© Copy right of this article rests with its authors Dilip Patel and Sagoon Patel

Knowledge Sharing Series

Cost Effective Periodic Inspections, Testing and

Maintenance for Higher Asset Integrity and Regulatory
Compliance for LNG Terminals

Authors

Dilip Patel
Independent Consultant, Non Executive Director and Training Lecturer

Sagoon Patel
Independent Engineering Consultant

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CONTENTS:

1.0 Introduction ...................................................................................................... 3

2.0 Asset Integrity .................................................................................................. 3
3.0 Risk Based Inspection (RBI) Program .............................................................. 4
4.0 Cost Effective Maintenance ............................................................................. 5
5.0 Static and Packaged Equipment for Process and Utility ................................... 6
6.0 Rotating Equipment ......................................................................................... 7
7.0 Non Cryogenic Storage Tanks .......................................................................... 8
8.0 LNG Tanks ....................................................................................................... 8
9.0 Piping, Pipe Supports, Valves and Insulation ................................................... 9
10.0 Corrosion and Erosion - Control and Maintenance ......................................... 10
11.0 Onshore and Marine structures...................................................................... 10
12.0 Other Systems ............................................................................................... 10
13.0 References: ................................................................................................... 11

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1.0 Introduction
Regulatory compliances and the need to have high level of asset integrity are of
paramount importance to the Owners of LNG Plants because of high risks involved
with LNG, where regular inspections and maintenance may be limited due to
inaccessibility of most of the cryogenic equipment.

This article takes a holistic approach across all major disciplines to include static and
rotating equipment, structures, piping, electrical & instrumentation equipment, and
corrosion/erosion risks.

The management of risks needs to be supported by regular inspections, monitoring of

plant performance, risk based inspections (RBI) and maintenance of performance
standards for all safety critical elements.

The general approach proposed here is based on the management of risks in

conventional oil and gas industry that is adequately supported by international
standards and national regulatory rules on:

a) Monitoring of plant performances for safe operation

b) Periodic and risk based inspections
c) Maintenance performances standards

2.0 Asset Integrity

Definition of Asset Integrity by the UK HSE

Asset Integrity can be defined as the ability of an asset to perform its required
function effectively and efficiently whilst protecting health, safety and the environment.
Asset integrity management is the means of ensuring that the people, systems,
processes and resources that deliver integrity are in place, in use and will perform
when required over the whole lifecycle of the asset.

Owners should have a clear strategy and a detailed procedure for the asset integrity
for plants and associated facilities. Asset integrity philosophy and detailed procedures
should be developed from the outset from concept, front end engineering design
(FEED), detailed engineering, procurement and construction (EPC) to commissioning
and operational phases.

A structured approach to the asset integrity should be prepared as per ISO 31000
that shows the principles for managing risk, the framework for managing risk and the
risk management process. For oil and gas industry specific guidance, owners should
refer to API-RP-75 and apply its principals to LNG terminals.

In the USA, mandatory requirements for maintenance and inspection are specified in
49 CFR Part 193 – Liquefied natural gas facilities, federal safety standards, which in
general refers to compliance to the requirements in clauses 13 and 14 of NFPA 59A.
These being at high level, the owners should develop detailed procedures for the
LNG terminals they own and/or operate.

In Europe, EN 1473 also specifies requirements for maintenance and inspection at

very high level in clause 4.6. Therefore, owners of terminals designed to EN1473
should develop their own procedures for maintenance and inspections.

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Asset Integrity - Key Objectives:

1. To ensure that all equipment, tanks, structures, pipes, etc will remain fit for
purpose for their intended service throughout their life cycle without loss of
product containment.
2. Safety and utility systems designed to prevent or mitigate loss of product
containment or injury will function at all times as intended.
3. Prevention of a significant release of hazardous material or a sudden release
of energy.
4. To ensure protection of people, environment and the plant.

3.0 Risk Based Inspection (RBI) Program

Risk Based Inspection (RBI) is an optimised plant specific process used for
examining equipment such as pressure vessels, heat exchangers, tanks and piping in
hydrocarbon plants. The RBI process is for examining the risks to Health, Safety,
Environment and business, which can be active or with probability to damage to the
plant. This process assesses risks and rank failure probability and consequence. This
assessment and ranking is applied to optimise inspection intervals based on plant
specific acceptable risk levels and operating limits, whilst mitigating risks as
necessary. RBI analysis should be either qualitative, quantitative or semi-quantitative
in nature.

Risk based inspection concept was developed by the UK HSE and then the EEMUA
published its guidance on the RBI.

