Training Course Explained

on

API RP-578

By
Don Mears
Analytical Training Consultants
September 19,2007
Guidelines & Application Procedures
For
Positive Material Identification
(PMI)
with
XRF & OES
Technologies

By
Don Mears
Analytical Training Consultants
¾ Introduction

ƒ Analytical Training Consultants has written and submitted to

API a training course on API-RP 578 for approval by the
committee.
ƒ The Committee has written the Second Edition and is in the
Balloting Stage ( Ballot 578-01-07 ).
ƒ A Committee member of API-RP 578 asked us to speak at this
“72nd Fall Refining and Equipment Standards Meeting” and
explain :
¾ Why Should this Course be Given ?
¾ Purpose of the Course
¾ Explain the need and requirements for “Positive Material
Identification” (PMI) using XRF and OES Technologies
` What is the Purpose of this Course ?

ƒ Purpose of the Course is to certify and re-certify API 570 inspectors, in

understanding and applying API RP 578 through an approved API
Training Course, that will qualify personnel in proper Guideline and
Application procedures utilizing XRF and OES technologies for PMI.

` The course will be covered in 2 day sessions and instruction on both

classroom theory and field testing procedures.

ƒ Through Understanding API RP 578 Guidelines

ƒ Through Application of proper PMI testing procedures

` The need and now requirement for Positive Material Identification

(PMI) has dramatically grown in the past few years in refinery and
petrochemical plant operations to 100% alloy material verification in
today's risk-based QC environment.

Analytical Training Consultants 11/26/2007 4

` Why should this course be given?
No
¾OSHA Instruction Directive # CPL 03-00-00-04
Catastrophe
¾Chemical Safety Board-BP Texas City Refinery Fire
Proper PMI
¾Chemical Safety Board-DPC Enterprises, Festus,
Missouri-Chlorine Release
¾All the
Proper
Reported & Unreported “ Near Misses” the Oil &
Training has experienced, but because of:
Gas Industry
¾ Luck
¾ Proper PMI, Inspection
¾ Training
¾ (RAGAGEP ) / API –RP 578

Analytical Training Consultants 11/26/2007 5

¾Why Should this Course be Given ?
¾ OSHA INSTRUCTION: Directive number CPL 03-00-004, effective June
7, 2007, which is the “ Petroleum Refinery Process safety Management
Emphasis Program”. The purpose: “this instruction describes policies
and procedures for implementing a National Emphasis Program (NEP)
to reduce or eliminate the workplace hazards associated with the
catastrophic release of highly hazardous chemicals at petroleum
refineries
..\..\Copy of all Research Material\Industry Reference Material\OSHA Instruction
(NEP).pdf

Analytical Training Consultants 11/26/2007 6

¾ Why Should this Course be Given ?
ƒ Safety Bulletin from U.S. Chemical Safety and Hazard
Investigation Board (CSB)—BP Texas City, Texas
Refinery Fire!!!!
ƒ ..\Training Course ATC-Final for API\Appendix Section
8\RHUBulletin-BP Texas City.pdf

Analytical Training Consultants 11/26/2007 7

` Why Should this Course be Given ?

ƒ Safety Bulletin from U.S. Chemical Safety and Hazard

Investigation Board (CSB)-Chlorine Transfer Hose
Failure due to improper material braid construction
(i.e., 316L and not the recommended braid of
Hastelloy C-276). On August 14, 2002, a 1-inch
transfer line ruptured during a railcar offloading
operation at DPC Enterprises in Festus, Missouri and
released 48,000 pounds of Chlorine into neighboring
area.
ƒ ..\Training Course ATC-Final for API\Appendix Section
8\CSBChlorineShutdownBulletin.pdf

Analytical Training Consultants 11/26/2007 8

¾ Why Should this Course be Given ?
¾ NEP= National Emphasis Program
¾ Scope- This instruction applies OSHA-Wide
¾ State Plan- Sates Adoption is not Required
¾ Action Offices- National, Regional, and Area Offices (AO)
¾ Originating Office- Directorate of Enforcement Programs (DEP)
¾ Executive Summary-This instruction provides guidance to Occupational
Safety and Health Administration (OSHA) national, regional, and Area Offices
and state programs which choose to implement a similar program concerning
OSHA's policy and procedures for implementing an National Emphasis
Program NEP to reduce or eliminate workplace hazards associated with the
catastrophic release of highly hazardous chemicals at petroleum refineries.
¾

