In-Service Inspection in France with a view to the future

1. In-Service Inspection in France with a view to the future Luc LEVASSEUR, Polimeri Europa, Chairman of TG 3 of EPERC TP luc.levasseur@polimerieuropa.com Guy BAYLAC, Consultant, Technical Advisor of EPERC TP guy.baylac@wanadoo.fr European Commission/TAIEX PED Worshop in Romania Bucharest – 27 February – 1 March 2007

2. Layout • Introduction • Current situation in France 1.1 General requirements 1.2 General regime 1.3 Adjusted regime in the chemical and petrochemical industries 2. A view on the future 2.1 Harmonisation of legislations 2.1 Development and standardization of Risk-Based Inspection 2.3 Replacement of the requalification with proof test by the concept of Fitnet for Service based on periodic inspections with adapted NDT 2.4 Extension of experience feedback • Conclusion

3. Introduction • In the search of competitiveness it is wise to compare the different national regulations for in-service inspection of pressure equipment, in order to determine the causes of important distorsions of costs of production • It is also important to propose solutions which will reduce costs while keeping a level of safety almost equivalent

4. Layout • Introduction • Current situation in France 1.1 General requirements 1.2 General regime 1.3 Adjusted regime in the chemical and petrochemical industries 2. A view on the future 2.1 Harmonisation of legislations 2.1 Development and standardization of Risk-Based Inspection 2.3 Replacement of the requalification with proof test by the concept of Fitnet for Service based on periodic inspections with adapted NDT 2.4 Extension of experience feedback • Conclusion

5. General requirements of the Decree dated 13 December 1999 (Article 17) • The User must keep the documentation available for the Inspection Authority • The User is responsible for maintenance, surveillance and repairs • Other requirements address • Installation and putting in service (on site assembly) • Conditions of use (operating instructions) • Repairs and modifications (rules applicable to new equipment)

6. General requirements of the Decree dated 13 December 1999 (Article 18) • Pressure equipment may be subject to the inspection of Agents of the French Administration or of Inspection Bodies (acting by delegation) • At the time of putting in service • At periodic requalification • After repair or modification

7. General requirements of the Decree dated 13 December 1999 (Article 19) • When an industrial establishment operates, under its responsibility and under the management of its inspection service, planified and systematic inspection actions ensuring the safety of pressure equipment the French Administration of the location of the establishment may • recognize this inspection service • authorize the performance of all or part of the inspections according to article 18 • authorize the adjustment of the periodicity of the periodic requalification (Adjusted Regime)

8. In-service inspection rules • Described in the Ministerial Order dated 15 March 2000 • Modified by the Ministerial Orders of 13 October 2000 and 30 March 2005. • Two cases are provided • General Regime • Adjusted Regime (for the sites having an Inspection Service Recognised by the French Administration according to modalities of the Circular DM-T/P 32 510) • The regime of follow-up is based on two components: • Periodic Inspection • Periodic requalification by hydraulic proof test (except derogation of the Central Commission of Pressure Equipment)

9. General regulatory Regime (fixed time intervals) • Pressure vessels: • Periodic Inspection 40 months maxi • Periodic Requalification 10 years maxi • Steam generators: • Periodic Inspection 18 months maxi • Periodic Requalification 10 years maxi • Piping: • Periodic Inspection inspection programme established by the User. No imposed periodicity • Periodic Requalification 10 years. Only certaines lines are concerned in function of PS et DN values (thresholds at PS> 4 bar & DN > 100)

10. Adjusted Regime of the Chemical and Petrochemical industries • Principle: Inspection planning is based on the criticity (also called risk). ( criticity = probability of failure x consequence of failure ) • Inspection Plans are established according to a methodology in conformity with a professional guide approved by the Administration. 2 guides exist for different periodicities of inspection : • Periods of 5 & 10 years. Guide DT 32 of U.I.C. • Periods > 5 & 10 ans. Guide DT 84 of U.I.C. (presently limited to 6 & 12 years), applicable after a period of 5 years spent at the 5/10 years regime.