 The UK-HSE Report CRR 363/2001 - Best Practice for Risk Based Inspection
as a Part of Plant Integrity Management
 EEMUA 206 - Risk Based Inspection, A Guide to Effective Use of the RBI
Process
 API 580 - Risk-Based Inspection Recommended Practice
 ASME PCC-3 - Inspection Planning Using Risk-Based Methods
 API 581 - Risk Based Inspection Resource
 DNV-RP G101- Risk Based Inspection of Offshore Topsides Static Mechanical
Equipment
 API 571 - Damage Mechanisms Affecting Fixed Equipment in the Refining
Industry

The EEMUA guidance was produced predominantly for application on pressure

systems and equipment, but it is considered that the guidance is also of use to all
those involved in risk-based inspection of other mechanical plant.

The RBI process is generally aimed to achieve the following:

 Better management of risks and to maintain asset integrity

 To provide a well-informed, interdependent approach for managing risks
 To develop a strategy of doing what is needed for safeguarding integrity and
improving reliability and availability of the plant
 Apply inspection regime based on risk ranking which is based on
understanding degradation and failure mechanisms

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 To reduce inspections and shutdowns length without compromising safety or

reliability
 To reduce the risk of failures, increase plant availability and reduce unplanned
plant outages
 To develop a flexible technique for continuous improvements to deal with
changing of risks
 To implement inspection techniques which considers potential failure modes
 To achieve overall cost effectiveness in a manner where increased
expenditure on inspection and preventive maintenance would result in lower
unplanned shutdown and thereby result in overall cost reduction

For each plant the RBI process should be implemented and this should be supported
by experienced and independent organisation. Usually an RBI workshop is organised
to determine risks, rank these and recommend appropriate level of inspections for all
equipment, piping, tanks and structures in the plant. The workshop follows similar
practice in principal to that applied for the hazard and operability (HAZOP) workshop
in the oil and gas industry.

The above process is straightforward for the equipment and its components that are
easily accessible for inspections. Non cryogenic equipment or those that are spared,
inspections may be planned as normal. However, additional considerations must be
given for the cryogenic equipment that may pose more problems and even get
damaged when the plant has to be shut down and warmed up to get access to the
equipment for thorough inspections.

4.0 Cost Effective Maintenance

Various ways of asset maintenance management that may be deployed for an LNG
terminal are:

 Known reliability and in-house experience based maintenance – This may

work if the in-house experience is extensive and supported by well planned
regime for maintenance
 Proactive maintenance – This is based on either in-house experience or
manufacturer’s recommendations
 Reactive maintenance when failure occurs – This is only suitable for non
critical equipment where failure or non availability can be tolerated easily
without affecting plant safety and operability
 Manufacturer recommended schedule – This is a good approach and may not
necessarily be the best or cost effective
 Condition based maintenance and monitoring (CBM) – This is based on
extensive monitoring of asset or equipment and then to determine what and
when maintenance is required. Monitoring is based on records of instruments
readings, visual inspection, performance data and behaviours, etc. Drop in
performance or unusual indicators triggers the need for maintenance rather
that prescribed time interval based maintenance.

For achieving the cost effective maintenance to ensure no unplanned plant outage
and safe running of the plant, CBM offers an attractive solution. However, this
requires planning from the early design stages to ensure that all necessary
monitoring and recording instrumentation and equipment with appropriate
communication, data storage hardware and analysis software are in place. Along with
this, skilled and trained maintenance personnel are required to achieve the desired

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outcome. By doing this it is possible to reduce overall cost when considering savings
made from not having the unplanned plant outage and not having to spend time and
resources for unnecessary maintenance.

There are sophisticated condition monitoring systems such as GE Bentley Nevada

System 1 and other similar proprietary systems which are available for monitoring
condition and performance of the plant equipment. However, these are required to be
installed when a plant is being designed and built. For plants with large number of
critical equipment, the additional cost spent in installing condition monitoring system
is well justified.

Computerised Maintenance Management System (CMMS) can assist in planning of

maintenance task, procurement of spares, recording of activities and other useful
data, spares inventory management, subcontractors call offs, audit and certification,
etc.

5.0 Static and Packaged Equipment for Process and Utility

Static equipment includes vessels, heat exchangers, vaporisers, filters, flares and
pressurised containers of pumps. These items are designed and built to international
pressure vessel codes such as ASME VIII, EN 13445 or BS PD 5500.

Within the EU, the Pressure Systems Safety Regulations (PSSR) 2000 places
responsibility on owners to ensure to prevent serious injury from the hazard of stored
energy as a result of the failure of a pressure system or one of its component parts.
Prior to using any qualifying pressure equipment (new or otherwise), a written
scheme of examination (WSE) must be in place, and an examination undertaken.
This regulation includes requirements for all pressure vessels and pressurised
pipework within the plant.

