CUI Seminar Stavanger, 07-06-18 UK HSE, Energy Division Chris Scales ales CEng MIMMM SenM nMWeldI eldI HSE Energy gy Division ision - Offshor ore e Spec ecial ialist ist Inspec pector tor - Material ials and Corrosion on
Energy Division – Topic Specialists
How we Regulate Tools we use What we find What we are doing/What is happening
How We Regulate UK Legislation – Goal Setting Regime Health and Safety at Work (etc.) Act, 1974 – General duty towards employees and non-employees (contractors). The Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015 Management of Health and Safety at Work Regulations, 1999 Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations, 1995 Offshore Installations and Wells (Design and Construction etc.) Regulations, 1996
Piper Alpha – Safety Case Regulations A central recommendation of the Cullen enquiry; Every operator/owner of an offshore installation must prepare and submit a Safety Case to the Regulator (HSE) for acceptance. The Safety Case must identify all risks with the potential to cause a major accident, and describe the processes in place to reduce them to a level which is as low as reasonably practicable (ALARP). The Safety Case is assessed and may be accepted by the Regulator. Every operator/owner must have an accepted Safety Case for each installation they operate.
Safety Cases, Inspection and Goal Setting Operators must comply with their accepted Safety Case, which means… do what they said they were going to do! HSE Inspectors ensure by inspection that operators are doing what they said they were going to do in their accepted Safety Case, to control risks. The goal set is to identify, reduce and manage risks. The means by which operators achieve this is up to them. How does this relate to CUI…?
Regulating - CUI • Inspect and assess CUI management strategy, onshore • Inspect and assess function of strategy offshore. Inspect plant. • Enforce where we identify a risk gap or non-compliance. • Achieve sustained compliance.
Tools we use; Legislation Provision and Use of Work Equipment Regulations, 1998 Regulation 5 (1) – Maintenance Every employer shall ensure that work equipment is maintained in an efficient state, in efficient working order and in good repair Regulation 6 (2) (a) – Inspection Every employer shall ensure that work equipment exposed to conditions causing deterioration which is liable to result in dangerous situations is inspected — (a) at suitable intervals
Tools we use; Guidance Energy Institute ; “ Guidance for Corrosion Management in Oil and Gas production and Processing ” – specific section on CUI HSE ; “ HSG 65, Managing for Health and Safety ” – Plan, Do, Check, Act. EFC 55 (Revised); “ Corrosion Under Insulation (CUI) Guidelines ” HSE, SPC/Tech/Gen/18 – “ Corrosion under insulation of plant and pipework v3 ” (available on HSE website). HOIS Document (16)R2 Issue 01 – “ HOIS Guidance for in-situ inspection of corrosion under insulation (CUI) ” – guidance on effectiveness of NDT techniques.
What we find Example 1 Original vessel, insulation found waterlogged. Replaced with new – 18 months old. New module
What we find Example 2 8” flowline, 30 bar, 80° C, 18.3mm nominal WT, Measured down to 6.8mm insulation looked OK .
What we find Example 3 Quality/Workmanship…or not!
What we find Example 3 continued… Poor quality Lack of awareness/understanding
What we find These examples raise the question, “Why does the operator not know what they are getting?” In many cases Fabric Maintenance, including insulation removal, reinstatement and application is contracted to a 3 rd Party. The “Intelligent Customer” should know what they require, why they require it and if they are getting it. …management of sub -contract work. Training and recognised standards in applying insulation is lacking in the UK sector, and will be a focus going forward.
What we find Example 3 Incident occurred late 2015. 8 ” Corroded, insulated pipe. High pressure gas. Ongoing . This incident, together with increased HSE focus on CUI, appeared to have prompted renewing of strategies, increased resource and Leadership Commitment across the UKCS.
