Inspection Procedure 00-SAIP-72
10 June 2009
Inspection Involvement in Management of Change Document Responsibility: Inspection Engineering Standards Committee
Saudi Aramco DeskTop Standards Table of Contents 1 2 3 4 5
Scope............................................................. Applicable Documents................................... Definitions...................................................... Responsibilities.............................................. Documentation...............................................
Previous Issue: 28 September 2005 Next Planned Update: TBD Revised paragraphs are indicated in the right margin Primary contact: Kakpovbia, Anthony Eyankwiere on 966-3-8747226 Copyright©Saudi Aramco 2009. All rights reserved.
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Document Responsibility: Inspection Engineering Standards Committee 00-SAIP-72 Issue Date: 10 June 2009 Next Planned Update: TBD Inspection Involvement in Management of Change
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Scope 1.1
This SAIP provides guidelines for Plant Inspection Units regarding its involvement and responsibilities in the facility's management of change. This is also to supplement the Risk Based Inspection studies per API RP 580. A direct replacement in kind as defined in section 3 is not covered by this SAIP except as mentioned in section 3 under definition of replacement in kind. Commentary Note: Changes and modifications in plants are needed for a variety of reasons such as yield improvement, compensation for unavailable equipment and production increases. The process changes usually involve changes in operating procedures; changes in piping, equipment or materials of construction as well changes in feedstock's, catalysts, fuels or their method of delivery.
1.2
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All Management of Change shall as a minimum assure the following considerations are addressed prior to any change: a)
The technical basis for the proposed change.
b)
Modifications to operating procedures.
c)
Necessary time period for the change.
d)
Authorization requirements for the proposed change.
Applicable Documents The following Standards are to be used as reference for this inspection procedure. 2.1
Saudi Aramco Documents Saudi Aramco General Instruction GI-0002.600
Plant/Unit Acceptance after T&I Shutdown
Saudi Aramco Inspection Procedures
2.2
00-SAIP-76
Worksheet Control & Tracking Procedure
01-SAIP-04
Injection Point Inspection Program
Industry Codes and Standard U.S. Department of Labor: Occupational Safety and Health Administration 29 CFR 1910.119(l)
Process Safety Management of Highly Hazardous Chemicals Page 2 of 6
Document Responsibility: Inspection Engineering Standards Committee 00-SAIP-72 Issue Date: 10 June 2009 Next Planned Update: TBD Inspection Involvement in Management of Change
Subsection l: Management of Change American Petroleum Institute API RP 580
Risk-Based Inspection
Commentary Note: When specific facility management of change procedure exists they shall be considered applicable to this SAIP.
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Definitions Management of Change (MOC): Management of change is a procedural system of control supported by appropriate documentation to ensure that safeguards are in place to eliminate the possibility of hazards introduction as a result of changes, other than replacement in kind, to operations, process parameters, control parameters, chemicals, plants and facilities. The MOC requirement is detailed in OSHA 29 CFR 1910.119(l). Design Change: For the purpose of this SAIP, a design change is defined as any replacement, modification, addition, changes that involve any operating procedures or design limits, or deletion of plant equipment or instrumentation which involves the mechanical, physical, chemical, or electrical or control parameters of process or equipment associated with change. Permanent Change: A permanent change is one which once implemented, will be a permanent feature of the design, operation or procedural control on the plant or facility. Temporary Change: A change implemented with the intent that it shall remain in place only until the next planned shutdown or until a date pre-determined by the applicable Operations Department superintendent responsible for that Plant or Area in conjunction with the Change Management Committee. Commentary Note: If design change is temporary, a specific duration is required to be indicated and a regular evaluation or inspection of the plant and or equipment conditions shall be performed on a pre-determined basis discussed during the preliminary design phase.
Emergency Change: An emergency change situation exists when changes must be made on short notice or no notice in order to maintain safe operations that could affect the lives, property or safe operational of the equipment. An emergency change may be defined as change that is authorized by the responsible personnel that must be implemented within the most expeditious time frame such as for safety, health environmental and/or continued operations.
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Document Responsibility: Inspection Engineering Standards Committee 00-SAIP-72 Issue Date: 10 June 2009 Next Planned Update: TBD Inspection Involvement in Management of Change
Replacement in Kind: A replacement in kind is one which the system affected remains within the established operating window and, in the case of hardware the old equipment is replaced with identical equipment meeting all requirements of the original design specifications. Commentary Note: Due to repeated failures of injection points, new or reinstated injection points in critical service is defined in 01-SAIP-04 should always be considered as a change.
