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- Herausgeber: John Wiley & Sons
- Kategorie: Fachliteratur
- Sprache: Englisch
This book is an update and expansion of topics covered in Guidelines for Mechanical Integrity Systems (2006). The new book is consistent with Risk-Based Process Safety and Life Cycle approaches and includes details on failure modes and mechanisms. Also, example testing an inspection programs is included for various types of equipment and systems. Guidance and examples are provided for selecting and maintaining critical safety systems.
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Veröffentlichungsjahr: 2017
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GUIDELINES FORASSET INTEGRITY MANAGEMENT
CENTER FOR CHEMICAL PROCESS SAFETYof theAMERICAN INSTITUTE OF CHEMICAL ENGINEERS
NEW YORK, NY
Copyright © 2017 by the American Institute of Chemical Engineers, Inc. All rights reserved.
Published by John Wiley & Sons, Inc., Hoboken, New Jersey.
Published simultaneously in Canada.
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Library of Congress Cataloging-in-Publication Data is available.
ISBN: 978-1-119-01014-2
It is sincerely hoped that the information presented in this document will lead to an even more impressive safety record for the process industries; however, neither the American Institute of Chemical Engineers (AIChE), its consultants, the AIChE’s Center for Chemical Process Safety (CCPS) Technical Steering Committee, the Asset Integrity Management Subcommittee members, their employers, their employers’ officers and directors, nor Unwin Company and its employees, officers and directors warrant or represent, expressly or by implication, the correctness or accuracy of the content of the information presented in these Guidelines. As between (1) the AIChE, its consultants, the CCPS Technical Steering Committee and Subcommittee members, their employers, their employers’ officers and directors, and Unwin Company and its employees, officers and directors, and (2) the user of this document, the user accepts any legal liability or responsibility whatsoever for the consequence of its use or misuse.
It is the commitment of CCPS to develop publications with the intent of driving continual improvement in process safety. To this end, this publication may, at its release, characterize an aspirational level of performance representing a state beyond recognized and generally accepted good engineering practice (RAGAGEP). It should be noted that RAGAGEP is not a static concept and will change based on continuously evolving industry information. As industry practices advance with time, generally accepted practices may reach and potentially surpass the practices described in this publication. Users are responsible to make their own determinations whether this CCPS publication is RAGAGEP.
CONTENTS
List of Figures
List of Tables
Preface
Acknowledgments
Files on the Web
1 Introduction
1.1 Background and Scope
1.2 What is Asset Integrity Management?
1.3 What Assets are Included?
1.4 AIM Life Cycle
1.5 Relationship to Other Programs
1.6 Relationship to RAGAGEP
1.7 Structure of this Document
Chapter 1 References
2 Management Responsibility
2.1 Leadership Roles and Responsibilities
2.2 Technical Assurance Responsibilities
Chapter 2 References
3 AIM Life Cycle
3.1 Overview
3.2 Research Through Process Development
3.3 Process Design
3.4 Engineering, Procurement and Construction
3.5 Commissioning
3.6 Operation and Maintenance
3.7 Decommissioning
3.8 RAGAGEP Selection and Application at Each Stage
Chapter 3 References
Appendix 3A. Design Review Suggestions
4 Failure Modes and Mechanisms
4.1 Introduction
4.2 Equipment Functions and Functional Failure
4.3 Failure Modes
4.4 Damage Mechanisms
4.5 Failure Effects
4.6 Risk
4.7 Analysis
4.8 ITPM Task Assignments
4.9 Operational Issues
4.10 Other Related Activities
Chapter 4 References
Appendix 4A. Risk Concepts Related to AIM
5 Asset Selection and Criticality Determination
5.1 Program Objectives and Philosophy
5.2 Asset Selection Criteria and Principles
5.3 Level of Detail
5.4 Asset Criticality Determination
5.5 Documentation
5.6 Roles and Responsibilities
Chapter 5 References
Appendix 5A. Sample Guidelines for Selecting Assets for an AIM Program
6 Inspection, Testing and Preventive Maintenance
6.1 ITPM Task Planning
6.2 ITPM Task Execution and Monitoring
6.3 ITPM Program Roles and Responsibilities
Chapter 6 References
Appendix 6A. Common Predictive Maintenance and Nondestructive Testing (NDT) Techniques for Mechanical Equipment
7 Established Approaches for Developing Test and Inspection Plans
7.1 Code/Standard Approaches
7.2 Regulatory Authority Approaches
7.3 Company-Specific Approaches
7.4 Risk-Based Inspection (RBI)
7.5 Failure Modes, Effects and Criticality Analysis Approaches
7.6 Safety Instrumented Systems
Chapter 7 References
8 AIM Training and Performance Assurance
8.1 Skills and Knowledge Assessment
8.2 Training For New and Current Workers
8.3 Verification and Documentation of Performance Assurance
8.4 Certifications
8.5 Ongoing and Refresher Training
8.6 Training for Maintenance Technicians and Operators Performing Maintenance Tasks
8.7 Training for Technical Personnel
8.8 Contractor Issues
