Scorecard Item No(s) Title: and API 510 & API 570, Deferrals Date: August 22, 2017

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1 Ballot ID: Scorecard Item No(s) Title: [tbd] and API 510 & API 570, Deferrals Date: August 22, 2017 Purpose: Source: Revision: 5 Impact: Rationale: Proposal: Name: Company: Phillips 66 John Harville (entire team includes; R.Konet, J.Reynolds, S. Bollinger, M.Smith, P.Blanda, D.Wang, A.Morey, J.Monroe, C.Paschke, J.Krynicki, T.Poulassichidis) Phone: john.j.harville@p66.com Provide a clear definition of the terms deferral and due date as well as clear/concise rules related to developing and/or invoking a deferral process. Industry practice, SCIMI scorecard items , and comments on Ballot ID 3826 (Std 570 Spring 2016 ballot items). This change will impact both API 510 and API 570. For consistency sake, the verbiage is identical between 570 and 510 (only exchanging the word piping for pressure vessel where appropriate) API is managing this change as one single ballot for both code documents. This proposal was previously included in ballot No 3826 titled Std 570 Spring 2016 ballot items. Negatives for that ballot were not resolvable and it was felt that the proposal did not fully address the scorecard items/concerns that originally prompted the proposal. Further discussions within the SCIMI resulted in a number of additional revisions to the originally balloted verbiage and the proposal below was agreed to at the Spring 2017 meeting. For consistency sake, this ballot affects two standards (API 510 and API 570) with details seen below. Also for consistency, when this ballot passes, the SCIMI will forward the final deferral verbiage to the SCAST for incorporation into API 653. The changes (end result) are identical in both API 510 and API 570. The following pages show the changes to each document in detail. API 510 (10 th Edition, Addendum 1) Revise table of contents as necessary Revise existing definition for inspection deferral Add new definition for due date Revise 6.7 Deferral of Inspection Due Dates API 570 (4 th edition, Addendum 1) Revise table of contents as necessary Add new definitions for deferral and due date Slight revision to verbiage in 6.1 to eliminate ambiguity. Revise 7.13 Inspection Deferral or Interval Revision Color Key of changes Blue = ballot commentary/guidance Black = existing (unchanged) verbiage) Red = new verbiage Red strikethrough = deleted verbiage Page 1 of 6

2 API 510 Proposed Changes Table of Contents rename 6.7 to Deferrals 6.7 Deferrals of Inspection Due Dates ## Revise the existing definition of inspection deferral and add new definition for due date (term is changing from inspection deferral to deferral. So put in alphabetical order and renumber as appropriate) inspection deferral A documented work process using risk assessment to defer an inspection beyond its due date for a specific period of time. See 6.7. An approved and documented postponement of an inspection, test or examination. (see 6.7) 3.1.XX due date The date established by the owner-user and in accordance with this code, whereby an inspection, test, examination or inspection recommendation falls due or is to be completed. The date may be established by; rule-based inspection methodologies (e.g. fixed intervals, retirement half-life interval, retirement date), risk-based methodologies (e.g. RBI target date), fitness for service analysis results, owner-user inspection agency practices/procedures/guidelines, or any combination thereof. Section 6.7 Revise the entire section as follows. Note: for ease of voter/commenter readability, the existing 6.7 verbiage was stricken and replaced in its entirety with the following; Strike: 6.7 Deferral of Inspection Due Dates Inspection tasks for equipment and pressure relief devices (not set by RBI) that cannot be performed by their due date can be risk assessed and deferred for a specific period of time, where appropriate. A deferral procedure shall be in place that defines a risk-based deferral process, including a corrective action plan and deferral date, plus necessary approvals, if inspection of a piece of pressure equipment is to be deferred beyond the established interval. That procedure should include: 1) concurrence with the appropriate pressure equipment personnel including the inspector and appropriate owner/ user management representative; 2) any required operating controls needed to make the extended run; 3) need for appropriate nonintrusive inspection with NDE, if any, as needed to justify the temporary extension; and 4) proper documentation of the deferral in the equipment records. Notwithstanding the above, an inspection or pressure relief device servicing interval may be deferred by the inspector, without other approvals, based on a satisfactory review of the equipment history and appropriate risk analysis, when the period of time for which the item is to be deferred does not exceed 10 % of the inspection/servicing interval or six months, whichever is less. For equipment with RBI intervals, the existing risk assessment should be updated to determine the change in risk that may exist by not doing the originally planned inspection. A similar approval process used for equipment with non-rbi intervals should be used to document the change in risk levels. Deferrals need to be completed and documented before the equipment is operated past the scheduled inspection due date and owner/user management apprised of the increased risk (if any) of temporarily operating past the scheduled inspection due date. Pressure equipment operated beyond the inspection due date without a documented and approved deferral is not permitted by this code. The deferral of scheduled inspections should be the occasional exception not a frequent occurrence. Page 2 of 6

