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Committee on Refinery Equipment May 2011 Update to the Refining Subcommittee Kelly Smith, ConocoPhillips, Chair, CRE. Purpose/Outcomes. Report on 2011 Plans and Activities: Update on Materials Database Project Report on standard revisions with significant impacts
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Committee on Refinery Equipment May 2011 Update to the Refining Subcommittee Kelly Smith, ConocoPhillips, Chair, CRE
Purpose/Outcomes • Report on 2011 Plans and Activities: • Update on Materials Database Project • Report on standard revisions with significant impacts • Discuss Standards Management Activities • Obtain RSC feedback
Materials Database Project • Background: • Basic data underpinning many of API’s refining standards is housed in reports of three non-profit research foundations and were considered at risk due to organizational and demographic issues • CRE developed and API contracted a business and implementation plan for a data archival system • Project schedule called for “proof for concept” pilot project to be available for review at Spring 2011 Meeting
Materials Database Project • April 2011 Status: • Follow-up meetings with contractor: • Delay in proof of concept until Fall Meeting • Concern about project scope and IP issues • Ultimate request by contractor for contract release • Additional data security and integrity steps taken: • Non-profit reorganization and merger • Non-profit BOD reconstituted • Financial audit completed • Librarian hired, indexing of books complete, indexing of technical reports underway • Records retention database schema under development • Records consolidation underway • New WRC Website launched with on-line purchase of materials • Next Steps: • API review • CRE Analysis – Steering Team Meeting 5/15, SCCM Update 5/16, follow-up meeting 5/17
Standards Revisions Key Standards Revision – Standard 653, Tank Inspection, Repair, Alteration, and Reconstruction: • In Jan 2010 a joint Inspection and Tanks task force met to consider changes to the risk-based internal inspection intervals (RBI) in Section 6. Primary Issues: • Fixed time limits for RBI • Basis for the time limits • The current 4th edition text (published in 2009) had led to confusion and compliance concerns around the use of RBI in setting intervals for tanks and two subsequent ballots
Standards Revisions Key Standards Revision – Recommended Practice 520, • Sizing, Selection, and Installation of Pressure-Relieving Devices in Refineries—Part II, Installation • Proposed revision is part of regular review and maintenance process to update the standard • Includes a revision to the safety relief valve section, specifically the “3% rule” • The initial draft ballot closed March 17, 2010 • OSHA provided comments and attended Fall meeting
Standards Revisions Key standards revision – RP 520, Part II • Proposed Ballot Resolution Language: • Points to API 510 and 576 and requires that the Users adhere to these standards as a pre-condition to allow higher than 3% • Adds a stipulation that exceeding 3% should not be the standard for new systems, except in applications (i.e. low pressure) where the 3% limit is impractical to meet • A reaffirmation ballot was conducted to keep document current • A literature search on pressure relief valve chatter is underway
Standards Revisions Key Standards Revision – Recommended Practice 521, • Guide for Pressure Relieving and Depressuring Systems, Addendum (April 2008) to 5th Edition, January 2007 • Addendum prepared in response to CSB Texas City recommendation • CSB Recommendations Staff has provided comments in advance of revisions task group meeting • Comments specific to three areas: overfill process or surge vessels, multiple-device disposal systems, Inherently Safer Technology, or IST
Standards Revisions Key standards revision – RP 571, Damage Mechanisms Affecting Fixed Equipment in Refineries, 2ndEdition, 2011 • RP provides general guidance as to the most likely damage mechanisms affecting common alloys used in the refining and petrochemical industry • RP can be utilized by plant inspection personnel to assist in identifying likely causes of damage; to assist with the development of inspection strategies; to help identify monitoring programs to ensure equipment integrity
Standards Revisions Key standards revision – Standard 556, Instrumentation, Control, and Protective Systems for Gas Fired Heaters, 2ndEdition, 2011 • Issue of industry instrumentation and controls has been highlighted as government regulators and other stakeholders • Developed jointly between Subcommittee on Instrument and Controls and the Subcommittee on Heat Transfer Equipment • Includes primary measuring and actuating instruments, controls, alarms, and protective systems as they apply to fired heaters
Standards Management CRE has developed a process to identify standards with potential significant industry impact In April the CRE held a conference call to review the standards work plan and identify those standards Several were highlighted in this report A standards tracking tool has been developed for CRE, PSC and SFPG standards to improve resource management
Column Heads • Subcommittee • Document • Document Name • Current Edition • Publication Year • Reaffirmation Year • Two-Year Extension Year • Year Due for Action • Position in Cycle (number of years since publication, reaffirmation) • Current Activity • Co-branded Equivalent Document • American National Standard (Y/N)
Column Heads, continued • Current Advocacy Issues (Education Needs, CSB information, etc.) • Regulatory Relationship (document cited or related, etc.) • Priority Matrix Information • Regulatory Signifcance • Basis for Certification/Monogram Program • Company Use/Broad Industry Need • Priority Rank • Resource Needs • Comments/Action Items • API Staff
RSC Feedback • Understand Database issue • Provide updates on standards 653, 520, Part II and 521 • Provide update on other significant standards revisions • Other Feedback?
Annex • RP 653 • RP 520 Part II
Standards Revisions • Key Standards Revision – Standard 653, Tank Inspection, Repair, Alteration, and Reconstruction: Two subsequent ballots and resolution meetings held: • Ballot 653-245 (Apr 2010) • 71% response rate and 85% approval rate • Eight negatives and 91 written comments • Ballot 653-245 Rev 1 (Nov 2010) • 68% response rate and 74% approval rate • 13 negatives and 107 written comments • New TF co-chairs developing language to resolve recent comments
Standards RevisionsKey Standards Revision – RP 520, Part II: • Proposed revisions designed to allow operators greater flexibility on maximum inlet non-recoverable pressure drop for safety relief valves while maintaining safe operations: • Current language states that pressure drop should not exceed 3% of the valve set pressure • Proposed language states that the “pressure loss…should not exceed 3 percent of the set pressure of the pressure relief valve except as permitted in 4.2.2.4 when supported by an engineering analysis”
Standards Revisions Key standards revision – RP 520, Part II • The ballot: • Received consensus with 66% response rate and 96% approval rate • Had one negative from an operator and 200 written comments • OSHA also provided comments • Included in the comment resolution process was an API-OSHA meeting held September 24, 2010 • OSHA provide additional November 10, 2010 letter and attended November 2010 meeting
Standards Revisions Key standards revision – RP 520, Part II • Proposed Ballot Resolution Language: • Eliminated the words “Engineering Analysis”. Instead used words “if exceed 3%, the following shall….” • Replaced “suitable margin relative to the blowdown shall be specified by the User” with “a 2% margin relative to blowdown shall be used” • Limited the inlet pressure drop to a maximum of 5% • Added the requirement to reduce the allowable built-up back pressure on conventional valves, if 3% is exceeded