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Table of Contents Introduction to Integrity Operating Windows..........1 Purpose and Scope of this RP.................................4 Definitions and Acronyms of IOW Related Terminology............................................................5 Data and Information Needed to Establish IOWs...7 Types of IOWs........................................................8 Examples of IOWs..................................................9 Work Practices for Defining IOWs and Their Limits 11 Documenting and Implementing Established IOWs 14 Monitoring and Measuring IOW Parameters.........17 Updating IOWs.....................................................18 Roles, Responsibilities and Accountabilities for IOWs....................................................................18 Integrating IOWs with Other MI Work Processes..20
Introduction to Integrity Operating Windows
1.1.In order to maintain the integrity and reliability of pressure equipment in the refining and petrochemical industry, management systems for several process safety initiatives are necessary. Most of those management systems are oriented toward having a rigorous inspection program, as well as all the supportive engineering activities to maintain pressure equipment April 27, 2010 Page 1
API RP 571 Damage Mechanisms Affecting Fixed Equipment in the Refining Industry API RP 572 Inspection Practices for Pressure Vessels API RP 573 Inspection of Fired Heaters and Boilers API RP 574 Inspection Practices for Piping System Components API RP 575 Methods for Inspection of Atmospheric and Low Pressure Storage Tanks API RP 576 Inspection of Pressure Relieving Devices API RP 577 Welding Inspection and Metallurgy API RP 578 Material Verification Program for New and Existing Alloy Piping Systems API RP 579 Fitness for Service API RP 580 Risk-Based Inspection API RP 581 Risk-Based Inspection Technology API RP 582 Welding Guidelines for the Chemical, Oil and Gas Industries API RP 583 Corrosion Under Insulation (pending publication) API RP 585 Pressure Equipment Failure Investigation (pending publication)
1.2.But well founded and well managed inspection and mechanical integrity systems applying the above standards alone cannot maintain the integrity of pressure equipment in and of themselves. Three other process safety management (PSM) systems are vital to support a rigorous inspection and mechanical integrity program in order to avoid pressure equipment leaks and failures. They include:
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1.15. CCP: Corrosion Control Parameters uncontrollable process variables that are similar to IOWs but may not require predesignated operator intervention, but that may still need to be trended and reported to determine if inspection or corrosion control activities may need to be adjusted in order to avoid long term equipment damage. 1.16. CLD: Corrosion Loop Diagram same as a CMD and PCD
1.17. CMD: Corrosion Materials Diagram a modified process flow diagram showing areas of similar corrosion mechanisms, similar operating conditions, and similar materials of construction in each portion of the unit, as well as the usual PFD information. Some CMD varieties are annotated with historic corrosion problem sites. 1.18. Critical IOW Limit an established IOW level defined as one at which the operator has one last opportunity to return the process to a safe condition and, if exceeded, could result in significant defined risks in a fairly short timeframe 1.19. Fixed Equipment see pressure equipment
1.20. IOW: Integrity Operating Window Established limits for process variables that can affect the integrity of the equipment if the process operation deviates from the established limits for a predetermined amount of time.
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1.24. PCD: Piping Circuit Drawing a modified PFD showing areas of similar corrosion mechanisms, similar operating conditions, and similar materials of construction in each portion of the unit. Same as CLD. 1.25. PFD: Process Flow Diagram A simplified diagram of a process unit showing the main pieces of equipment and piping, with limited details of process design parameters. 1.26. PHA: Process Hazards Analysis A work process to assess the hazards and risks associated with a operating a process unit. 1.27. PSM: Process Safety Management the practice of
1.28. Pressure Equipment Stationary or fixed equipment for containing process chemicals under pressure, as opposed to rotating equipment which has moving parts for the purpose of causing process fluids to move through pressure equipment. Pressure equipment includes such items as piping, vessels, reactors, tanks, pressure relief devices, columns, towers, and filters. 1.29. RBI: Risk-Based Inspection The work process for assessing the risks associated with pressure equipment in order to prioritize inspection activities and to produce a detailed inspection plan. 1.30. ROL: Reliability Operating Limit another term for standard IOW limit or CCL 1.31. SME: Subject-matter-expert One who has in-depth knowledge and experience on any particular subject as it relates to IOWs, e.g. corrosion/materials SME; process SME; operations SME. 1.32. SOL: Safe Operating Limit another term for Critical IOW Limit
1.33. Standard IOW Limit an established IOW level defined as one that if exceeded over a specified period of time could cause some specified undesirable risks to occur. At the standard IOW limit level, the operator will generally have some predetermined action to take, which may vary from process control to seeking guidance from supervisors or appropriate other technical personnel. April 27, 2010 Page 6
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1.36. In order to facilitate the effectiveness and efficiency of the IOW work process, this information should be collected and brought to the IOW team meeting to the extent possible.