In the United States the ASME Boiler and Pressure Vessel (BPV) Code establishes
the rules governing the design, fabrication, and inspection of boilers and pressure
vessels.

Typically, the following major process and utility equipment packages and static items
are installed at LNG terminals.

 Marine loading/unloading arms (MLA)

 Boil off gas Recondenser
 Boil off gas drain drums
 LNG drain drum at jetty
 Flare drain drum
 Submerged combustion vaporiser (SCV)
 Open rack vaporiser (ORV)
 Gas odorisation package and storage vessels
 Gas metering package
 Pipeline pig receiver / launchers
 Instrument air and dryer package and storage vessels
 Liquefied nitrogen storage vessels and vaporisation package
 Sea water intake package
 Sodium hypochlorite injection package
 Air conditioning and mechanical ventilation (ACMV) package including chillers

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Inspection Plans with specific inspection activities that are needed to ensure the
mechanical integrity of the pressure equipment should be established in collaboration
with the manufacturers, with the following in mind:

 Credible damage mechanisms that could affect the specific equipment. API
571 covers detailed information.
 Primary areas of degradation and expected rate/susceptibility.
 The type and extent of non-destructive examinations (NDE) and inspection
techniques required to detect and evaluate the damage mechanisms.
 Corrosion monitoring plans, NDE surveys, monitoring of process variables etc.
 Preparation required for the examinations and inspections.
 Inspection interval and dates of the next external and thorough inspections
and servicing intervals for the pressure-relief devices.

Full compliance to design codes and standards provide assurance of reliable

operation of newly-constructed vessels, tanks and piping.

Fitness-for-service standards such as API 579-1/ASME FFS-1, should be used to

assess whether or not it is safe to operate aging equipment that may have degraded
in service. Multi-disciplinary fitness-for service assessments performed on key assets
during a scheduled shutdown should greatly reduce the likelihood of unplanned
outages.

6.0 Rotating Equipment

The following machinery equipment are generally found in an LNG terminal.

 Boil off gas (BOG) compressors

 In tank (LP) and high pressure (HP) send out LNG pumps
 Seawater pumps
 Firewater pumps
 Utility pumps
 Boil off gas return blowers
 Emergency diesel generators
 GTGs for power generation
 Gas engines generating sets (GEG) for power generation
 Instrument air compressors
 ACMV equipment including chillier compressors

Inspection and maintenance of rotating equipment forms an important part of terminal

operation to avoid unplanned plant outages due to equipment failure.
As a minimum, inspection and maintenance should be carried out as per the
manufacturer’s recommendations. These should be modified for any site specific
concerns and to incorporate alternative recommendations for condition based
monitoring (CBM) and maintenance. To achieve a successful CBM the plant operator
must have in place necessary instrumentation for dynamic monitoring, recording and
required diagnostic tools. Interpretation of this data requires a specialist who can
recommend necessary modifications to the maintenance schedule. It is also
important that for effective CBM, to the extent possible, site vibration trends are
analysed against factory acceptance test results as well as commissioning data.

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All unplanned equipment shutdown, should be followed up by Root Cause Analysis

(RCA) and the results incorporated into the plant inspection programme. This should
help in capturing any plant wide as well as application specific concerns.

7.0 Non Cryogenic Storage Tanks

Non cryogenic storage tanks with near atmospheric pressure are designed, built,
inspected and tested to API – 650 – “Welded Steel Tanks for Oil Storage”. In-service
and periodic inspection and repair of such tanks are specified in the API – 653 - Tank
Inspection, Repair, Alteration, and Reconstruction”. Also in the UK such rules are
specified by Engineering Equipment and Materials Users Association ( EEMUA)
Publication No.159.

Following tanks are normally utilised in LNG Plants.

 Sodium hypochlorite storage tank - Reinforced Fiberglass Plastic

 Diesel storage tank – C Steel
 Firewater storage tanks – C Steel
 Utility water storage tank – C Steel
 Potable water storage tank – Stainless Steel

Inspection Plan for the above tanks may be prepared in accordance with API 653 for
inclusion in the LNG Terminal assessment integrity programme.

8.0 LNG Tanks

The LNG Tanks have an exemplary safety record for over 50 years. This has been
achieved because of the design codes specifically developed for LNG and LNG
industry’s dedication to safety.

The initial design code, NFPA 59A-1967, followed by in the US, 49CFR193, in the
1980s, BS 7777 in the 1990s and then EN 1473/EN 14620 codes in Europe, API 620
with API 625 in the USA and similar standards like DNV OS-C503 in other countries
have successfully guided the industry for safe design, installation, testing,
commissioning and operation of LNG tanks.

