Isolating Equipment/Piping via physical air-gap to render it exempt from inspection?

[InspectorShain]

I have worked in refineries where it was an Owner/User procedural requirement to physically disconnect a vessel or piping system, and create an air-gap, prior to being considered "Out of Service" and rendering the component exempt from inspection requirements. My question is: Is anyone aware of any API/ASME/etc. industry standard or recommended practice which references "Out of Service" (specifically utilizing air-gapping) as an exemption from inspection or corrosion monitoring? Thank you, in advance.

 

[InspectorShain]

To clarify, there is no specific vessel I'm needing to inspect. It is a matter of any facility, in general, installing blinds or closing/locking block valves and identifying the equipment/piping as "Out of Service" (as well as on the P&ID), and saying "We don't want to waste money on inspection because it's now (arguably) "Out of Service". Some facilities require completing disconnecting (air-gapping) before a pressurized component can be classified "OOS". My question: Is there a code reference which clarifies the definition of "Out of Service", thus rendering a pressurized component exempt from API 510/570/etc. Inspection requirements?

 

[InspectorShain]

All right well several hours of searching the internet and code books led me to this one entry, from the NBIC code RB-3238 (1998 Interpretations):

INTERPRETATION 98-03
Subject: RB-3238 Interrupted Service
1998 Edition with the 1995 Addendum
Question
1:
Does paragraph RB-3238(f) of the NBIC define when a pressure vessel is
inservice or out-of-service?
Reply: No, the NBIC does not define out-of-service or in-service. This is subject to
jurisdictional requirements.

Out of curiosity, I then found this entry from New Jersey state law:

“Out-of-service” means any container, pipe, or equipment from which all liquid and sludge has been removed, all connecting lines and piping have been disconnected and blanked off, all valves (except for ventilation valves) have been closed and locked, and on which conspicuous signs have been posted that state that it is out of service and note the date of removal from service.

So I answered my own question, I think, but any additional input on the subject is welcomed.

 

[GulfCoastInspector]

InspectorShain, you may want to take a look at this quote I have copied from a recent external inspection of mine.

API 510 TENTH EDITION, MAY 2014 gives additional guidance concerning retired from service and abandoned in place equipment not contained in previous editions. I have quoted this guidance in italics below.

API 510 TENTH EDITION MAY 2014
1.1.1 Coverage
However, vessels that have been officially retired from service and abandoned in place (i.e. no longer are an asset of
record from a financial/accounting standpoint) are no longer covered by this “in-service inspection” code.

6.4 External Inspection
6.4.2 For equipment that is retired and abandoned in place, the owner/user may need to conduct appropriate external inspections to make sure that deterioration of insulation, vessel supports, and other pertinences do not deteriorate to the point where they become a hazard to personnel.


I am still waiting on an official ruling on what constitutes (i.e. no longer are an asset of record from a financial/accounting standpoint).

Hope this helps


Larry

 

[racookpe1978]

Works. Up to the point when you need to "re-certify the tank to put it back in use. Then .... Major dollars. All just to save a few dollars "inspecting" an empty, non-pressurized tank? Isolation is a good idea with respect to the blanking off and air gap, but look again at the expense of "un-insuring" them for a short time.

 

[InspectorShain]

Thanks for your responses, even if they were about 6 months late (lol). The reality I came to (and based on GulfCoastInspector's post, still am in agreement with) is that API/NBIC simply does not define what is considered the opposite of "In-Service". I would think that if you are publishing codes, recommended practices and guidelines for the inspection, repair and rerating of "In-Service" vessels and piping, naturally you might throw in a disclaimer of what condition would exempt the vessel or piping from being considered "In-Service", as that is going to be an obvious question or attempted loop-hole of many owner-users, right off the bat. However, the only real committed answer or lack thereof to this subject must be made by interpreting your local jurisdictional verbiage and cross-checking it against the owner/users documented practices, if they are documented at all.

I don't understand why this is an un-touched issue, with regard to API. I wonder if at some point they will recognize this as being a potentially abused loop-hole, due to lack of definition, and maybe offer additional recommendations/guidance/clarification as to what can reasonably be considered In/Out Of Service, at some point. Until there is a RAGAGEP in place defining a thing, that thing will continue to be misunderstood by some, perhaps understood and acted upon by others, but not consistently applied across the industry, due to the lack of guidance or lack of any generally accepted practice for all to follow.

 

[dcasto]

Several years ago we were faced with a dilemma where we didn't need the equipment, but our contractual financial instruments required that we could not take equipment out of service. We found a published standard out of the EU called mothballing equipment for future continued use. The scope covered equipment that was in tempory out of service. It set guidelines for the process of taking the equipment out of service with blinds and block and bleeds and blanketing ect...

Then it had guideline for reduced to no future inspections. We sent it to our financial instrument holders, ok bankers, and they bought off.

I can't find it again, but the title had the words mothballing and/or temporary shutdown of equipment.