1. What are the challenges operators are facing when trying to maintain their relief system program in a low-price oil environment?
The industry faces several challenges in the current low-price climate specifically due to the uncertainty in the pandemic-driven supply and demand pressures that extend beyond normal market economics. In addition to the impact of the pandemic, there are geo-political and regulatory pressures that may impact the oil pricing for some time. These aren’t normal times and Operators have to adjust accordingly to ensure profitable and viable processes.
Simply put, low oil prices translate to less money to spend on Capital Projects, Maintenance, Inspection, and even Operations. A relief system program is no different and may be impacted throughout its lifecycle. The focus of Operators should always be to make sure their relief systems hardware are operating safely and per their intended design since they represent the last line of defense against potential loss of primary containment in most cases.
The existence of a relief device goes through the following phases – Design and Development, Installation and Commissioning, Operations and Maintenance, Modifications, and Decommissioning. Some of these costs are associated with capital expenditure (CAPEX) and operating expenditure (OPEX).
The challenges that may impact relief systems and how an Operating company may adjust their methodologies will be expanded for each phase of the lifecycle.
Design and Development (Including Installation and Commissioning)
The design, development, installation and commissioning of a relief system(s) are usually part of a project and will be examined together: The project determines via engineering analysis the need and design of relief systems. Project spending may suffer the most, specifically if the project can be delayed through a cost / benefit analysis or a safety and risk analysis taking into account current market pressures. We have seen Operators currently going through their planned projects to decide which are essential and which can be delayed or cancelled all together. Typically, projects that intend to increase production or are planned for expansion of existing assets can be delayed since the current demand is low. It is recommended that Operators prioritize and possibly delay projects that are currently in the engineering phase or have not been started yet specifically if they are not related to the safe and sustained operation of their current Assets. It is also recommended to complete projects that are in their final phases.
Operations and Maintenance
The operation and maintenance phase of the relief system lifecycle is very important and should not be circumvented for obvious safety reasons. There are however several mechanisms that are available to Operators to reduce the OPEX cost and ensure continued safe operation of these critical Assets. Operators should focus on the following elements:
- Develop and maintain safe operating limits and strive to stay within these limits. Staying within the equipment’s safe operating limits will reduce the demand on the relief devices and will also reduce the need for non-scheduled inspection and maintenance.
- Implement a robust administrative controls program to ensure that Personnel actions do not compromise the overpressure protection. This will reduce the demand and thus reduce the need for non-scheduled inspection and maintenance.
- Make the move to a risk-based inspection and maintenance program which will ultimately reduce the cost. Briefly, the benefits of such a program would be to increase the inspection interval of high-risk relief devices which improves safety and reliability while low-risk relief valves maintenance intervals may be extended which would reduce cost without impacting reliability.
- Schedule their planned relief systems maintenance during a planned TAR to reduce cost and production impact that may be seen if maintenance is performed during an unplanned outage.
Modification in this context refers to changes, replacements, and small projects that are needed for continued safe operation without significant impact on production such as replacing a leaking bellows valve, for example. Operators should focus on the following elements:
- Try to replace faulty equipment in-kind to reduce the engineering cost associated with installing new equipment and eliminate the need for management of change process (MOC).
- Implement a robust MOC system to make sure that any replacement meets the required specifications for safe operation. Having a robust MOC system would reduce cost associated with engineering design inefficiencies such as not assessing the impact of the change on other systems which may require potential rework if not captured at the right time.
- Ensure access to accurate and complete documentation of relief system process safety information (PSI) as defined in the relevant standards. Having access to a complete set of PSI will help the engineer assess design alternatives and will ensure that the best and most cost effective design is selected. This would also allow Operations to select alternative modes of protection, if available, so that the maintenance could be delayed to a more appropriate time.
- Install valves to allow removal and replacement of relief devices without production interruption – if it can be done in a safe manner. A risk assessment should be evaluated for each case.
Decommissioning is the permanent removal of equipment from service when it is not intended to return back to service in the future. This may or may not include the demolition of the equipment. During this period, it is recommended that Operators should decommission the equipment by means other than demolition and removal from the field such as positive isolation from the live process, draining, inerting, and barricading to prevent access when it is not required.
2. What are some of the relief system program flaws you expect operators will need to overcome due to new operating norms?
Operators have to balance the need to cut CAPEX and OPEX without sacrificing safety and reliable operability. To help in the decision making, I cannot stress enough the need for a good process safety program for relief systems. The typical flaws that always come up for a relief system program are:
- Outdated design basis documentation that cannot be updated and maintained evergreen.
- Design basis that doesn’t include all overpressure scenarios and doesn’t document all relief calculations.
- Lack of training for Operations personnel on how to interpret the overpressure protection analysis.
- Lack of training for personnel that can initiate MOCs to identify the need to update the relief system analysis.
3. What steps or priorities should operators consider when looking to overcome program flaws?
The first priority to overcome these flaws is for Operators to ensure that their relief system PSI is updated and complete, accessible, and available in a form that can be modified based on the needs of the plant. The second priority is to have training for all personnel to be able to identify when relief systems updates are needed during a project or an MOC. The third priority is to have a single person or department in charge of coordinating the design, maintenance, and inspection of the relief to safeguard consistency.
4. How can operators find the right balance between their people, work processes, and technologies when looking to improve their relief system program?
The right balance is to impart the knowledge to the owners (Operations) of the relief devices to identify the need for modification or updates, to have competent engineers be in charge of the relief systems design and documentation to drive consistency, and to use technology such a SharePoint or a databases that house all the relief system PSI and makes them accessible to the stakeholders. Additionally, use an MOC database / software to track changes and action items to closure that also include verification steps to ensure the work is completed as intended.