Types of IOWs
1.37. Typically IOWs fall into two categories of limits, physical and chemical. 1.38. Physical limits are those that are not chemical in nature, but include all other aspects of a process design that are vital to maintaining control within established design parameters. Examples of physical limits include: various limits on pressure and temperatures including design, operating, partial pressures, dew points, dry points, heating and cooling rates, delta P, etc., In addition there are flow rates, injection rates, inhibitor dosage, amperage levels for contactors, slurry contents, hydrogen flux, vibration limits, corrosivity probe measurements, etc. 1.39. Chemical limits, as the name implies are those that relate to the chemistry and fluid content of the process. Examples of chemical limits include: pH, water content, acid gas loading, sulfur content, salt content, NH4HS limits, NH3 content, TAN, acid strength, amine strength, inhibitor concentration, chloride contamination levels, oxygen content, etc. 1.40. Clearly the above lists of examples of physical and chemical limits are not all inclusive and are meant only to stimulate thinking about the potential process parameters that may need IOWs established in order to avoid process safety incidents associated with integrity breaches of pressure equipment (both short and long-term). 1.41. At least two levels of IOWs are common, which can be labeled with different names. For purposes of this document they are referred to as standard and critical limits, but may also be referred to as reliability and safety limits, among other names. A standard IOW level is defined as one that if exceeded over a specified period of time could cause one or more of the following to occur after some period of time : Loss of containment, A release of hydrocarbons or hazardous fluids, Page 8
1.42. Standard limits may in some cases be just more conservative limits set prior to reaching critical limits to provide the operator with more time and options for regaining control before the more drastic measures required for exceeding a critical limit must be implemented. 1.43. Most IOWs are controllable, but some are not and may not have an immediate type of operator intervention assigned to them. But deviations from design conditions can still lead to accelerated corrosion or other damage over a longer period of time. Uncontrollable parameters still may need to be reviewed, trended and reported to designated technical personnel so that planned inspection activities can be adjusted to determine if accelerated damage may be occurring. For purposes of this document and to differentiate the two types of IOWs, uncontrollable IOW parameters will be referred to as Corrosion Control Parameters (CCPs). However, in this document, when the term IOW is used, it generally applies to specific controllable parameters as well as CCPs.
Examples of IOWs
1.44. Heres an example (figure 1) of an IOW set for high temperature hydrogen attack (HTHA). Note that mechanical design limits from the construction code for the vessel are outside the IOW limits for the process, which are set by applying the Nelson curvesin API RP 941. Note also that although the start-of-run conditions are within the IOW, the end-of-run
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Some examples of critical IOW limits would include: Boiler Feed Water Level Loss of boiler feed water level could quickly cause boiler tube rupture
Hydroprocess Reactor Temperature Metal temperatures below the MDMT could give rise to brittle fracture
Heater Tube Skin Temperature Tube could rupture quickly if overheated, caused, for example, by a no flow or hot spot condition.
Sulfuric Acid Strength in Alkylation Too low acid strength could cause runaway reaction
Atmospheric relief system on a major piece of pressure equipment Over-pressure could result in major environmental and/or community impact
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Would like to have more examples Some examples of standard IOW limits would include: REAC NH4HS Concentration Corrosion of the air cooler and downstream piping
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Crude Fractionator Dew Point Temperature Sustained operation below dew point could cause damage to fractionator internals or potential loss of containment.
pH of Crude Tower Overhead Sustained operation below standard pH level could lead to corrosion of tubing and piping and potential loss of containment.
Hydroprocess units Water and/or chloride carry-over in hydrocarbon feed streams or hydrogen could cause accelerated corrosion from ammonium salts and hydrogen chloride solutions.
Desalter Outlet Salt Content Sustained operation above standard level could lead to corrosion and potential loss of containment
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Would like to have more examples Some examples of CCPs include: Ammonia content in a crude overhead system that could be assessed to determine if ammonium chloride fouling and corrosion may be occurring. Need several more examples
1.49. More detailed, specific examples of IOWs for two process units are included in Appendix A. A suggested tabular reporting of IOWs is shown in Appendix B, including the IOW, the related damage mechanisms, the required response, the timing of the response, and related information.