11. Adjusted Regime • Pressure vessels: • Periodic Inspection inspection plan established by the User. Intervals up to 5 years ( 6 ) maxi • Periodic Requalification 10 years (12 ) maxi • Steam Generators : Same as for Pressure vessels • Piping: • Periodic Inspection inspection programme established by the User. Intervals up to 10 years ( 12 ) maxi • Periodic Requalification 10 years. Only certain lines are concerned in function of the values of PS et DN (thresholds at PS> 4 bar & DN > 100)

12. Guide DT 84: Contents • Purpose of the guide • Domain of application • Dispositions necessary to apply the methods • Method of elaboration of an inspection plan • Management of experience feedback • Revision of inspection plans • Documentation

13. Circular DM – T/P 32 510 • The recognition of an Inspection Service depends on the condition of meeting certain requirements: • requirements based on the principles of the standard NF EN 45 004:1995. • complementary requirements specific to the Technical Inspection.

14. Requirements of DM – T/P 32 510 • Normative and regulatory references • Administratives requirements • Independence, impartiality and integrity • Confidentiality • Organisation and Management • Quality System • Personnel • Installations and equipments • Methods and inspection procedures • Manipulation of samples and objects presented to Inspection • Records • Inspection reports and inspection certificates • Sub-contracting • Claims and appeal • Co-operation.

15. Layout • Introduction • Current situation in France 1.1 General requirements 1.2 General regime 1.2 Adjusted regime in the chemical and petrochemical industries 2. A view on the future 2.1 Harmonisation of legislations 2.1 Development and standardization of Risk-Based Inspection 2.3 Replacement of the requalification with proof test by the concept of Fitnet for Service based on periodic inspections with adapted NDT 2.4 Extension of experience feedback • Conclusion

16. Harmonisation of legislations • A goal-setting legislation for in service inspection in the spirit of the Pressure Equipment Directive is requested by EPERC • To reduce cost variations resulting from different national regulations • To foster the development of Risk-Based Inspection (RIB) • To increase the safety by concentration of available means on critical components • The aforementioned Articles 17 and 19 of the French Decree of 13 December 2000 could be considered as a good start of goal-setting legislation

17. Development and standardization of RBI • RBI is universally recognized as the tool for in-service inspection • RIMAP project was finished in June 2004 • EPERC requests the avaibility in 2007 of the CEN Workshop Agreement • Definitions, methods, should be standardized • The research work on the models of degradation should continue

18. Replacement of requalification with hydrotest by other tests • EPERC Report ˝Considerations on the hydrotest,˝  available on the Website, distinguishes • Cases where the hydrotest appears justified • Cases where it is not useful or detrimental • In the second case, the Report suggests the use of Fitness for Service methods for planning inspections with appropriate NDT, as this is already done in some countries • EPERC also wishes the publication of the CEN Worshop Agreement FITNET in 2007

19. Experience feedback • The importance of experience feedback for RIB is well known in the development of calculation models • French Union of Chemical Industries and Union of Petrochemical Industries have establish data banks of experience feedback • It is suggested to evolve towards European data banks

20. Layout • Introduction • Current situation in France 1.1 General requirements 1.2 General regime 1.2 Adjusted regime in the chemical and petrochemical industries • A view on the future 2.1 Harmonisation of legislations 2.1 Development and standardization of Risk-Based Inspection 2.3 Replacement of the re-qualification with proof test by the concept of Fitnet for Service based on periodic inspections with adapted NDT 2.4 Extension of experience feedback • Conclusion

21. Conclusion • The French regulations for in-service inspections have been presented • The adjusted regime of inspection of the Chemical and Petrochemical industries using Risk-Based Inspection (RBI) and Fitness for Service (FFS) is a factor of progress in comparison to the general regime • It is necessary to go further. RBI and FFS deserve to be fostered by a European goal-setting legislation which will reduce cost distorsions between countries due to in-service inspection.