KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion INSTALLATION or DUTYHOLDER Key Persons interviewed DATES(S) Company Summary of Inspection Traffic Lights IMT and INSPECTOR(S) Position Red 6 5 Amber Green W 4 3 2 1 0 Section A: Ageing and Life Extension (ALE) Policy and Leadership Section B: ALE - Organising Section C: ALE - Planning and Implementing Section D: ALE - Measuring Performance Section E: ALE - Auditing and Reviewing Performance Summary of Inspection Findings: HSE Action taken: August 2011 V1.0 Page 1 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section A: Ageing & Life Extension – Policy and Leadership (Questions for senior management – typically Operations Manager, Asset Integrity Manager, Safety Engineering Technical Authority) Principal Questions: 1) What do you consider the ageing and life extension issues to be for Fire, Explosion and Hazardous Fume (FEHF:DMP) detection, mitigation and protective systems? 2) Can you give some examples where you have encountered issues regarding ageing and life extension? 3) How did you deal with these? 4) Describe the policies that senior management has in place to ensure that: a) the design basis for FEHF:DMP equipment is suitable for current and projected Major Accident Hazards (MAH); b) modifications to the FEHF:DMP systems are competed with a full consideration of the current MAH risk profile of an installation; c) performance standards for safety critical elements on existing (as well as new) FEHF:DMP equipment are suitable and sufficient for the revised functional specification; d) improvements in health, safety, and welfare standards are implemented where reasonably practicable in compliance with current HSE and Industry guidance, and applicable national and international standards and codes of practice; e) the mechanical integrity of systems containing hazardous materials is sound; f) redundant equipment that represents significant congestion and aggravated explosion damage, or barrier to emergency response are removed where this is reasonably practicable; g) failure of one or more prevention or mitigation measures does not increase risk to the most exposed group of workers to intolerable levels for continued production operations. 5) What are the Key Performance Indicators used to indicate the asset integrity status to Senior Managers? Benchmarks sought in replies: Awareness of original design life of plant and equipment Awareness of internal and external corrosion, corrosion under insulation/passive fire protection and erosion Knowledge of relevant changes in regulation, regulatory guidance, industry guidance, international standards and codes of practice Knowledge of relevant operational experience Incident investigation and dissemination of findings Incident reporting of near misses as well as RIDDOR and HCRs August 2011 V1.0 Page 2 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section A: Ageing & Life Extension – Policy and Leadership Policy on ageing and life extension covering the projected lifetime of the asset Periodic review of design basis triggered by trends in MAH profile, or time elapsed from previous review Updated consequence, vulnerability and probability models Key documentation QRA, P&IDs, Cause and Effect Diagrams, Hazardous Area Classification Drawings, Operating Procedures etc. are revised to reflect any changes Formal Safety Assessments, HAZID, HAZOP, Fault Tree Analysis, Failure Modes and Effects Criticality Analysis triggered by policy on ALE Safety Integrity Levels are conducted/reviewed to confirm no changes in functional, reliability/availability, or vulnerability specifications A continuing programme of non-destructive testing and visual inspection methods is used to verify adequate PFP condition, thickness, and absence of defects Registers maintained A seeps, weeps, and leaks register is maintained A defined life repair register is maintained, audited and reviewed A log of inhibits and over-rides is maintained, audited, and reviewed. An operational risk assessment process is in place Examples of leading (e.g. number of successful TR integrity, detectors and Active fire protection systems tested in a period), and lagging (e.g. number of faults discovered during testing of Fire pumps, detectors, PFP, fire walls and penetrations HVAC systems) indicators provided Ageing and life extension (ALE) policy owned by senior management Senior management has responsibility for implementing ALE policy Senior management support for equipment/system replacement Asset Integrity Management (AIM) addresses ALE Fitness for purpose demonstrations are described References to codes, standards & guidance, for example: o OSD Info sheets 1/2006, 2/2006, 3/2006 4/2009 BS 13702, IP 15 SPC 30 o HSE Research Report RR 509 Plant Ageing (Management of equipment containing hazardous fluids or pressure) o Relevant Energy Institute publications August 2011 V1.0 Page 3 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section A: Ageing & Life – Extension Policy and Leadership Onshore Management: Offshore Operations: HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NONCOMPLIANCE Court proceedings recommended 6 SIGNIFICANT NONCOMPLIANCE Enforcement Notice Served August 2011 V1.0 5 GENERAL NONCOMPLIANCE Letter & changes made to intervention 4 PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Letter Verbal advice No findings 3 2 1 NOT INSPECTED 0 Page 4 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section B: Ageing & Life – Organisation (Questions for senior management – typically Operations Manager, Asset Integrity Manager, Safety Engineering Technical Authority) Principal Questions: 1) Who is responsible for: a) Major Accident Hazard identification and risk assessment; b) The fire & explosion ALE policy; c) Conducting fire & explosion integrity condition assessments and life-extension studies etc. for the fire & explosion integrity system 2) 3) 4) 5) 6) d) Maintenance