This is another case where OSHA and EPA compliance may be the least of our concerns, as this is REAL LIFE process safety – NOT compliance work! Yes, we have to comply with our repair RAGAGEP; but I was referring to whether a facility does a MOC or not. Let’s examine this type of work and you may be surprised at my answer to “Is a MOC required when making repairs to an ASME pressure vessel?”
Scenario:
We have a nozzle on a pressure vessel, and during the vessel’s MI inspection, it was found that this nozzle has been damaged and needs a “repair.”
In the most basic of terms, this repair, although tightly controlled, MAY NOT require a MOC to meet compliance with 1910.119 or Part 68.
Do I use the MOC tool to MANAGE this type of change – ABSOLUTELY, But I am the type of safety professional who views the MOC as a tool and not a compliance requirement to make OSHA/EPA happy.
This type of change may be small in area – but it is HUGE in its potential impact on a business and its process safety. Using the MOC, I would scope out all of the process safety information that needs to be CREATED and UPDATED, as well as have special meetings with contractors who wish to bid on the job as this job requires an “R stamp” which is a rare certificate to hold. Doing this work incorrectly equates to potential catastrophic risks and a huge mess with regard to the pressure vessel’s future use.
But in the big scheme of things, we plan to cut out to damaged nozzle and replace it with an exact replica. We plan to do so per NBIC Part 3 requirements. This work falls squarely into the “Replacement in Kind” (RIK) category, which requires no MOC. But if there was ever a project that screams for a MOC, repairing a pressure vessel is one!
Now for the flip side of the argument…
This work will require me to update my Process Safety Information (PSI) in the forms of an “R form” from the contractor doing the work, a revised “U-1 form”, and a new vessel nameplate – so in this regards, many would do a MOC AND a PSSR since the change was significant enough to require an update to the PSI.