I am not a valve expert, although I often play one where I work. What I am is an end user, but I believe that provides me a unique outlook on risk.
My initial introduction to industrial valves came during mechanical engineering classes in college. Such classes are where the student discovers the deep, technical “insight” behind valve design: that a valve is two opposing triangles pointing at each other on a drawing.
Yep, that was about where my knowledge began. When I asked for a few more details, the answer was, “Oh, the suppliers or the valve guys can help you with that.” Fortunately, over the years I’ve found that to be true. I have received much support, advice and knowledge-sharing from many a valve OEM and distributor, for which I am grateful.
As the user, however, I am truly at the end of the line when it comes to dealing with the results that stem from the many decisions others make before a single valve is installed in one of my plants. This is an important point when you consider the inherent risks that design and specification decisions may have before and during installation. The user is left with the job of managing, maintaining and correcting based on what’s been done.
The days are long gone when building a chemical plant or a refinery was a matter of finding a flat, salt-marsh prairie somewhere and throwing together pipes, vessels, boilers, pumps, tanks, an alarm or two, and valves, of course—then making products as fast as you could. In those days, little thought was given to considerations such as the environment, community impact, long-term cost of ownership, or even the degree of risk for those working in or near the facility.
The good news is that many of yesterday’s plants are still standing, operating, and making product and profit for the owners. With improvements, upgrades and enhancements, those facilities are much safer, cleaner and efficient than when they were first built, which was often mid-20th century or before. Newer facilities are even safer.
Why is this so? Unfortunately, it’s because history and tragedy have taught us many lessons. Yet from the tough lessons, processes and tools have been created to manage inherent risks and mitigate hazards that come with many of our chemical and refining processes.
With all this in mind, I ask: when is a valve no longer just a commodity? What implications arise from a simple block valve enhanced to become part of a complex safety instrumented system (SIS)? What happens when risks are out of the control of the original designer or even the valve manufacturer?
THE USER VIEW
All of these issues end up with the user, who has to deal with what was installed based on decisons made both recently and sometimes long ago. These decisions may have been technical choices based on key drivers or even the engineering/sourcing trends of the day. That’s why we have to look at how risk was considered in those choices. We also have to consider what type of risk the key driver for the plant or project design was: Economics? Safety? Something else?
API 580 defines risk as the product of the probability of some event occurring during a time period of interest and the consequences (generally negative) associated with the event. In simple mathematical terms:
Risk = Probability × Consequence
To be honest, managing risk is not that simple. We expect our equipment to run and perform at many levels. We expect it to last; yet we know it can (and probably will) either fail at some point or become inefficient as a function of wear. There are risks that we, as users, can control and others that are awaiting discovery. The industry also has the additional challenge that the bar on process safety performance and environmental compliance rises ever higher and that bar applies to every facet of the petrochemical industry… even to something as simple (well, maybe not always “simple”) as a valve. We should recognize that, given this regulatory climate, users need more and more support from the OEMs and their distribution resources to meet the challenges. We should consider those challenges as we talk about where risk is today.
Managing risk starts at the beginning, before front-end engineering design (Pre-FEED). This is primarily within the use of good process safety/hazard analysis practices. A well-conducted and thorough analysis can guide the project team through choices such as valve selection and materials of construction, actuation and ancillary instrumentation. This is where safety instrumented functions are determined and where the separation of specialty versus commodity valves and decisions concerning actuation should be made. Through process hazard analysis (PHAs) and hazard and operability studies (HAZOPS), we work to mitigate the potentials for failure. This is just the first step, however. As the preliminary design work proceeds, other decisions concerning the operational environment, materials of construction and other design factors such as accessibility and ergonomics can be brought to bear.
A sad truth is that currently, operations and maintenance experts might not be invited to the party to review what the designers have created. How often has the question “How the heck will you operate this efficiently or isolate that safely?” not been asked of the user? What is even more disconcerting is to find out that designers with 15 to 20 or more years of engineering design experience have never set foot in an actual production unit.
AFTER THE THRILL OF THE EPC
At last the new facility or project is built. The years of planning, designing and building are done and the engineering, procurement, construction (EPC) process is complete. It is time to experience the joys of plant or project startup where theory will finally meet reality.
Within reliability engineering circles, this is called the bathtub curve because of the shape of what happens: At the beginning of the curve (startup), one experiences a good number of failures. The root and contributing causes for these failures is varied; but this is when we begin to find out if the choices, decisions, mindsets of two or three years ago are in our favor today. This is also the time where the different key drivers between the owners and the EPC contract will be most evident.
This may become even more apparent with larger capital investments if the mindset of “valves are only commodities” prevailed in valve selection and procurement. Instead of stating, “We have too many valves,” the question, “Do I have sufficient valves to safely operate, isolate and maintain this plant?” might be a better one. Be advised: A plant startup is a terrible time to find out how much that pair of rush-ordered and hot-shotted, 30-inch stainless-steel (SS) full port ball valves needed for a hot tap and stopple.
This also is the time when one discovers how good the materials management, construction and installation quality control was. Hopefully, we can catch things such as not installing a carbon steel (CS) valve in a service that requires 316SS, valve handle pinch-points, or wrong flow orientation during installation and before the water runs. Even something as simple as proper handling and protection of pipe and valves ordered early that are kept in the laydown yard for long periods of time can prevent many hours of corrective actions and replacements during start-up.