Change Management Committee (CMC): This committee consists of the responsible Operations, Maintenance, Engineering, the Area Inspection Unit Inspector and the Loss Prevention Engineer. This committee is normally responsible for reviewing all changes and communicates with and advises the MOC Coordinator of the necessity, benefits, practicality and level of urgency including all implications or the proposed change. MOC Coordinator: An operations representative who has the overall responsibility for the Change. Reviewers: The Subject Matters Experts when necessitated or required based on the complexity of the Change are nominated by the (CMC) to review the proposed Change. In the inspection Unit, he could be a corrosion engineer or a senior inspector in the area affected by the change. 4
Responsibilities 4.1
Plant Modifications 4.1.1
Participate in the preliminary design phase or developmental stage with the CMC team or Operations, Mechanical, and Engineering (OME) team as applicable, to define and discuss the proposed change, aid in and determining a best practice approach and overall Change concept.
4.1.2
Review all conceptual and detailed design packages with inspection input and communicate with the CMC for implementation and execution.
4.1.3
Review all detail drawings, applicable piping and or material specifications, welding procedures, NDT, PMI and hydrotesting requirements, equipment specifications, and inspection requirements required during the preliminary, execution, and final change phases.
4.1.4. Perform interim inspection during the construction phase to ensure that new modifications are in compliance with approved drawings and applicable Saudi Aramco engineering standards including applicable industry code requirements.
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Document Responsibility: Inspection Engineering Standards Committee 00-SAIP-72 Issue Date: 10 June 2009 Next Planned Update: TBD Inspection Involvement in Management of Change
4.2
4.1.5
Communicate with CMC team as needed to ensure that all new drawing revisions and revisions to the Change that may affect inspection requirements are discussed and agreed upon.
4.1.6
Conduct pre-mechanical completion (MCC) inspection and submit exception item(s) if any. Meet with CMC team to discuss all exception items for clarification and final acceptance when needed.
4.1.7
Receive and maintain as-built drawing files for design change packages as applicable.
4.1.8
Update the On-Stream Inspection Program, Risk Based Inspection database or any other inspection program that may be affected by the change.
Process Change 4.2.1
Participate in the preliminary discussions with OME team for familiarization of the proposed process change to determine what effects the change will have on inspection methods, strategies and schedules.
4.2.2
Review the inspection requirements needed if the process change requires a change in material(s), i.e., piping, valves, etc. The Inspection Unit shall document changes within a process to evaluate their inspection strategy and tactics.
4.2.3
Establish communications with CMC team and or OME to confirm and record when the new Process Change was implemented. Daily communications with OME team is recommended to highlight and discuss operational process upsets so that inspection may evaluate and determine if the plant equipment integrity was affected and or to schedule inspection if deemed necessary.
4.2.4
Require from the OME and or CMC the results of a systematic process, involving appropriate subject matter experts (SME's) to identify and document each process variable that must stay within a specific range in order no to increase the chances of equipment failure beyond that normally expected.
4.2.5
If the Process Change does require a Design Change, invoke the requirements listed under paragraph 5.
4.2.6
The inspection units should request a look ahead schedule of activity for the purpose of planning inspection coverage of the different disciplines.
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Document Responsibility: Inspection Engineering Standards Committee 00-SAIP-72 Issue Date: 10 June 2009 Next Planned Update: TBD Inspection Involvement in Management of Change
4.2.7
4.3
5
Update the On-Stream Inspection Program, Risk Based Inspection database or any other inspection program that may be affected by the change.
Temporary Repairs and Installations 4.3.1
The Inspection Unit shall confirm that temporary repairs made by qualified personnel, using approved methods and procedures so that the risk of an incident is not increased by sub-standard repairs. This will minimize unscheduled outages due to failures of inappropriate repairs.
4.3.2
The Inspection Unit shall confirm that temporary installations are installed by qualified personnel, using approved methods and procedures to make sure they are adequate for the intended purpose and the length of time required. This will minimize unscheduled outages due to failures of inadequate installations.
4.3.3
The Inspection Unit shall ensure that worksheets covering temporary repairs remain open and tracked until it is changed to permanent as soon as possible. The tracking of the worksheets shall be per 00-SAIP-76.
4.3.4
Update the On-Stream Inspection Program, Risk Based Inspection database or any other inspection program that may be affected by the change.
Documentation 5.1
Inspection unit shall maintain all MOC change documentation in the applicable plant file and equipment and also maintain a log of all changes. The final MOC documentation shall have evidence that Inspection performed a final inspection and is closed with no outstanding issues.
5.2
Inspection unit shall maintain all documents related to acceptance of the plant after T&I per GI-0002.600 ensuring that all changes have been reviewed and accepted.
10 June 2009
Revision Summary Revised the "Next Planned Update". Reaffirmed the contents of the document, and reissued with editorial changes (changed document responsibility and primary contact to Chairman, Inspection Engineering Standards Committee).
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