What we find A significant proportion of assets on the UKCS are operating close to, or beyond their original design lives. Often, installations have been owned and run by a number of Operators and as a result, in many cases historical information is missing or no longer accurate. The location or extent of insulation, inspection history, history of physical change or changes to the process do not reflect the current status, meaning that effective management is not possible without a substantial re-baselining exercise. In many cases, operators are coming from a position of ‘catch up’, following periods of mismanagement or neglect, sometimes by previous owners. Extensive re-baselining is necessary to establish status.
What we find Example 4 4”, 20 Bar fuel gas line pinhole leak – outboard, difficult access, never stripped for inspection. Not reported, rather than reported as “not inspected”. Inadequate reporting process, poor supervision and lack of audit of inspection activities…RBI scheme.
What we find From Example 4 • The Operator acknowledged historic failings in the CUI management programme that led to the failure. • Stripped and inspected 60% of Hydrocarbon containing pipework over approximately 2 month period. Further findings…. • Took the opportunity to review historical data, reset their understanding of the status of insulated systems and update CUI management strategy.
What we find Example 5 The Operator was told, and reminded, but just did not inspect.
What we find Common Enforcement - Damaged or poorly applied/reinstated insulation. - Insulation removed for inspection and not restored or partially restored, leaving open ends. - Lack of historic information, inaccurate data, uncertainty over status. - Failure to inspect. - Inadequate management strategies; stripping only at anomalies, visual inspection. - No consideration of risks associated with removing insulation.
What we are doing/ What is happening • HSE works with industry groups to provide the Regulator’s viewpoint and assist in developing guidance and techniques, e.g. HOIS, Energy Institute. • HSE is looking to initiate the reformation of the UK CUI Forum, which includes offshore, onshore industries including those outside oil and gas, e.g. nuclear. • Establishing and maintaining links on technical issues with other regulatory bodies such as PSA, as well as at the International Regulator’s Forum (IRF). • HSE is planning a project to gather and analyse data on CUI incidents/failures/enforcement that we hold, but possibly with additional outreach to industry.
SD (formerly HSL) Health and Safety Laboratory – expertise and facilities to perform a wide range of Testing, analysis and research work.
What we are doing/ What is happening Inspection Focus – Risk Based Inspection (RBI) HSG 65; Plan, Do, Check, Act
What we are doing/ What is happening Getting the basics right; - Understanding what you have (where the insulation is and Plan condition, actual process parameters etc.) - Developing an effective CUI management strategy/identify risks - Implement the Strategy Do Inspection with effective repair – quality, assurance, awareness - - Measure/analyse data (failures, near misses, anomalies) Check - Review strategy Act - Implement changes as required How many incidents/anomalies, how much remedial work and resource could be saved if the basics were carried out fully and effectively?
What we are doing/ What is happening Energy Institute - Guidance – Revised edition soon to be issued…..updates since 2008 focus on the following areas; – key differences between carbon steel and Corrosion Resistant Alloys (CRA) – timing for thorough inspections typically range from 5 – 20 years – insulation removal is still the most effective form of thorough inspection – predictability and definition of prone areas – suitability of Non-Intrusive Inspection (NII) techniques – limitations of probability assessment – the pitfalls to avoid – consideration for live equipment insulation removal – permanent and partial permanent removal of insulation – increased rupture threat for under-inspected carbon steel
What we are doing/ What is happening Oil and Gas Technology Centre (OGTC) – UK Government Funded • An open call for ideas to provide solutions for solving CUI issues, under the headings; Predicting Detecting Inspecting Mitigating • Funding is available to develop the most promising ideas. Submission window recently closed.
What we are doing/ What is happening HOIS – Industry JIP concerned with NDT “Guidance for in -situ inspection of Corrosion Under Insulation (CUI) “ – this is a confidential document to HOIS JIP participants. Further NDT trials are about to begin in June, part funded by OGTC, including; • New variants of PEC • Realtime radiography • Guided wave This should lead to a substantially revised document which will be publicly available.
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