The other end of the bathtub curve occurs after a time of smooth operation when the user begins to deal with the effects of entropy and aging. Here, too, some of those early decisions and mindsets come to bear, especially in determining how long the flat of the curve can be. For example, the use of insufficient or incorrect coatings will promote early onset of corrosion under insulation. Wrong material choices (for example, the non-wetted CS valve components that don’t see the process but are exposed to both chemicals through leaks/vapors and environmental conditions such as rain or a saline atmosphere) can lead to problems ranging from operability to loss of containment.
What also may become evident on the right side of the curve is the initial installed quality of the valve itself. This can range from casting flaws and defects and poor metallurgical treatment to incorrect or inferior components.
If the user community is diligent, these problems are generally corrected in a timely manner with little loss or injury. In a recent event at a major Gulf Coast facility, a release of hydrocarbons occurred that could have been catastrophic. The cause was traced to a tiny piece of metal—a packing follower made by a third-tier supplier (which not surprisingly is no longer in business) that broke on a number of similar make and model valves throughout the unit. Fortunately, the facility was in the process of correcting the problem when the release occurred so there were no surprises. Even more fortunately, the release was quickly contained and no one was hurt.
So far we’ve referenced some of the day-to-day risks a user may encounter. However, other risks loom on the horizon. As noted earlier, many petro-chemical facilities built 40-60 years ago are still standing, operating, and making product and profit for the owners. With improvements, upgrades, and enhancements, many of these facilities are much safer, cleaner and efficient than when they were first built. However, these assets are being worked harder with increased throughputs and longer outage cycles. As no one has yet created a way to reverse entropy, the user community must be more vigilant.
Adding to the mix are other future risks: The two largest can be lumped into two groups: “Keeping Up with the Joneses” and “Keeping Up with Uncle Sam.”
COMPETITION AND CONSOLIDATION
Running the nation’s industries is a very competitive business. Not only are we working our assets harder, but the playing field has shifted. In the past two decades, with the many mergers and acquisitions within the petrochemical industry, some companies are no longer the household names they once were. With each consolidation, merger or acquisition, there is a resultant headcount reduction. When this happens, it is not just support services such as clerks and procurement reps that are let go. Engineering and similar technical resources also take a hit. During this time, companies adopt lean concepts, which also winnows the expertise. One last wrinkle in this picture is the final wave of boomers, who are close to leaving or have already left the ranks.
When the subject matter experts go—those with a company’s expertise and tribal knowledge, those that know why certain decisions were made—they take all the combined wisdom with them. As alluded to at the beginning of this article, valve training in our engineering colleges and universities is sparse, and I don’t think that has changed much from my own days, so this knowledge and expertise void will only widen.
Because of all this, users are relying more and more upon outside resources (EPCs, consultants, distributors and OEMs) for technical support.
CONSEQUENCES OF REGULATORY “SUPPORT”
The rising bar of increased regulatory expectations is the new norm. Add to this the fact that whole communities and towns and support industries now surround those plants that were plopped on isolated prairies. Closer neighbors are more acutely aware of what we do and how it could impact their lives. That means managing risk takes on even greater importance in light of possible impact on communities and the environment.
Some of what must be done to meet regulatory expectations is pretty straightforward in areas such as process safety management (PSM) and mechanical integrity (MI). In fact, the concept of MI was around long before the Occupational Safety and Health Administration (OSHA) co-opted the term through 1910.119. Simply put, MI is just darn good maintenance. OSHA expectations are only that our process equipment, including piping and controls, is appropriately designed, maintained and sustained.
Other regulatory expectations are more difficult to manage and may take more time to implement, as exhibited by the evolution of low-E valves. Newer rules, like the adoption of NSF/ANSI 61 (Drinking Water System Components—Health Effects) by many states, have caught both valve OEMs and their distributors, and the petrochemical industry off guard.
The problem can come from internal direction also. There have been a number of incidents where governmental entities such as the Environmental Protection Agency have negotiated with the appropriate internal corporate department; however, engineering or other technical resources are not brought into the discussion. If they had been, it might help to assure that unrealistic timing or unrealizable solutions are not promulgated in the form of consent decrees or other agreements.
A contributing cause to most of these regulatory examples is lack of communication between appropriate parties. This leads us to discussion of our greatest future risk: conflict.
As we have seen, every player involved with valves, from the OEM to the EPC, the owner to the user, has a different set of drivers and mindsets when it comes to selecting and installing valves. Although some degree of risk consideration and mitigation is used in the early processes, ultimately it’s up to the user to manage all of the known and possible risks so a safe and sustainable working environment can be maintained.
As we have also seen, the user community cannot do it alone. There was a positive sidebar to the hydrocarbon release example referenced previously: honest support and good information sharing with the OEM occurred up to and after the incident. Nothing was hidden and both sides were working toward a combined solution to resolve the problem. The incident could have been much worse without that degree of cooperation.
Our reducing knowledge base and ever-increasing safety and environmental expectations have created a greater need for improved partnerships and technology sharing between the petrochemical industry and OEMs, distributors …even the EPCs. After all, isn’t conflict our greatest risk?
Just in this past decade, too many tragic examples where we all failed have occurred. Deep down, we know that these incidents didn’t need to happen, that some risk was either not identified or mismanaged and, as a result, everyone involved failed.
As the saying goes: Those that forget the past are condemned to repeat it. Going forth, if we can’t agree on the right technical and sustainable solutions, poor decisions will be made… again. Unfortunately, users will be the ones living with that risk.