Following the guidance of OSHA and EPA, the industry has attempted to simplify what type of change requires the initiation of the Management of Change system and which type of change is a “replacement in kind” (RIK). Oddly enough, both OSHA and EPA chose not to define the meaning of “change”; instead, they have officially defined what a “replacement in kind” would be by stating… Replacement in kind means a replacement that satisfies the design specifications. For years, the PSM/RMP community has felt that if we had a valve with the same materials of construction throughout the valve components, and the performance specifications for items such as pressure and temperature were the same, we were doing a “replacement in kind.” I want to challenge this approach from a first-hand account I had in a PSM-covered process.
Since my incident in the late ’90s, I have ALWAYS included a Mechanical Integrity review in my evaluation of a “change” vs. “RIK.” We had replaced hundreds of valves during a shutdown because of performance issues with the current “brand” of the valve. The new valves we were installing were an EXACT match as far as “performance specifications” such as operation, installation method, materials of construction, pressure rating, temperature rating, etc. However, these valves had a MUCH DIFFERENT mechanical integrity inspection frequency! We went from a valve that needed annual inspection, testing, and exercising to a valve that needed this attention on a quarterly basis. We missed this in our review, as all we looked at was “performance specifications” and not necessarily the “design specifications”, and there is a difference! When the process was “designed,” items like “maintenance costs” and “downtime” were certain considerations. The reason why the original valves were used was simply to reduce downtime due to preventative maintenance requirements. After all, a process having several hundred valves that need only ANNUAL attention has a MUCH LOWER maintenance cost and a MUCH HIGHER UP-TIME than a process using valves that require quarterly attention.
The biggest concern from this lesson is how we learned it. Several months, but less than 12 months after our shutdown, we had a significant release of our HHC. The release was “reportable”; thus, we received some regulatory scrutiny because of the incident. During a PSM review by our local OSHA office, the first documentation they asked for was the PSI related to the failed valve. On the surface, a review of “performance specifications” all looked OK. They then reviewed our PHA to see if we had considered the failure of piping and piping components, which we did, and this is where they could have made our lives difficult! In our PHA, we had listed as a “safeguard” for pipe/pipe component failure that the piping and valves were in our MI Inspection/Testing program (PM Program). So OSHA asked a simple question… if the valve meets “specifications” and the valve is included in the MI/PM program, then what went wrong for this valve to fail in the manner it did to cause a significant release.
As many of you know, OSHA has up to six months to complete its inspection/investigation. And it was during these six months that more of these valves failed. These incidents were not reportable releases because of the actions and changes we made after the first incident. However, being a VPP STAR site, we self-reported this to OSHA since we had issues with these “new” valves. OSHA returned and asked to see the work order history of these valves since they had been installed during the shutdown less than a year earlier. They also asked to see the contractor qualifications of the contractor firm that installed the valves (although the contractor turned out to be a dead end, this shows how OSHA will travel down many different roads to find defects in your management systems). With the PSI in hand and the work order history, OSHA needed only about 4 hours to identify a serious issue. They contacted the manufacturer of the new valves to validate their finding, which the manufacturer validated. Right in the valve booklet (e.g., specification sheet) of the new valves, it states that the valves are required to be exercised and inspected every three months. In fact, some of the tasks the manufacturer of the new valve called out were CRITICAL misses that we were NOT doing because we did not update our “maintenance procedure” for these valves because we treated it is a “RIK”!!!!! We had MISSED THESE CRITICAL TASKS since their installation nearly nine months earlier, AND we were missing a bunch of quarterly inspections on each one of these valves (of which several had already failed).
There was a lot of debate as to whether we complied with the MOC element and if citations were in order. It came down to the fact that we were a VPP STAR site, and the company was in the top five companies with VPP sites – so no citations! However, we were warned that we needed to broaden our approach to MOCs and RIKs. By the way, the EPA was not as forgiving and issued an NOV for the reportable release but did not do an RMP inspection, as this all happened before June 21, 1999.
I now have a keen eye for this type of scenario during our audits, and we can find similar occurrences at just about every facility we audit. To give you some idea of how prevalent they are, here are some examples to look out for:
Area vapor detectors – Regardless of what you are detecting, most facilities will take the approach that if the set points of the detectors are not being changed with the new “brand name” detectors, a MOC is not required. This has led to “calibration frequencies” not being met. We have found a facility or two using the incorrect cal/span gases because they did not realize the new sensors required different span ranges of their cal gas. Also, don’t forget that the Maintenance Procedures will also need to be changed, and with no MOC, this normally does not happen, AND this is an EASY FIND for any auditor/inspector.
Safety Instrumented Systems (or just basic interlocks) – The majority of processes with HHC/EHS will rely on some varying degree of Safety Instrumented Systems(SIS) or just plain old interlocks. Take, for example, a Hi-Hi Level SIS on a storage tank. The system will sound an alarm, turn off a pump and close a valve when tripped by Hi-Level in the vessel. This SIS contains dozens of “parts”, of which different manufacturers make many times. The same assumptions apply here as with the vapor detector example above… as long as we are not changing set points within the SIS, MOC is unnecessary. In fact, many facilities still struggle with the level of detail they will have on file for the “safety systems”. Most will have the Hi-Hi Level SIS listed but often will not define the interlock logic (e.g., what happens when the set point is reached) in the PSI. With this said, this leads to the MI program’s flaws, as the Work Order system will list the SIS as a piece of equipment and NOT each component within the SIS. This is CRITICAL, as each component of the SIS needs to meet strict failure frequencies in order for the SIS to meet our demand needs. We have seen several SISs that were designed and installed properly, but have been bastardized over the years to the point that the system would not pass “kindergarten”, much less an SIS test! Because the different components are from different manufacturers, they will have different inspection/testing/calibration frequencies and requirements. We could defeat one of our critical process safeguards when we do NOT consider these inspection/testing/calibration frequency requirements of EACH component.
A manufacturer upgrades their pump model after 50 years of successful design. They keep the same model # and name for the pump but advertise that it saves energy due to it’s increased efficiencies in pumping. The pump is built using the same materials of construction, the same size motor, the same pump curve, etc. The only thing that changed was the RPM the pump operates at. And due to the increased RPMs, the new pump contains a “manufacturer’s recommendation” to conduct a vibration analysis at least every 12 months. The other change that comes with the new pump is its synthetic oil. Because the “performance specs” (e.g., psi, materials of construction, temperature, pump curves, etc.) were the same, a MOC was not done, and the “manufacturer’s recommendations” for the new oil and the vibration analysis were missed. Thus, our MI program is now deficient!
I hope I have sparked a renewed interest in your Management of Change efforts with these “lessons learned” and that you will hopefully take a step back and ask… could this happen here with our process(s)? I also hope that you have a clearer picture of what a “design specification” is, versus what a “performance specification” is, which scratches the surface of a change that could significantly impact our process safety efforts.