CUI Seminar Stavanger, 07-06-18 UK HSE, Energy Division Chris - - PowerPoint PPT Presentation
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
Chris Scales ales CEng MIMMM SenM nMWeldI eldI HSE Energy gy Division ision - Offshor
e Spec ecial ialist ist Inspec pector tor - Material ials and Corrosion
Health and Safety at Work (etc.) Act, 1974 – General duty towards employees and non-employees (contractors). 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 The Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015
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.
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…?
CUI management strategy,
Inspect plant.
risk gap or non-compliance.
compliance.
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
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
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.
New module Original vessel, insulation found waterlogged. Replaced with new – 18 months old. Example 1
Example 2 8” flowline, 30 bar, 80°C, 18.3mm nominal WT, insulation looked OK. Measured down to 6.8mm
Example 3 Quality/Workmanship…or not!
Example 3 continued…
Poor quality Lack of awareness/understanding
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 3rd 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.
Incident occurred late 2015. Corroded, insulated 8” pipe. High pressure gas. Ongoing.
Example 3 This incident, together with increased HSE focus on CUI, appeared to have prompted renewing of strategies, increased resource and Leadership Commitment across the UKCS.
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
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. Example 4
From Example 4
management programme that led to the failure.
review historical data, reset their understanding of the status of insulated systems and update CUI management strategy.
Example 5 The Operator was told, and reminded, but just did not inspect.
Common Enforcement
restored, leaving open ends.
status.
anomalies, visual inspection.
Regulator’s viewpoint and assist in developing guidance and techniques, e.g. HOIS, Energy Institute.
Forum, which includes offshore, onshore industries including those outside oil and gas, e.g. nuclear.
but possibly with additional outreach to industry.
with other regulatory bodies such as PSA, as well as at the International Regulator’s Forum (IRF).
Health and Safety Laboratory – expertise and facilities to perform a wide range of Testing, analysis and research work.
Inspection Focus – Risk Based Inspection (RBI) HSG 65; Plan, Do, Check, Act
condition, actual process parameters etc.)
Getting the basics right;
Plan Do Check Act How many incidents/anomalies, how much remedial work and resource could be saved if the basics were carried out fully and effectively?
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
Oil and Gas Technology Centre (OGTC) – UK Government Funded
CUI issues, under the headings; Predicting Detecting Inspecting Mitigating
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;
This should lead to a substantially revised document which will be publicly available.
are effective and fully implemented, enforcing legislation where risk gaps are identified and holding operators to account where negligence can be demonstrated.
reinstated – emphasis must be placed on quality of materials/design, competency of personnel, heightened awareness and culture.
a screening tool but need to be demonstrated to be effective for this purpose.
in building a CUI management strategy is vital to its success. All parameters need to be considered.
provide sufficiently detailed information of a high enough confidence to negate the need for visual inspection.
the most reliable way to find and assess the extent of CUI.
this large resource could be more effectively used to;