One of the more common misses by a lot of businesses, especially those using pressure vessels (PVs) in their PSM/RMP covered processes, is the “initial inspection” at the time of installation. We have discussed the “change of service” inspection several times; however, this inspection is for NEW PVs being installed. This requirement will certainly apply to those facilities that have adopted API 510 as their PV inspection RAGAGEP, as well as any state or local jurisdiction that has adopted it.
The code is very clear in its language, so why many miss this requirement is beyond me. Kudos to OSHA for starting to issue citations against this requirement:
(emphasis by me)
API 510
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6.2 Inspection During Installation and Service Changes 6.2.1 Vessel Installations 6.2.1.1 Pressure vessels SHALL BE inspected by an inspector AT THE TIME OF INSTALLATION. The purpose of this inspection is to verify the equipment is safe for operation and that no unacceptable damage occurred during transportation to the installation site, and to initiate plant inspection records for the equipment. This inspection also provides an opportunity to collect desired baseline information and to obtain the initial thickness readings at designated CMLs. The installation inspection SHALL VERIFY: a) the nameplate information is correct per the manufacturer’s data reports and design requirements; b) the equipment is installed correctly, supports are adequate and secured, exterior equipment such as ladders and platforms are secured, insulation is properly installed and flanged, and other mechanical connections are properly assembled and the vessel is clean and dry; c) PRDs satisfy design and installation requirements per the requirements in API PR 576. If noncompliance is found or the requirements for the PRD are not met, document and recommend appropriate repairs or engineering assessment that may be necessary to confirm the vessel is FIT FOR SERVICE and properly protected from over-pressure. 6.2.1.2 Internal field inspection of new vessels is NOT REQUIRED; provided appropriate documentation (e.g., manufacturer’s data reports and final shop inspection report) assures the vessels comply with the specified design and specification requirements. |