With the recent catastrophic and fatal pressure vessel (PV) failure in KY, I have to speak up and point out a very dangerous and unfortunately common failure we see in our work. Far too often we visit a facility under the guise of doing process safety work and we typically find the PSM covered PVs and their PRDs are in a MI program. However, in the same room we can find PVs and their PRDs that are 40+ years old and never once been inspected and the PRD has never been tested, much less replaced. We are almost always told “Thanks, but please stay focused on the PSM process”.
And to put the cherry on top of this ______ Sunday, many of these organizations will proclaim they are utilizing the Serious-Injury-Fatality (SIF) Risk Management Model. There is not much more SIF than a catastrophic failure of a PV. With this said, I offer the following advice to those who really want to manage these SIF risks across the organization.
All PVs and their PRDs need to be managed via a common database. I always used my Centralized Maintenance Management System (CMMS). One of the most common misses we find are “air receivers”. The record find is a 53 year old receiver that had zero inspection history and had been used in “other services” that an “air receiver”.
By placing all Stamped PVs and their PRDs into a database, we can then get them on an inspection schedule. But this requires resources to be directed to do this work and then to manage the on-going inspection program. I have seen this done as a site-wide program or by each department. The person managing this program needs to be knowledgeable in PV design and their inspections.
Please understand, you should not be surprised when you find dozens to hundreds of Stamped PV within your workplace. These PVs can even be found inside machinery.
Once the PV’s are in the database, we then turn to their PRDs. Understand that newer PV will most like have PRD “Trees” rather than a single PRD. This newer design allows for the PRD maintenance without having to drain and gas-free the vessel. This means we could have more PRDs than we do PVs. This also means more data to manage and more pieces to inspect/test.
Lastly, remember – PVs start off with a 10-year inspection frequency; However, over time, this frequency will increase due to the “Remaining Service Life” of the vessel. And PRDs are typically on a 5-year schedule, which means we will be busier with PRD inspection/testing than we will be with PV inspections.
SAFTENG members can read all my other articles on PV inspections and PRD inspection/testing to understand how best to manage these safety critical elements.