3 Replace with: 6.7 Deferrals Inspections, tests or examinations for pressure vessels and associated pressure-relieving devices that cannot be completed by their due date, may be deferred for a specific period of time subject to the requirements in the following sub-sections. Pressure vessels or pressure-relieving devices that are operated beyond the due date without a valid deferral in accordance with these requirements, is not permitted by this code. Deferrals should be the occasional exception, not a frequent occurrence. All deferrals shall be documented. The guidance of an inspector, engineer or corrosion specialist should be obtained before requesting, granting, consenting to, or approving a deferral Simplified Deferral A simplified short-term deferral may be approved by the owner-user if ALL of the following conditions are met; a) The current due date has not been previously deferred. b) The proposed new due date would not increase the current inspection/servicing interval or due date by more than 10% or six months, whichever is less. c) A review of the current operating conditions as well as the pressure vessel or pressurerelieving device history has been completed with results that support a short-term/onetime deferral. d) The deferral request has the consent of the owner-user inspector and an appropriate operations management representative(s) Deferral Deferral requests not meeting the conditions of a Simplified Deferral above, shall follow a documented deferral procedure/process that includes the following minimum requirements; a) Performing a documented risk-assessment or updating an existing RBI assessment to determine if the proposed deferral date would increase risk above acceptable risk threshold levels as defined by the owner-user. The risk assessment may incorporate the following elements; - Fitness for service analysis results - Consequence of failure - Applicable damage mechanism susceptibilities and rates of degradation - Calculated remaining life - Historical conditions/findings from inspections, tests and examinations and their technical significance - Extent and/or probability of detection (i.e. effectiveness) of previous inspections, tests or examinations as well as the amount of time that has elapsed since they were last performed - Considerations for any previous changes to inspection or test intervals (e.g. reductions in interval due to deteriorating conditions) - Disposition(s) of any previous requests for deferral on the same pressure vessel or pressure-reliving device - Historical conditions/findings for pressure vessels or pressure-reliving devices in similar service if available b) Determining if the deferral requires the implementation of, or modification to existing integrity operating windows or operating process control limits. c) Reviewing the current inspection plan to determine if modifications are needed to support the deferral. d) Obtaining the consent and approval of appropriate pressure vessel personnel including the owner-user inspector and appropriate operations management representative(s). e) Updating the pressure vessel or pressure-relieving device records with deferral documentation before it is operated beyond the original due date. Page 3 of 6