Analytical Training Consultants 11/26/2007 9

¾ Why Should this Course be Given ?
¾ Purpose-This instruction describes an OSHA National Emphasis
Program (NEP) for inspecting petroleum refineries (refineries)
included in Standard Industrial Classification (SIC) 2911 [North
American Industrial Classification System (NAICS) 324110] and
contains policies and procedures to verify employers’ compliance
with OSHA’s Process Safety Management (PSM) of Highly
Hazardous Chemicals standard, 29 CFR 1910.119.
¾ References-
¾ Federal Register Vol 57 Number 36 Process Safety Management
29 CFR 1910.119
¾ CPL 02-02-045-PSM Compliance Guidelines and Enforcement
procedures

Analytical Training Consultants 11/26/2007 10

¾ Why Should this Course be Given ?
ƒ References Cont’
¾OSHA CPL 02-00-103-Field Inspection Reference Manual
¾OSHA Refinery Location List (DEP) Intranet website
¾API RP 578-Material Verification Program for New and
Existing Alloy Piping Systems
¾Safety Bulletin-”Positive Material Verification: Prevent
Errors During Alloy Steel Systems Maintenance, BP
Texas City, TX Refinery Fire. U.S. Chemical Safety and
Hazard Information Board (CSB)

Analytical Training Consultants 11/26/2007 11

¾ Why Should this Course be Given ?
ƒ Expiration- This Instruction is in effect until further
notice
¾Application- OSHA compliance personnel shall ensure
that the directive are followed when inspecting the
refineries selected under this NEP
¾Federal Program Change: Establishes
¾ National Emphasis Program ( NEP)- SIC-2911/NAICS
324110
¾ Process Safety Management ( PSM )-Standard 29 CFR
1910.119

Analytical Training Consultants 11/26/2007 12

¾ Why Should this Course be Given ?
ƒ Application to State’s- They must respond to OSHA a
notice of intent, either; OSHA’a Emphasis Program or
State’s Plan
¾Background: OSHA NEP because of a “Large number “
of fatal or catastrophic incidents in petroleum refining !
¾Stats since the PSM was promulgated by OSHA in
1992:
¾ No other Industry Sector has had as many fatal or
Catastrophic Incidents related to the release of “Highly
Hazardous Chemicals ( HHC) as the “Petroleum
Refining Industry”!!!!

Analytical Training Consultants 11/26/2007 13

¾ Why Should this Course be Given ?
¾According to OSHA’S Data Base;

¾ Since May 1992 (36) Fatality/Catastrophe (FAT/CAT)

incidents related to HHC have Occurred
¾ Incidents include 52 Employee Deaths and 250 Employee
Injuries, 98 required Hospitalization
¾ The number of “Refinery” Incidents Surpasses the
Combined Total of the next 3 highest Industries over the
same period
¾ Chemical Manufacturing-12 FAT/CAT
¾ Industrial Organic Chemical Manufaturing-12 FAT/CAT
¾ Explosive Manufacturing-11 FAT/CAT

Analytical Training Consultants 11/26/2007 14

¾ Why Should this Course be Given ?
¾According to OSHA’S Data Base : ( Examples Used )
¾ BP Texas City Texas, March 23,2005 had:
Killed-15 people
Injured-170 people
¾ Kern Oil, Bakersfield, California, January 19,2005
Killed -1 person
Injured- Multiple
¾ Giant Industries Ciniza Refinery, Gallup, New Mexico,
April 8,2004
Killed – None
Injured-6 people
Hospitalized-4
‰ The above Reasons to Practice: RAGAGEP

Analytical Training Consultants 11/26/2007 15

¾ Why Should this Course be Given ?