and Testing of safety critical: detection, control /mitigation and protective systems; e) Operational Risk Assessment; f) Management of Change; How do these persons fit into the organization? How are views on risk management, including downgraded situations involving SCE’s communicated to and from the workforce? How do you document Operational Controls and Maintenance Records How do you assure the competency of personnel involved in the management, operation, inspection, and maintenance of plant and equipment? How is competence assured for contractors? Benchmarks sought in replies: An understanding of thee need for monitoring & trending data An understanding of life extension issues for fire & blast resistance Well defined roles and responsibilities Wide consultation with the workforce Ownership of the management system Systems and procedures for change control Arrangements to secure corporate memory Systems and procedures for document control Systems and procedures for Operation Systems and procedures for Maintenance management Competence assurance systems in place for operations and maintenance personnel Competence assessment system for contractors August 2011 V1.0 Page 5 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section B: Ageing & Life – Organisation Onshore Management: Offshore Operations: HSE Comments: HSE Action taken: August 2011 V1.0 Page 6 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section C: Ageing & Life Extension – Planning and Implementation (Questions for senior management – typically Safety Engineering Technical Authority, Asset Integrity Managers, EH & S Managers, Project Managers, OIMs) Principal Questions: What is your system for hazard identification? How do you assess risk? How do you establish the protective and mitigation measures? How do you prioritise the work? Is maintenance, inspection, or testing contracted out? How is implementation controlled? How is change controlled? How are downgraded SCE’s for fire, explosion and hazardous fume managed 9) How is performance of the SCE’s monitored and trended such that age and condition trigger the above processes 1) 2) 3) 4) 5) 6) 7) 8) Benchmarks sought in replies: Risk Based Inspection, Campaign, Breakdown, Condition Monitoring Periodic replacement, testing and inspection Operating and Maintenance records, including service life Incident data, internal/external Risk targets Integrated system Change requests, approvals, tracking register, management of change procedures, verification Procedures for changes in: plant and equipment safe operating envelopes; plans, procedures and key documentation; people and organisation; major accident hazards; regulatory policy; guidance, and international codes and standards Design life is documented Explanation of how equipment subject to ageing is selected and identified Review of the suitability of the performance standards Evaluation of wear, deterioration and damage in service Review for operation outside of design limits, and for changed design standards Obsolescence identified and managed Plans for replacement and provision of spares Targeted inspection and maintenance, including difficult to access equipment Life extension studies and fitness for purpose demonstrations August 2011 V1.0 Page 7 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section C: Ageing & Life Extension – Planning and Implementation available Condition of mitigation systems such as PFP, gas detection or deluge in place established The original design criteria and any information that demonstrates that the original design criteria are no longer valid available Platform modifications, additions, any repairs / strengthening particularly of the TR documented; Changes of use violating the original design or previous integrity assessment assessed; Departures from the original basis of design e.g. increased gas inventory or higher throughput in separators assessed and actioned; The versions of the codes used dispersion or explosion models suitable and validated regularly Firewater pump or main ring main failure resulting in overall deluge failure evaluated and action planned corrosion/blast wall integrity compromise detector obsolescence considered and monitored/ action planned . August 2011 V1.0 Page 8 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section C: Ageing & Life Extension – Planning and Implementation Onshore Management: Offshore Operations: HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NONCOMPLIANCE Court proceedings recommended 6 SIGNIFICANT NONCOMPLIANCE Enforcement Notice Served August 2011 V1.0 5 GENERAL NONCOMPLIANCE Letter & changes made to intervention 4 PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Letter Verbal advice No findings 3 2 1 NOT INSPECTED 0 Page 9 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section D: Ageing & Life Extension – Measuring Performance (Questions for senior management – typically Safety Engineering Technical Authority, Maintenance Managers, Production Supervisors) Principal Questions: 1. What codes, standards, recommended practices, guidelines, etc. have been identified as relevant to ageing & life-extension (ALE) and asset integrity management (AIM) for fire explosion and hazardous fume MAH’s? 2. What specific key performance indicators (KPIs), 'traffic lights' or similar are used to review the fire & explosion condition with respect to ageing and the effectiveness of the maintenance, testing and inspection system? 3. What inspection methods are used to detect ageing or deteriorating performance of the FEDMS? How does the inspection philosophy allow for the detection of ageing, e.g. 4. Planning and frequency of inspections and maintenance in recognition of ageing mechanisms, including integration of baseline, periodic and special inspections 5. Use of maintenance procedures which consider the need for a more detailed inspection if a period of life extension is to be justified or deterioration from ageing mechanisms is detected 6. Consideration of scheduling of IMR interventions in light of deterioration rates, availability of competent services, reliability of techniques and confidence for near- and long-term assurance of integrity 7. What risk-based methods are employed that allow for loss of integrity from ageing of detection and mitigation systems (with key supporting references). 