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2013 California State Emphasis Program

UPDATE September 19, 2013 Pipe Clamp/Seal Procedures and Practices in California Petroleum Refineries. 2013 California State Emphasis Program. A SLIP OF THE TONGUE. During a 4 Crude Unit meeting with regulators Chevron personnel admitted they were “thinking about” clamping the leak.

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2013 California State Emphasis Program

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  1. UPDATE September 19, 2013Pipe Clamp/Seal Procedures and Practices in California Petroleum Refineries 2013 California State Emphasis Program

  2. A SLIP OF THE TONGUE • During a 4 Crude Unit meeting with regulators Chevron personnel admitted they were “thinking about” clamping the leak. • So the question was asked, “How many of these leak seals do you have?” • “We’ve done about 2,000 in last ten years”.

  3. No, seriously; About 2,000 in the last ten years. Refinery Regulators

  4. But the Real Question is… Are They legal? No, Not Online Lawyers…

  5. Are Pipe Clamps Legal? • Yes they are…and if used as a temporary repair they can be quite safe.

  6. Our Mission (should you decide to accept…) • To ensure California Refineries are following Good Engineering Practices when it comes to sealing leaks in process piping.

  7. Legal Foundation Title 8: Section 6845 (a)……the testing, inspection, and repair of all piping systems shall comply with … and API 570, Piping Inspection Code, Second Edition, October 1998, Addendum 3, August 2003; and ASME B31.3-2002, Process Piping; herein incorporated by reference.

  8. API 570, Section 8.1.4Nonwelding Repairs (On-Stream) “During turnaround or other appropriate opportunities, temporary leak sealing and leak dissipating devices, including valves, shall be removedand appropriate actions taken to restore the original integrity of the piping system.“

  9. LEAK SEAL Inspection Protocols • All 15 Refineries in California will be inspected • Review “Leaking Pipe” databases (if available) • Search database narrow field of inspection; • high temperature (>600 deg) • Priority: high or emergency • Liquid in pipe that would burn or is toxic. • Not steam, not condensate. (water) • (*exception: control on a process?) • Select targets • Request specific dates of last turnarounds

  10. Types of Temporary Repairs Observed • Clamps (flange, valve) • Pipe wraps • Wire wraps • Crimps • Injection fittings All are “non-welding” repairs

  11. Emphasis Program results so far…(The Good) • A Wilmington Refinery • Based on site visits to this location 37 different Temporary Non-welding Repairs also known as leak seals, clamps, TLRs, etc. were visually observed. This employer has an effective MOC and Turnaround repair program for temporary non-welding repairs as of the date of our visits. • No temporary non-welding repairs in place after their MOC expired. • No temporary non-welding repairs left in place after the last turnaround in their respective units. • One violation of 8 CCR 5189 was issued, but this was for a recordkeeping violation regarding a missing date in management of change documents.

  12. Emphasis Program results so far…(The Good) • Same Wilmington Refinery • The employer has a robust sulfidation corrosion prevention program in place before our visit and before the Chevron Richmond incident. • Stop Work Authority • Their head operators have the authority to shut a unit down. The incident commander has the authority to shut down. They have shut units down before and this is confirmed in their incident investigation reports over the last 5 years.

  13. Emphasis Program results so far…(The Good) • A Carson Refinery • Temporary non welding repairs installed, monitored and replaced by next turnaround and before their MOC time periods run out; • Sulfidation corrosion prevention program Actively looking for excess corrosion in areas of crude distillate over 500 degrees F, and identifying and removing A56 carbon steel and replacing it with higher corrosion resistant chromium alloyed steels.

  14. Emphasis Program results so far…(The Good) • A Carson Refinery continued… • Stop Work Authority • Head operators have the authority to independently order shut down of a unit and have done so in the past per a review of previous incident reports. • No violations observed concerning TLR’s.

  15. Emphasis Program results so far…(The not so bad) • Some of the Other Refineries in California • Most temporary repairs were gone (86%) • Some still there and awaiting first turnaround, i.e. still under MOC • Some still in place passed TA, awaiting next TA, still under MOC • Some were past life stated in the MOC • Some given MOC of ten years.

  16. Emphasis Program results so far…(The not so bad) • Title 8 §6845(a) citations: • 9 leak seals past TA date (6 of these injection fittings) • Left in place 11 to 30 months past last TA • Some in place 5 to 7 years past MOC replacement date. • MOC Violations • 3 repairs beyond own MOC dates • One MOC given 8 years even though in the MOC said maximum 5 years.

  17. Emphasis Program results so far…(The Ugly) • OK, Wake up… First question to the group. Yes, it’s a PSM Question… • If I have a carbon steel pipe with a leak in it and I use a carbon steel patch to stop the leak, do I need to conduct a management of change i.e. MOC?

  18. Emphasis Program results so far…(The Ugly) • Answer number one… • Since the patch is made of carbon steel and the leaking pipe is made of carbon steel then they are “like in kind” as defined in 5189(l) – Management of Change or… • Answer number two… • Since the integrity of the pipe may be compromised an MOC should be initiated to review inspection and testing data of leaking pipe, consider conducting a PHA to determine consequences of actions, and conduct a review operating procedures. • AND THE ANSWER IS…Number 2

  19. Emphasis Program results so far…(The Ugly) • At one small, not in the area refinery, the compliance officers found 15 sections of pipe with welded patches on them… • And NO paperwork to justify the safe use of carbon steel patches. • By no paperwork we mean no MOC, no inspection or testing results, no PHA’s, no nothing… • Would that scare you if you worked at the refinery?

  20. Emphasis Program results so far…(The Ugly) • But we’re not done yet… • Other deficiencies noted… • Confined Space • Energy Control • Emergency Eyewash and Safety Shower • Machine Guarding • Respiratory Protection • Emergency Response (or lack thereof)

  21. So…What Does It All Mean? • I Don’t Know, What Do You Think? ME? I think Refineries in California…except one…So Far…Are Doing a Really Good Job.

  22. Questions???

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