4 API 570 Proposed Changes Table of Contents rename 7.13 to Deferrals 7.13 Inspection Deferrals or Interval Revision ## Add new term/definition for deferral and due date. 3.XX deferral An approved and documented postponement of an inspection, test or examination. (see 7.13) 3.XX due date The date established by the owner-user and in accordance with this code, whereby an inspection, test, examination or inspection recommendation falls due or is to be completed. The date may be established by; rule-based inspection methodologies (e.g. fixed intervals, retirement half-life interval, retirement date), risk-based methodologies (e.g. RBI target date), fitness for service analysis results, owner-user inspection agency practices/procedures/guidelines, or any combination thereof. Section 6.1 1st paragraph, last sentence. Revise to read;..see 7.13 for more information and requirements on overdue inspections, and inspection deferrals, and inspection interval revisions. Section 7.13 Revise entire section as follows; Note: for ease of voter/commenter readability, the existing 7.13 verbiage was stricken and replaced in its entirety with the following; Strike 7.13 Inspection Deferral or Interval Revision Inspection tasks for piping circuits and pressure relieving devices that cannot be performed by their due date can be risk assessed and deferred for a specific period of time, where appropriate. A deferral procedure shall be in place that defines a risk-based deferral process, including a corrective action plan and deferral date, plus necessary approvals. For equipment with RBI intervals/due dates, the existing risk assessment should be updated to determine if the change in risk is acceptable by not doing the originally planned inspection. If inspection of a piping circuit is to be deferred beyond the established interval. that procedure should include: a) concurrence with the appropriate piping personnel including the inspector and appropriate owner/user management representative; b) any required operating controls needed to make the extended run; c) need for appropriate nonintrusive inspection with NDE, if any, as needed to justify the temporary extension; and d) proper documentation of the deferral in the piping or PRD records. Notwithstanding the above, an inspection or pressure relieving device servicing interval may be deferred by the inspector, without other approvals, based on a satisfactory review of the equipment history and appropriate risk analysis, when the period of time for which the item is to be deferred does not exceed 10% of the inspection/servicing interval or six months, whichever is less. Page 4 of 6

5 Deferrals need to be completed and documented before the equipment is operated past the scheduled inspection due date and owner/user management apprised of the increased risk (if any) of temporarily operating past the scheduled inspection due date. Piping operated beyond the inspection due date without a documented and approved deferral is not permitted by this Code. The deferral of scheduled inspections should be the occasional exception not a frequent occurrence. NOTE If there are potentially any unusual types of degradation involved in the inspection of the piping systems, the inspector is advised to seek the guidance of the piping engineer or corrosion specialist before interval changes are approved. Replace with: 7.13 Deferrals Inspections, tests or examinations for piping and associated pressure-relieving devices that cannot be completed by their due date, may be deferred for a specific period of time subject to the requirements in the following sub-sections. Piping or pressure-relieving devices that are operated beyond the due date without a valid deferral in accordance with these requirements, is not permitted by this code. Deferrals should be the occasional exception, not a frequent occurrence. All deferrals shall be documented. The guidance of an inspector, piping engineer or corrosion specialist should be obtained before requesting, granting, consenting to, or approving a deferral Simplified Deferral A simplified short-term deferral may be approved by the owner-user if ALL of the following conditions are met; e) The current due date has not been previously deferred. f) The proposed new due date would not increase the current inspection/servicing interval or due date by more than 10% or six months, whichever is less. g) A review of the current operating conditions as well as the piping or pressure-relieving device history has been completed with results that support a short-term/one-time deferral. h) The deferral request has the consent of the owner-user inspector and an appropriate operations management representative(s) Deferral Deferral requests not meeting the conditions of a Simplified Deferral above, shall follow a documented deferral procedure/process that includes the following minimum requirements; f) Performing a documented risk-assessment or updating an existing RBI assessment to determine if the proposed deferral date would increase risk above acceptable risk threshold levels as defined by the owner-user. The risk assessment may incorporate the following elements; - Fitness for service analysis results - Consequence of failure - Applicable damage mechanism susceptibilities and rates of degradation - Calculated remaining life - Historical conditions/findings from inspections, tests and examinations and their technical significance - Extent and/or probability of detection (i.e. effectiveness) of previous inspections, tests or examinations as well as the amount of time that has elapsed since they were last performed - Considerations for any previous changes to inspection or test intervals (e.g. reductions in interval due to deteriorating conditions) - Disposition(s) of any previous requests for deferral on the same piping or pressurereliving device - Historical conditions/findings for piping or pressure-reliving devices in similar service if available g) Determining if the deferral requires the implementation of, or modification to existing integrity operating windows or operating process control limits. Page 5 of 6

6 h) Reviewing the current inspection plan to determine if modifications are needed to support the deferral. i) Obtaining the consent and approval of appropriate piping personnel including the owneruser inspector and appropriate operations management representative(s). j) Updating the piping or pressure-relieving device records with deferral documentation before it is operated beyond the original due date. Page 6 of 6