Pipe Clamp/Seal Procedures and Practices in California Petroleum Refineries

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Pipe Clamp/Seal Procedures and Practices in
California Petroleum Refineries

• 2013 California State Emphasis Program

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Are Pipe Clamps REALLY Legal?

• Yes they areand if used as a temporary repair
  they can be quite safe.

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Incidents Involving Pipe Clamps

• Sunoco Inc. has been fined 147,000 for faulty
  maintenance procedures at its oil refinery in
  East Toledo after an April 6, 2009 incident.
• A worker was hit with gasoline that spurted out
  of a pipe.
• OSHA alleged that the refinery failed to use
  properly engineered pipe clamps to ensure pipe
  leaks were repaired properly to repair or
  replace pipe valves and to follow proper repair
  procedures.

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Incidents Involving Pipe Clamps

• Wynnewood Refining Company The refinerys
  alkylation (Alky) unit. Concerned about the
  number of leaks and the apparent ineffectiveness
  of the PermaWrap repairs on flare line.
• Chief Pipe Inspector Mr. Long recommended
  replacing portions of the line. Management,
  however, rejected this recommendation and
  continued its course of temporary repairs.
• On May 12, 2006, a fire erupted in the Alky Unit,
  one cause of the fire was a rip in the flare line
  where several repairs had been attempted.

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Wynnewood Refining Company continued

• The ALJ specifically acknowledged that
• an employers good faith efforts to correct a
  hazard, even if not entirely effective, can
  negate willfulness however, whether an employer
  acted in good faith is an objectively reasonable
  test. Thus, if an employers measures to address
  a hazard were to maintain production rather than
  a genuine effort to abate the hazard, the
  violation will be found to be willful.

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Our Mission (should you decide to accept)

• Review Pipe Leak Repair Databases
• Review Process Pipe Repairs
• (except for utilities lines i.e. utility water
  lines, fire water lines, some steam lines, and
  nitrogen/air lines)
• Look at clamps
• Review leak seal (MOC) data
• Cite any repair not changed at next turnaround
  (?)

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Legal Foundation (is like quick sand)

• Title 8 Section 6845 (a)the testing,
  inspection, and repair of all piping systems
  shall comply with
• and API 570, Piping Inspection Code, Second
  Edition, October 1998, Addendum 3, August 2003
  and ASME B31.3-2002, Process Piping herein
  incorporated by reference.

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API 570, Section 8.1.4 Nonwelding Repairs
(On-Stream)

• During turnaround or other appropriate
  opportunities, temporary leak sealing and leak
  dissipating devices, including valves, shall be
  removed and appropriate actions taken to restore
  the original integrity of the piping system.

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RAGAGEP"Recognized And Generally Accepted Good
Engineering Practice"

• What is a RAGAGEP?
• an engineering, operation, or maintenance
  activity based on established codes, standards,
  published technical reports or recommended
  practices.
• What is NOT a RAGAGEP?
• it is not a historical practice at a facility
  that has been done for many years  and "has not
  killed us yet or "the way we have always done
  it.
• Why do I speak of RAGAGEP?

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API (570) RAGAGEP

• But not everyone agrees
• Dr. Andrew Hopkins renowned expert on Safety Case
  regulation stated at a presentation of the Oil
  and Gas Expert Forum on safety case regulated
  stated
• API is not a Best Practice Standard BUT a
  Lowest Common Denominator Standard.
• I present this only as Food for Thought.

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LEAK SEAL Inspection Protocols

• All 15 Refineries in California will be inspected
• Review Leaking Pipe databases (if available)
• Search database narrow field of inspection
• high temperature (gt600 deg)
• Priority high or emergency
• Liquid in pipe that would burn or is toxic.
• Not steam, not condensate. (water)
• (exception control on a process?)
• Select targets
• Request specific dates of last turnarounds

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Temp Repair Types

• Clamps (flange, valve
• Pipe wraps
• Wire wraps
• Crimps
• Injection fittings
• All are non-welding repairs

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Welding repairs
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Welding Repairs
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Welding repair
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Non-Welding RepairClamp
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Clamp (flange, valve)
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Clamp(600 deg Methane)
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Clamp (flange, valve)
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Clamp (flange)
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Clamp, flange
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2 flanges clamped
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Pipe wrap
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Crimps, pinching
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Sealant injection (valve)
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Injection fittings on flanges
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Injection fittings flanges, valves, pipe, clamp
body (64 points)
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packing gland injectionOrbit valve
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Most leak seals are or include injection fittings

• Excess sealant can result in blockage of full
  valve closure
• Some are injected more than once
• It is not a permanent solution

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So, What about Steam Rings (?)