There are different types of LNG tanks and each type of tank requires a unique
approach for inspection and maintenance.

 Single containment tanks

 Double containment tanks
 Full Containment with 9% Ni inner and PC-RC Outer tank
 Full Containment with invar or stainless steel inner membrane and PC-RC
Outer tank
 Full containment in ground tanks

Clause 9 of EN-14620, Part 1 states “The contractor shall indicate critical items that
may require further attention in future so that the inspection and maintenance
program of the tank shall be prepared accordingly”.

As stated before, currently there are no international or national codes like API
510/570/653 specifically developed for in-service inspections of LNG tanks and

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equipment. In the UK, The Engineering Equipment and Materials Users Association –
EEMUA- has developed User’s Guide for the Inspection, Maintenance, and Repair of
Aboveground Vertical Cylindrical Steel Storage Tanks Publication No 159, which may
be used, in parts, as the basis for inspections of LNG tanks.

It is important that the tank design, materials, construction details and operations
data history including any modifications details are available to formulate inspection
strategy for the tank.

The complete inner tank and the inside of the outer tank are designed and built for
inspection free operation by incorporating temperature sensors along the bottom
slab, tank bottom and wall, thermal corner protection detail and in the vapour space
below and above the inner tank roof. In addition, certain tanks also incorporate inner
tank movement monitoring instruments. Seismic monitoring is also installed in certain
parts of the world where seismic risks are significant. Monitoring of the LNG tank
foundation is performed after the hydrotest. However, this monitoring should be part
of the ongoing monitoring process.

Owner should prepare with support from specialists an inspection plan for the LNG
tanks and this should be tailor made for each different type of LNG tank. It is primarily
external inspections, inclinometer survey and settlement survey. Thermography and
gas leak detection when required.

9.0 Piping, Pipe Supports, Valves and Insulation

Piping systems are generally designed and built to ASME B 31.3 code. In service
inspection and testing programme are essential for piping systems that carry LNG
from unloading arms to storage tanks, Low Pressure (LP) LNG from in-tank pumps to
High Pressure (HP) Send Out Pumps and finally to ORV Vaporisers. The same
applies to HP send out gas pipework.
LNG piping may vary from 40” to 2” nominal diameter. Pipes are made from stainless
steel and insulated with heavy duty polyurethane form insulation. A weather tight
stainless steel sheet finally covers the insulation to form a continuous protection layer
from outside. At some terminals the cladding over insulation can be GRP or urethane
material. At many points like instrument connections and support locations the
protection system has to be penetrated thus, forming potential weakness areas,
which requires inspection and maintenance.
The API code 570 “Piping Inspection Code: In-service Inspection, Rating, Repair, and
Alteration of Piping Systems” also provides in depth guidance for planning and
performing in service inspections for piping systems.

Pipework Inspection Considerations:

The following design considerations influence inspections that need to be

implemented at LNG terminals. Further details are available in API 570 and API 580.
a) The design features at LNG terminals can be unique to cryogenic
pipework and normally each operator should develop site inspection
procedures and check lists as considered appropriate by a competent
person either appointed by a statutory authority or independent third party
inspection agency.

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b) Materials of construction for piping in cryogenic service are usually

austenitic stainless steels or steels containing nickel. None of these
materials exhibit ductile to brittle transition behaviour at the cryogenic
operating temperatures.
c) Cryogenic equipment is operated at pressures above atmospheric.
Therefore, the design, fabrication, testing and inspection are in
accordance with recognised codes for piping and pressure vessels –
normally to ASME/API standards.
d) Equipment in contact with LNG should not be subject to any form of
internal aqueous corrosion because LNG is dry and clean. Outside of
piping is normally protected from corrosion by weatherproof insulation
system. However, penetrations of the outside layer will increase chance
of water getting to the stainless steel piping. Most of the time water will
freeze with limited chloride stress corrosion cracking possibility.
e) LNG piping go through large temperature cycles at start-up and shutdown.
There may be risk of cracking of attachment welds on stiffening brackets
and support rings as result of thermal cycling and if the supports do not
allow designed thermal movements.

10.0 Corrosion and Erosion - Control and Maintenance

For monitoring corrosion and erosion owners should deploy RBI approach unless
there is a need for a different approach based on experience.

There is corrosion risk at the ORV tubes if coating is damaged. The SCV tube bundle
can also suffer from chloride corrosion if caustic dosing system which keeps the bath
water Ph neutral has mal-functioned.