¾ “Recognized And Generally Accepted Good

Engineering Practice” (RAGAGEP) – are
engineering, operation, or maintenance activities
based on established codes, standards, published
technical reports or recommended practices (RP) or
a similar document. RAGAGEPs detail generally
approved ways to perform specific engineering,
inspection or mechanical integrity activities, such as
fabricating a vessel, inspecting a storage tank, or
servicing a relief valve (See CCPS [Ref. 33]).
¾
Analytical Training Consultants 11/26/2007 16
 Master List Generation Exceptions
¾ Deletions. Based on their familiarity with local refineries, ROs
and AOs shall delete from the master list:
¾ Any refineries that are known to be out of business,
documenting the basis for such determinations;
¾ Any refinery establishment which is an approved participant in
OSHA's Voluntary Protection Programs (VPP), or in OSHA
Consultation's Safety and Health Achievement Recognition
Program (SHARP); or
¾ Any refinery establishment that has already received an
inspection under this NEP.
¾ Covered in the next 2 years

¾ 40% in the First year

¾ 60% in the Second Year

¾ Important information is found in APPENDIX A regarding the
“Static List of” Inspection Priority Items (IPI) and contains
questions that the Compliance Safety and Health Officer
(CSHO)’s are to address in their compliance evaluation of an
employer’s refinery “Process Safety Management” (PSM)
program.
¾ It should be noted that both PMI and proper OPERATOR
TRAINING programs are QUESTIONS that the (CSHO) will
address to the Owner/Operator as to compliance with their
Process Safety Management (PSM) program.
 Positive Material Identification (PMI)
¾ Does the employer ensure that replacement piping is suitable
for its process application?
¾ Yes, No, N/A
¾ If no, possible violations include:
¾ The employer did not follow RAGAGEP when it failed to conduct
positive material identification (PMI) testing to ensure that
construction materials of replacement/repaired piping were adequate
for process conditions (An example RAGAGEP for PMI testing for
existing piping systems includes but is not limited to, API RP 578,
Material Verification Program for New and Existing Alloy Piping
Systems, Section 4.3), and CSB, Safety Bulletin – Positive Material
Verification: Prevent Errors During Alloy Steel Systems Maintenance,
BP Texas City, TX Refinery Fire);
¾
 Proper Operator Training
¾ Have operating employees been trained on the procedures they
are expected to perform? If NO, Possible Violations Include:

¾ The employer did not provide initial operator training on each

specific procedure operators are expected to perform; or
¾ 1) The employer did not document the training,
¾ 2) The employer did not document the means used to verify the
training, or
¾ 3) The employer did not verify that the operator understand the
training.
¾
 Proper Operator Training
¾ Based on the employer’s explanation of their management
of operator refresher training (See document request in Section
X.E.3.o.), have the five randomly selected operating employees
received, completed, and understood the refresher training
(See document request in Section X.E.3.n.)? For each
employee who operates a process, has the employer ensured
that the employee understands and adheres to the current
operating procedures and that the refresher training is
provided at least every three years-- more often if necessary?
¾ YES, NO,N/A
 Proper Operator Refresher Training
¾ If no, possible violations include:

¾ 1) The employer did not provide operator refresher training at

least every three years or more often, if necessary (e.g., on a
frequency consistent with that determined through
consultation with employees); or
¾ 2) The employer did not document the training;
¾ 3) The employer did not determine that the operator
understood the training it received; or
¾ 4) The employer did not document how it verified the training
 Incident Investigation Report
¾ The CSHO must document in the INCIDENT INVESTIGATION
REPORT the number of “Actual” and a “Near-Miss” incident
which has occurred in you plant. A very important part of this is
the “Factors that contributed to the incident”. In section Q of
Appendix A OSHA list examples and PMI and Training are a
part of this list:
¾ Examples of "Factors that contributed to the incident”/“causal
factors” can include, but are not limited to:
¾
 Incident Investigation Report
¾ Examples of "Factors that contributed to the incident”/“causal
factors” can include, but are not limited to:
¾ The employer did not design, operate, maintain, inspect, or
change (MOC) equipment or equipment systems per
RAGAGEP;
¾ The employer did not train its employees in its procedure for
transferring product from the Chemical X intermediate tank to
Reactor 23;
¾ The 3-inch reactor transfer line was replaced without
conducting a PMI, as a result, the replaced piping that was
constructed of an off-specification material failed in a short
period of time;
¾ Because of the previously discussed information and my
experience with both selling and training personnel in the
Petrochemical and Refining Oil and Gas business, “Analytical
Training Consultants” is producing the PMI Training Course:

