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Proactive FERMI (Fixed Equipment Reliability and Mechanical Integrity) gap assessment provides a roadmap to Best Practices utilization

Many US refineries and chemical plants had a reactive culture up until the mid-1990’s, when OSHA 1910.119 PSM legislation creation was the direct result of poor industry performance with several major incidents. Most facilities struggled to understand that Process Safety Management (PSM) is a performance based standard, particularly element j. Mechanical Integrity. Element j. relies heavily on "Recognized and Generally accepted Good Engineering Practices”. OSHA conducted random audits in the mid-1990’s and also performed audits if there were a serious incident at a facility or if the facility received sufficient complaints, and, as a result, many companies tried to define a covered process to understand “what the requirements” were. Since that time, most have just adopted PSM as a plant-wide initiative.

Management Of Change (MOC), Process Hazard Analysis (PHA), and MI standards are applied to all fixed equipment. By the early 2000’s, most refineries and petrochemical plants had implemented a host of proactive inspection / Fixed Equipment (FE) reliability programs, including special emphasis programs on wet H2S cracking, small bore connections, Positive Material Identification (PMI), CUI, material operating envelopes, etc. Additionally, a risk-based approach has been adopted by many companies which systematically considers potential consequences and equipment condition, rather than a fixed time based approach for FE inspection intervals. All of these can be considered as examples of best practices, if the plant is committed and has fully implemented.

Recently, OSHA has increased expectations significantly by rolling out a comprehensive National Emphasis Program, consisting of intense audits of up to 6 months at refineries. This was prompted by recent industry incidents, such as BP Texas City’s explosion in 2005.

After a piping failure and resulting large explosion and fire in an ethylene unit, E2G was contacted to conduct a Fixed Equipment Reliability Mechanical Integrity (FERMI) Gap Assessment at a US refinery location. E2G’s engineers and specialists in the areas of inspection, mechanical integrity, reliability, and materials and corrosion spent two weeks at the refinery to compare plant practices to industry best practices to ascertain to what level the plant is taking advantage of industry best practices, to identify areas of vulnerability and where good practices existed. The specific request was to look at opportunities to implement industry best practices because failures do occur in plants that feel they comply with basic Mechanical Integrity regulations. Operators believe that had best practices been implemented, that many of the failures would not have occurred. The primary purpose of the assessment was to:

  • Identify MI concerns at the facility,
  • Provide an expert review of the fixed equipment inspection and reliability groups,
  • Evaluate current MI practices in comparison to Best Practices commonly found at high performing refineries, and
  • Provide detailed recommendations for improving the overall MI performance.

These goals were accomplished through a combination of off-site procedure reviews, personnel interviews, data verification, and inspection and engineering package technical reviews. The FERMI assessment specifically focused on key areas of mechanical integrity including, but not limited to:

  • Inspection Management Systems
  • Equipment Inspection Strategies and Planning
  • NDE Procedures
  • Personnel Training and Qualifications
  • Engineering and Maintenance Practices
  • Materials and Corrosion

The FERMI assessment noted areas where the refinery had strong performance and had instituted industry best practices. Likewise, a number of opportunities for improvement in the management and application of fixed equipment reliability and mechanical integrity best practices were identified. The assessment identified over 50 gaps, which were prioritized, with almost half those being deemed high priority. The gaps ranged in scope from changes in the facility culture to specifically addressing items such as CUI and localized corrosion. Additionally, over 80 facility procedures were reviewed and improvements were identified to achieve industry best practice.

E2G’s extensive owner-user experience and knowledge of industry best practices allowed for prioritization of important findings and development of recommendations to address those items. The final recommendations provided the refinery a path-forward to close FERMI gaps as well as overall FERMI performance relative to others in industry.