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Non-Conformance NGL HE

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Deferred Hydrotest and risk assessment: Technical
analysis is critical to the process
The Purpose
The intent of the presented integrity and operational risk assessment to get ARH approval
for deferral of hydrotest requirement of overdue NGL HE equipment (In- Operation) which
classified as Non-conformance equipment for ARH requirement of 10 years hydrotest. In
light of the below technical analysis which highlight the operational, integrity and risk
perspectives for the below referenced equipment, The expected deferral should be till next
shutdown camping 2025.
Assessment Scope
The assessment scope focus on fouling impact over the below listed heat exchanger and
the possibility to extend their service till next shutdown campaigns 2025 from process point
of view and other integrity perspective related . The assessment shall show that the existing
condition of the referenced heat exchanger in light of their design and operating parameters
which may justify the need to defer the 10 years hydroetst with means of manageable risks.
Provided that in case of deferral approval it couldn’t be extended or repeated beyond the
determined deferral in any case.
NGL heat exchangers with overdue hydrotest of ARH 10 years are listed below:
Heat Exchanger
Tag.
Test Condition
Non Conformance
Reason
Recommendation/Target
NGL E01-2706
Tested at service
pressure
Inconclusive inspection
due to
insufficient cleaning
Cleaning to be improved,
hydrotest postponed to 2025
NGL E01-2701-1
Tested at service
pressure
Not ready for inspection
due to inadequate
cleaning
Cleaning to be improved,
hydrotest postponed to 2025
NGL E01-2701-2
Tested at service
pressure
Not ready for inspection
due to inadequate
cleaning
Cleaning to be improved,
hydrotest postponed to 2025
NGL E01-2701-3
Tested at service
pressure
Not ready for inspection
due to inadequate
cleaning
Cleaning to be improved,
hydrotest postponed to 2025
NGL E01-2701-4
Tested at service
pressure
Not ready for inspection
due to inadequate
cleaning
Cleaning to be improved,
hydrotest postponed to 2025
NGL E01-2702-1
Tested at service
pressure
Not ready for inspection
due to inadequate
cleaning
Cleaning to be improved,
hydrotest postponed to 2025
E NGL 01-2702-2
Tested at service
pressure
Not ready for inspection
due to inadequate
cleaning
Cleaning to be improved,
hydrotest postponed to 2025
The referenced heat exchanger were offered for both external and internal inspection during
shutdown campaign Q1/Q2 2022, the inspection conclude that tube bundle not performed
difficult to be completely cleaned for satisfactory cleaning level fit for inspection and
hydrotest purposes but unfortunately the referenced equipment not inspected as per the
approved ITP’s for the previous cleaning issue. The alternative to solve such outstanding
which may interrupt shutdown schedule and operation resume to test the referenced heat
exchanger to the actual operating/service pressure to get confidence level to extend their
operational service. All equipment passed without leaking or pressure drop.
Criticality assessment
Many of the data requirements for the risk analysis are shared with a criticality assessment.
If a criticality assessment has been completed for the referenced NGL heat Exchangers, the
effects of failure, such as safety, Integrity and production impact, can be used. This data will
provide the majority of the "consequence" input to the risk calculation.
A. Equipment Efficiency and Process Control
(Part to be filled with Process team- add any valuable inputs/insights from process point of view (i.e.
fouling, unit efficiency, etc.)
B. Integrity Assessment
(Part to be filled by (Integrity highlight on chloride stress corrosion cracking and brittle fracture damage
mechanisms/riskd)
C. Mitigation Measures
(Part to be filled by chemical engineer or process team highlight mitigation practice against fouling
buildup )
D. Cleaning Methodology
(Part to be filled by SD team and highlight on the approved cleaning method for tube ID for tube
bundles which gaurntee adequate cleaning for future inspection and hydrotest purposes)
E. Other Consideration
(Part to be filled by any part related to general consideration to be taken in account, calrfifccations, etc.)
Conclusion
Recommendation
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