8. What leading or lagging indicators are used to indicate components / structure or equipment that may not be performing as required or showing signs of deterioration in their integrity or performance? 9. What reference is made to codes, standards, recommended practices, guidelines, etc., relevant to ageing & life-extension (ALE) and fire & explosion integrity management? 10. How does the duty holder evaluate the implications of revised or new codes, standards, guidelines, etc., and adapt fire & explosion inspection and maintenance, etc., where necessary? 11. What parameters are measured during operation/inspection/ fault condition? 12. Where are the performance standards recorded? 13. How do you track progress for testing/inspection? 14. How are these communicated to senior management? August 2011 V1.0 Page 10 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section D: Ageing & Life Extension – Measuring Performance Benchmarks sought in replies: Leading and lagging KPIs to monitor impact of ALE are defined Management reviews KPIs and acts Contractor and 3rd party maintenance findings reviewed Procedures in place to detect ageing Ageing processes monitored Failure trends identified Benchmarking of design against current standards Inspection methods and techniques are used to detect and trend ageing i.e. creep, cracking, corrosion, damage, and wear More detailed inspection required if life extension is contemplated or deterioration from ageing is detected Register of weeps, leaks, and breaks i.e. minor, significant and major hydrocarbon releases to inform the life extension analysis Data measurement which does not meet the performance standards used to determine remaining or extension to life Formal life-extension studies are performed Use made of trends of incident, accident and near-miss data Senior Management is aware of the status and condition of plant and equipment related to Fire, Explosion and Toxic Fume management August 2011 V1.0 Page 11 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section D: Ageing & Life Extension – Measuring Performance Onshore Management: Offshore Operations: HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NONCOMPLIANCE Court proceedings recommended 6 SIGNIFICANT NONCOMPLIANCE Enforcement Notice Served August 2011 V1.0 5 GENERAL NONCOMPLIANCE Letter & changes made to intervention 4 PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Letter Verbal advice No findings 3 2 1 NOT INSPECTED 0 Page 12 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section E: Ageing & Life Extension – Auditing and Reviewing Performance (Questions for senior management – typically Asset Integrity Manager, Maintenance Manager, Operations Manager, OIM, safety Engineering Technical Authority) Principal Questions: 1) How does the verification scheme address the ALE of Fire, Explosion 2) 3) 4) 5) and hazardous fume detection control, mitigation and protective system safety critical elements (SCEs)? Who conducts a review of the key performance indicators? How frequently? What results from such a review? How are recommendations to senior management made with respect to the level of resources required to maintain fire & explosion integrity? 6) How are lessons learned and trended for incident, accident and near- miss data and how is this being used to improve and the AIM system? 7) Are performance standards on the loss of integrity from deterioration associated with ageing and life extension available for all fire & explosion detection and mitigation systems safety critical elements (SCEs)? 8) To what extent has the verification process identified any deterioration from ageing mechanisms and associated loss of integrity or demonstrated that integrity has not been compromised by ageing mechanisms? 9) What evidence is there that fire & explosion SCEs meet / do not meet performance standards? What anomalies have been identified? 10) What improvements have been identified and implemented as a result of the verification process? How is their implementation monitored? 11) How has the senior management satisfied itself that the verification process has adequately addressed any loss of integrity associated with ALE? 12) What conclusions can be drawn directly from the verification process on the risks from ALE to the overall fire & explosion integrity of the installation? Benchmarks sought in replies: A degree of independence is included in the audit and review arrangements The outcome of audits and reviews results in an updated ageing and life extension strategy Proposed changes are recorded / logged assessed and approved before implementation Formal audit programme which addresses ALE management processes August 2011 V1.0 Page 13 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section E: Ageing & Life Extension – Auditing and Reviewing Performance Audit findings reviewed by senior management Management improvements identified SCE verification process addresses ALE issues August 2011 V1.0 Page 14 of 15 KP4: Ageing and Life Extension – Inspection Template – Fire and Explosion Section E: Ageing & Life Extension Auditing and Reviewing Performance Onshore Management: Offshore Operations: HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NONCOMPLIANCE Court proceedings recommended 6 SIGNIFICANT NONCOMPLIANCE Enforcement Notice Served August 2011 V1.0 5 GENERAL NONCOMPLIANCE Letter & changes made to intervention 4 PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Letter Verbal advice No findings 3 2 1 NOT INSPECTED 0 Page 15 of 15