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Pipe Clamp/Seal Procedures and Practices in California Petroleum Refineries. 2013 California State Emphasis Program. Are Pipe Clamps REALLY Legal?. Yes they are…and if used as a temporary repair they can be quite safe. Incidents Involving Pipe Clamps.

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pipe clamp seal procedures and practices in california petroleum refineries

Pipe Clamp/Seal Procedures and Practices in California Petroleum Refineries

2013 California State Emphasis Program

are pipe clamps really legal
Are Pipe Clamps REALLY Legal?
  • Yes they are…and if used as a temporary repair they can be quite safe.
incidents involving pipe clamps
Incidents Involving Pipe Clamps
  • Sunoco Inc. has been fined $147,000 for faulty maintenance procedures at its oil refinery in East Toledo after an April 6, 2009 incident.
  • A worker was hit with gasoline that spurted out of a pipe.
  • OSHA alleged that the refinery failed to use properly engineered pipe clamps; to ensure pipe leaks were repaired properly; to repair or replace pipe valves; and to follow proper repair procedures.
incidents involving pipe clamps1
Incidents Involving Pipe Clamps
  • Wynnewood Refining Company; The refinery’s alkylation (Alky) unit. Concerned about the number of leaks and the apparent ineffectiveness of the PermaWrap repairs on flare line.
  • Chief Pipe Inspector Mr. Long recommended replacing portions of the line. Management, however, rejected this recommendation and continued its course of temporary repairs.
  • On May 12, 2006, a fire erupted in the Alky Unit, one cause of the fire was a rip in the flare line where several repairs had been attempted.
wynnewood refining company continued
Wynnewood Refining Company continued…
  • The ALJ specifically acknowledged that
    • “an employer’s good faith efforts to correct a hazard, even if not entirely effective, can negate willfulness; however, whether an employer acted in good faith is an objectively reasonable test. Thus, if an employer’s measures to address a hazard were to maintain production rather than a genuine effort to abate the hazard, the violation will be found to be willful.”
our mission should you decide to accept
Our Mission (should you decide to accept…)
  • Review Pipe Leak Repair Databases
  • Review Process Pipe Repairs
  • (except for utilities lines i.e. utility water lines, fire water lines, some steam lines, and nitrogen/air lines)
  • “Look at clamps”
  • “Review leak seal (MOC) data”
  • Cite any repair not changed at next turnaround (?)
legal foundation is like quick sand
Legal Foundation (is like quick sand)

Title 8: Section 6845 (a)……the testing, inspection, and repair of all piping systems shall comply with …

and API 570, Piping Inspection Code, Second Edition, October 1998, Addendum 3, August 2003; and ASME B31.3-2002, Process Piping; herein incorporated by reference.

api 570 section 8 1 4 nonwelding repairs on stream
API 570, Section 8.1.4 Nonwelding Repairs (On-Stream)

“During turnaround or other appropriate opportunities, temporary leak sealing and leak dissipating devices, including valves, shall be removedand appropriate actions taken to restore the original integrity of the piping system.“

ragagep recognized and generally accepted good engineering practice
RAGAGEP"Recognized And Generally Accepted Good Engineering Practice"
  • What is a RAGAGEP?
    • an engineering, operation, or maintenance activity based on established codes, standards, published technical reports or recommended practices.

What is NOT a RAGAGEP?

    • it is not a historical practice at a facility that has been done for many years  and "has not killed us yet“ or "the way we have always done it“.
    • Why do I speak of RAGAGEP?
api 570 ragagep
API (570) = RAGAGEP
  • But not everyone agrees…
    • Dr. Andrew Hopkins renowned expert on Safety Case regulation stated at a presentation of the Oil and Gas Expert Forum on safety case regulated stated;
    • “API is not a Best Practice Standard BUT a Lowest Common Denominator Standard.”
    • I present this only as “Food for Thought.”
leak seal inspection protocols
LEAK SEAL Inspection Protocols
  • All 15 Refineries in California will be inspected
  • Review “Leaking Pipe” databases (if available)
  • Search database narrow field of inspection;
    • high temperature (>600 deg)
    • Priority: high or emergency
    • Liquid in pipe that would burn or is toxic.
    • Not steam, not condensate. (water)
    • (*exception: control on a process?)
  • Select targets
  • Request specific dates of last turnarounds
temp repair types
Temp Repair Types
  • Clamps (flange, valve
  • Pipe wraps
  • Wire wraps
  • Crimps
  • Injection fittings

All are “non-welding” repairs

most leak seals are or include injection fittings
Most leak seals are or include injection fittings
  • Excess sealant can result in blockage of full valve closure
  • Some are injected more than once
  • It is not a permanent solution