¾ For this reason we have been invited to ask you in the industry
to review our course and have an open discussion with your
input, so it will properly meet your industry needs in
development of a “Process Safety Management” (PSM)
program.
Training Course Explained
on

API RP-578

By
Don Mears
Analytical Training Consultants
September 19,2007
¾ THROUGH UNDERSTANDING API RP 578 GUIDELINES ( DAY 1 )
¾ Scope of the Course
¾ General
¾ Alloy Substitutions in Carbon Steel Systems
¾ Roles and Responsibilities
¾ Industry References
¾ Terms and Definitions
¾ Extent of Material Verification Program
¾ Explain use of Material Verification Program Test Methods
¾ Field Evaluation of PMI Test result procedures
¾ Proper Marking and Record Keeping
¾ Review and Testing on Academic Material of API-RP-578
¾ THROUGH APPLICATION OF PROPER PMI TESTING PROCEDURES ( DAY 2 )
¾ Using XRF Technology- (Hands-on Application/Demonstration)
¾ Review of XRF Technology
¾ Who should use it?
¾ What is XRF – Technology Explained
¾ When should XRF be used?
¾ Where should XRF be used—Types of Alloys
¾ How should XRF be used—PMI methods and Procedure Guidelines
¾ Why should XRF be used-Percent of PMI needed?
¾ THROUGH APPLICATION OF PROPER PMI TESTING PROCEDURES ( DAY 2 )
¾ Using XRF Technology- (Hands-on Application/Demonstration)
¾ Testing Procedures and Operation (Hands-on with Analyzer)
¾ Instrument Operation Safety, Radiation Safety, State Regulations
and Registration Requirements
¾ Instrument power on/off, calibration and reference checking

¾ Sample handling, preparing, positioning, accessory tools needed

¾ Instrument features, modes, utilities, libraries, field entries, etc.

¾ Instrument calculations, Fundamental Parameters (FP) Empirical

Calculations, Teach and Match, Spectrum Match
¾ Instrument download, upload, PC software features and reports.

Example of Live Hands on with XRF:

..\..\..\..\..\..\..\Desktop\NDTr 6.0.lnk
¾ THROUGH APPLICATION OF PROPER PMI TESTING PROCEDURES ( DAY 2 )
¾ Using OES Technology-(Hands on application/Demonstration)
¾ Review of OES Technology
¾ Who should use it?
¾ What is OES-Technology Explained?
¾ When should OES be used?
¾ Where should OES be used—Types of Alloys
¾ How should OES be used—PMI Methods and Procedure Guidelines
¾ Why should OES be used--Percent of PMI needed?
¾ THROUGH APPLICATION OF PROPER PMI TESTING PROCEDURES ( DAY 2 )
¾ Using OES Technology-(Hands on application/Demonstration)
¾ Testing Procedures and Operation (Hands-on with analyzer)
ƒ ..\Training Course ATC-Final for API\PowerPoints\ATC-API 578-Day 2-Spectro iSORT and TEST-
OES.ppt
¾ Instrument Operation Safety
¾ Instrument Power on/off, Standardization and Reference Checking
¾ Sample handling, preparing, positioning, accessory tools needed
¾ Instrument features, modes, utilities, libraries, field entry’s etc.
¾ Instrument Calculations, Teach and Match ( Go or NO Go ),
¾ Instrument download, upload, PC software features and reports.
¾ CONCLUSION
¾ Review Test Results and Questions
¾ Issue Grades Pass/Fail
 Summary Comments for Presentation:

¾ “Reasons Why! This Course should be given ! ”

¾ OSHA INSTRUCTION D/N CPL-03-00-00-04 Uses Examples:

ƒ API RP 578
ƒ Operation Training and Refresher Training
¾ Safety Bulletin from U.S. Chemical Safety and Hazard Investigation Board
(CSB)—BP Texas City
¾ Safety Bulletin form U.S. Chemical Safety and Hazard Investigation Board
(CSB)---Chlorine Transfer Hose Failure
¾ All the Reported and Unreported “Near Misses” the Oil and Gas Industry has
experienced.

ANSWER: YES or NO !
Questions ?