1.51. The quality of the process and therefore the quality of the IOWs produced is dependent upon the synergy from the interaction of this group of knowledgeable, experienced SMEs. 1.52. Once the process of identifying all the potential and likely equipment degradation and failure modes is complete, then the same group looks at the process variables that can have an impact on the type and rate of deterioration that can occur and begin to set the limits on those process variables to avoid accelerated, unexpected or excessive degradation. Process conditions at startup, shutdown, during likely and/or historic operational upsets should be considered. There are numerous documented cases within the industry of accelerated corrosion and cracking rates of materials of construction under adverse conditions than range from 10-20 mils per year to a few inches per year. The materials/corrosion specialist will need to have this type of information in hand to help the team decide what the appropriate operator response needs to be and how fast the actions need to be implemented. (consider including a generic chart of examples of accelerated degradation rates in some process streams like the COP table) 1.53. One of the facilitators roles should be oriented toward eliciting information about what is actually happening in the field relative to what is in the documented records or what is thought to be happening by those who are not operators. The facilitator needs to have a knack for when to ask probing questions to get to fully understand issues that may impact the IOW work process. Discussions should take place about historical problems as well as changes that are anticipated in the process unit. As mentioned before, there may be upper and lower limits that need to be established and there may be one or more levels of those limits with different actions within different time frames required as each IOW level is exceeded. 1.54. Risk analysis may/should be applied in the IOW establishment process to determine what is the level of risk to which equipment might be exposed for each type of exceedance of each designated process variable. Clearly this risk assessment would then help to determine what actions the operator needs to take and how fast the operator needs to act before things get too April 27, 2010 Page 12
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Operating Operating Window Window 1.60. Figure 3. Zones of operation including target ranges with standard and critical limits
1.62. There may be numerous ways to document each set of IOWs for each process unit. Here are two suggested ways, one being a more detailed (and thereby more useful from a broader perspective) and the other being a more concise (and therefore simpler, but less useful from a broader perspective). 1.63. Include the IOWs as part of a comprehensive document on corrosion control in every process unit. These documents have been called Corrosion Control Documents (CCDs), Corrosion Control Manuals (CCMs), or RiskBased Inspection (RBI) Data Files by some in the industry. Some of the possible inclusions in such a document include, but are not limited to: Description of the process unit and the normal process conditions Shutdown, start up, and abnormal operating conditions that may affect corrosion and other degradation mechanisms, including the possibility of inadvertent contamination of process streams with unexpected but possibly predictable corrosive species, Process Flow Diagrams (PFDs) showing construction materials, Corrosion Loop Diagrams (CLDs) or Piping Circuit Drawings (PCDs), which are areas of similar corrosion mechanisms, similar operating conditions, and similar materials of construction in each portion of the unit, Probable types of degradation, damage and fouling in each corrosion circuit, where each damage mechanism is expected to occur, the relative susceptibility to the damage mechanisms, as well as likely damage rates expected to occur and under what circumstances, A history of corrosion problems that have experienced in this process unit or similar units, Quantitative and predictive models for the degradation mechanisms, Page 15
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Updating IOWs
1.70. The IOW list should be periodically updated to account for process changes, hardware changes, inspection results or new information about degradation mechanisms, or perhaps even a variable that was overlooked in the original IOW establishment process (not uncommon). The MOC process should be applied whenever IOW variables are being revised or updated, utilizing the same types of SMEs that were used to generate the original IOW list. If the generic site MOC process proves to be too time-consuming or burdensome for IOW updates, then a modified MOC process specifically addressing IOW updates has proven for useful for some owner users.
1.72. Inspection personnel have a role bringing data to the IOW team for creating and updating IOWs, as well as adjusting inspection activities as necessary when IOW exceedances are reported to them. 1.73. Corrosion/materials specialists have a role in bringing the materials/corrosion degradation information and analysis to the IOW team for creating and updating IOWs, as well as a role in understanding exceedances and advising inspection personnel on how inspection activities might need to be revised to account for the exceedance, if any, as well as advising process engineers on process issues that may be needed to avoid long term materials degradation issues. A corrosion/materials specialist will often have the role and responsibility of facilitating the IOW team, as well as documenting and distributing the results of the IOW work process. The corrosion/materials specialist may also have a role in providing operator training on IOWs. 1.74. Operations has a role in bringing information about current operating practices and data to the IOW team for creating and updating IOWs. But their main role is in monitoring and responding to any IOW exceedances in the manner designated in the IOW control system and documentation. Additionally operations has the responsibility to communicate any IOW exceedance in the designated manner to other designated stakeholders for their potential actions. 1.75. The unit process engineer has the role of bringing process design and engineering data to the IOW team for creating and updating IOWs. Often the unit process engineer is the designated owner of the IOW list and responsible to ensure that all IOWs are properly and continuously implemented in the manner designated in the IOW documentation. The owner of the IOW work process would also have the responsibility to ensure that exceedances were properly reported to others and a role in responding to exceedances and ensuring that responses to exceedances were handled and implemented in a timely manner. 1.76. Plant management has the role and accountability of ensuring that the IOW work process is adequately staffed with knowledgeable, experienced SMEs, that the work process is carried out in a timely manner, that all IOWs agreed upon are implemented in a timely manner, and that adequate April 27, 2010 Page 19
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Example list of potential IOWs for a generic amine process unit Amine concentration Water content Rich amine acid gas loading Lean amine acid gas loading Regenerator steam to feed ratio Velocity in rich amine piping Velocity in lean amine piping? (Is this really an IOW?) Reboiler steam temperature (Is this a design parameter, rather than an IOW?). Heat Stable Salt (HSS) concentration (you will need units for this) Iron content in circulating amine (Is this really an IOW?) Sour water velocity from regen O/H condenser to reflux drum (Is this really an IOW?) Amount of reflux being purged (% vol) Temperature of acid gas piping to SRU (Is this an issue? Is it not always at ambient?) Total suspended solids % vaporization after pressure letdown CV (if piping is CS) Example list of potential IOWs for a generic crude distillation unit Example list of potential IOWs for a generic hydroprocess unit Example list of potential IOWs for a generic alkylation process unit
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