Positive Material Identification (PMI)

Does the employer ensure that replacement piping is suitable for its process application? Yes, No, N/A

If no, possible violations include: The employer did not follow RAGAGEP when it failed to conduct positive

material identification (PMI) testing. Example RAGAGEP for PMI: API RP 578, Material Verification Program for New and Existing Alloy

Piping Systems, Section 4.3) CSB, Safety Bulletin – Positive Material Verification: Prevent Errors

During Alloy Steel Systems Maintenance, BP Texas City, TX Refinery Fire

Don Mears

Oil & Gas Industry Consultant

Handheld X-ray Fluorescence for PMI & OSHA’s CHEM NEP- Downstream Petro Chemical Sector

“Codes and Specifications for Mitgating Corporate Risk”

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Chemical Safety Board (CSB) Established in1990

• After the deadly 1989 explosion of Phillips Houston Chemical Complex that claimed the lives of 23 people in Pasadena, Congress setup a system designed to reduce the number of chemical accidents by forming the investigative board, known for short as CSB. Congress established the board to overhaul the Clean Air Act and to create an independent agency designed to keep tabs on the chemical and petroleum industry.

• According to the findings of the U.S. Chemical Safety and Hazard Investigation Board, since 1998 an average of five plant workers have been killed every month in the United States by explosions or leaks of chemicals that have become integral to modern industrial life.

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CSB Releases Case Study on Fatal 2008 Accident at Goodyear Tire and Rubber Plant in Houston, Texas

• “Recognized And Generally Accepted Good Engineering Practice” (RAGAGEP):

• Is what OSHA/CSB require from our Petro Chemical Companies !!!!

• The accident occurred on June 11, 2008, when an overpressure in a heat exchanger

• CSB identifies gaps in facility emergency response training and calls for increased adherence to existing industry codes.

• CSB Investigations Supervisor Robert Hall said, “We found the accident likely would not have happened had operators followed the ASME code”

• CSB investigations look into all aspects of chemical accidents, including physical causes such as equipment failure as well as inadequacies in regulations, industry standards, and safety management systems.

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• As of August, 2010, 112 inspections opened • 38 Un-programmed (34%) • 74 Programmed (66%) • 9 resulted in no inspection occurring because there was no PSM

covered process • 62 inspections have issued citations • Average 9.0 citations per inspection • Average $3,500 per citation • Over 60 different standards cited • 44% of all citations were other than PSM

• Therefore: OSHA Released :Chemical National Emphasis Program (CHEMNEP) (CPL 03-00-014)-Nationwide 11/29/2011

Chemical Plant NEP Inspections for Pilate Program in Regions (1,7,10)

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Chemical Plant NEP Citations by PSM Element

Element Description % of PSM

Citations Cumulative % j Mechanical Integrity 23.8% 23.8% d 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 3.4% 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 1.0% 100.0%

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Reasons Why – RAGAGEP ?? • “Recognized And Generally Accepted Good Engineering

Practice” (RAGAGEP): API RP-578 Engineering, operation, or maintenance activities based on established

codes, standards, published technical reports or recommended practices (RP) or a similar document. RAGAGEPs detail generally approved ways to perform specific engineering, inspection or mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or servicing a relief valve (See CCPS [Ref. 33]).

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Conclusion- Questions & Answers-XRF Demonstration