Cavitation risk for LNG pumps with nitrogen blending is a possibility due to heat gain,
if the nitrogen gas is liberated from the LNG and liquid nitrogen mixture inside the HP
pump. It is possible that valves or pipework downstream of control valve in LNG and
seawater service may suffer from cavitation or erosion. Specialist ultrasonic thickness
monitoring equipment is available from manufacturers like Permasense-Emerson
which can perform online monitoring and data collection from vessels and pipes to
alert the owner for metal loss due to corrosion, erosion or cavitation.

Other risks include corrosion under insulation and crevices of pipes and supports.
These areas should be part of RBI plan.

11.0 Onshore and Marine structures

Marine and other onshore structures should be part of the RBI plan for periodic
inspections to assess onset of any corrosion or other defects. Cathodic or sacrificial
anode protection systems should also be monitored and maintained to ensure
provision of active protection against corrosion.

12.0 Other Systems

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There are many other equipments and systems which require inspection, testing and
maintenance and typical ones are listed below. These equipment and systems will
require inspection, testing and maintenance plan to ensure overall safe and reliable
operation of the LNG terminal.
 Instrumentation and Control Systems
 Emergency shutdown and control valves
 Pressure relief valves
 Safety instrumented systems to IEC 61511 (SIS)
 Fire and gas detection system
 Safety critical elements
 Electrical equipment and systems
 Communication equipment and systems
 Lifting equipment and elevators
 Active and passive fire protection systems
 ACMV systems
In particular all of the safety related systems must be inspected, tested and certified
at regular intervals or as per the regulatory requirements. For the SIS, it is critical that
the system is function tested and certified by an independent third party as per the
detailed test plan compliant to the requirements of IEC 61511 code.

13.0 References:
1. EN – 1473 - Installation and equipment for liquefied natural gas — Design of onshore
installations
2. EN-14620 Design and manufacture of site built, vertical, cylindrical, flat-bottomed
steel tanks for the storage of refrigerated, liquefied gases with operating
temperatures between 0 °C and p165 °C : Parts 1, 2, 3, 4 and 5
3. NFPA 59A - Standard for the Production, Storage, and Handling of Liquefied Natural
Gas (LNG)
4. API – 12F - Specification for Shop Welded Tanks for Storage of Production Liquids
5. API – 510 pressure vessel inspection code
6. API – 620 - Design and Construction of Large, Welded, Low-pressure Storage Tanks
7. API-620 - Tank Systems for Refrigerated Liquefied Gas Storage
8. API – 650 - Welded Steel Tanks for Oil Storage
9. API – 653 - Tank Inspection, Repair, Alteration, and Reconstruction
10. PD395 - API 579-1/ASME FFS-1- Fitness-for Service
11. API 570 - Piping Inspection Code API 571 Damage Mechanisms Affecting Fixed
Equipment in the Refining Industry
12. API – 571 Damage Mechanisms Affecting Fixed Equipment in the Refining Industry
13. API - 580 - Risk-Based Inspection Recommended Practice
14. API 581 Risk Based Inspection Resource
15. API RP 75 - Recommended Practice for Development of a Safety and Environmental
Management Program for Offshore Operations and Facilities
16. API RP 74, Recommended Practice for Occupational Safety for Onshore Oil and Gas
Production Operations
17. ASME PCC-3 Inspection Planning Using Risk-Based Methods
18. ASME VIII - Boiler & Pressure Vessel Code (BPVC)
19. ASME B.31.3 - Process Piping

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20. EEMUA Publication No.159 - Above ground flat bottomed storage tanks - a guide to
inspection, maintenance and repair
21. EEMUA – 206: Risk Based Inspection - A Guide to Effective Use of the RBI Process
22. EN 13445 – Unfired Pressure Vessels
23. BS PD 5500 - Specification for unfired fusion welded pressure vessels
24. Pressure Systems Safety Regulations (PSSR) 2000
25. IEC 61511 - Functional safety - Safety instrumented systems for the process industry
sector
26. Key Programme 3 Asset Integrity Programme - A report by the Offshore Division of
HSE’s Hazardous Installations Directorate
27. Key Programme 3 Asset Integrity - KP3 Handbook – UK HSE
28. ISO 31000 : Risk Management – Principles and Guidelines
29. CPL 03-00-004 Petroleum Refinery Process Safety Management National Emphasis
Program (This is no longer in use)
30. 49 CFR Part 193 – Liquefied natural gas facilities: federal safety standards
31. The UK-HSE Report CRR 363/2001 ‘Best Practice for Risk Based Inspection as a
Part of Plant Integrity Management
32. DNV-RP G101Risk Based Inspection of Offshore Topsides Static Mechanical
Equipment

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