8.9 Roles and Responsibilities
Chapter 8 References
Appendix 8A. Sample Training Survey
Appendix 8B. Sample Training Guide
9 Asset Integrity Procedures
9.1 Types of Procedures Supporting the AIM Program
9.2 Identification of Needs
9.3 Procedure Development Process
9.4 Format and Content
9.5 Other Sources of AIM Procedures
9.6 Implementing and Maintaining AIM Procedures
9.7 AIM Procedure Program Roles and Responsibilities
Chapter 9 References
Appendix 9A. Example AIM Procedure
10 Quality Management
10.1 Design
10.2 Procurement
10.3 Fabrication
10.4 Receiving
10.5 Storage and Retrieval
10.6 Construction and Installation
10.7 In-service Repairs, Alterations and Rerating
10.8 Temporary Installations and Temporary Repairs
10.9 Decommissioning / Re-use
10.10 Used Assets
10.11 Spare Parts
10.12 Contractor-Supplied Assets and Materials
10.13 QA Program Roles and Responsibilities
Chapter 10 References
Appendix 10A. Sample Vendor QA Plan
Appendix 10B. Positive Material Identification
Appendix 10C. Sample Service Contractor QA Plan
11 Equipment Deficiency Management
11.1 Equipment Deficiency Management Process
11.2 Acceptance Criteria
11.3 Equipment Deficiency Identification
11.4 Responding to Equipment Deficiencies
11.5 Equipment Deficiency Communication
11.6 Tracking of Temporary Repairs
11.7 Deficiency Management Roles and Responsibilities
Chapter 11 References
12 Equipment-Specific Integrity Management
12.1 Vessels, Tanks and Piping
12.2 Relief and Vent Systems
12.3 Instrumentation and Controls
12.4 Rotating Equipment
12.5 Fired Equipment
12.6 Electrical Systems
12.7 Fire Protection and Suppression Systems
12.8 Ventilation and Purge Systems
12.9 Protective Systems
12.10 Passive Mitigation Systems
12.11 Solids-Handling Systems
12.12 Refrigeration Systems
12.13 Utilities
12.14 Safety Equipment
Chapter 12 References
Appendix 12A. Asset Integrity Activities by Equipment Type
13 AIM Program Implementation
13.1 Budgeting and Resources
13.2 Use of Data Management Systems
13.3 AIM Benefits and Return on Investment
Chapter 13 References
Appendix 13A. AIM Program Design Activity Worksheets
14 Metrics, Audits and Continuous Improvement: Learning from Experience
14.1 Performance Measurement and Monitoring
14.2 AIM Program and Implementation Audits
14.3 Continuous Improvement
Chapter 14 References
Appendix 14A. AIM-Related Regulatory Citations
15 Other Asset Management Tools
15.1 Introduction to Common Risk-based Analytical Techniques Used in AIM Programs
15.2 Incorporating Risk into AIM Decisions
15.3 Reliability-Centered Maintenance
15.4 Protection Layer Analysis Techniques
15.5 Asset Failure and Root Cause Analyses
Chapter 15 References
Acronyms and Abbreviations
Glossary
Index
LIST OF FIGURES
FIGURE
1-1
Summary of AIM activities throughout a facility life cycle
2-1
Definition of the integrity operating window (IOW)
3-1
Life cycle stages cross-referenced to Chapter 3 sections
5-1
Risk-based determination of safety-critical equipment
6-1
ITPM task selection process
6-2
Contribution of early, constant and wear-out failures to observed failure rate
6-3
Example ITPM task selection decision tree
7-1
Management of risk using RBI
7-2
RBI program flowchart
7-3
SIS development and implementation steps showing test and inspection interfaces
8-1
Training flowchart
9-1
AIM procedure hierarchy
9-2
Basic procedure development process
9-3
Procedure-writing checklist
11-1
Technical evaluation condition selection
14-1
AIM program continuous improvement model
14-2
Example AIM process map with suggested performance measures
15-1
Example risk matrix with ALARP region
15-2
Example RCM decision tree
15-3
Sample LOPA worksheet
15-4
Sample failure analysis process
15-5
Sample fault tree
15-6
Sample causal factor chart
LIST OF TABLES
TABLE
1-1
Example AIM Interfaces with Other Facility Programs
1-2
Relationships between AIM Activities and Risk-Based Process Safety Elements
1-3
Chapters Addressing Management Systems for AIM Activities
2-1
Example AIM Roles and Responsibilities Matrix
3-1
Typical Design Code Applications
3-2
Issues Relevant to Use of RAGAGEP at Different Life Cycle Stages
4-1
Example Process Equipment Failure Modes
4-2
Example Failure Modes for Some Other Asset Types
4-3
Example Damage Mechanisms
4-4
Example FMEA
5-1
Suggested Major Incident Definition
5-2
Some Typical Safety-Critical Equipment for Exploration and Production Facilities
5-3
Example Roles and Responsibilities Matrix for Asset Selection and Criticality Determination
6-1
Definition of ITPM Terms
6-2
Typical Asset File Information for Selected Asset Types
6-3
Factors Affecting ITPM Tasks for Relief Devices, Instrumentation and Rotating Equipment
6-4
Example ITPM Plan in Tabular Format
6-5
Example Roles and Responsibilities Matrix for the ITPM Task Planning Phase
6-6
Example Roles and Responsibilities Matrix for the ITPM Task Execution and Monitoring Phase
7-1
Sample FMEA Worksheet
8-1
Training Approach Considerations
8-2
General Electrician Training Matrix Format Example
8-3
Widely Accepted AIM Certifications
8-4
Training Categories and Example Requirements
8-5
Example Asset Engineer Potential Training Requirements
8-6
Example Roles and Responsibilities Matrix for the AIM Training Program
9-1
Example AIM Procedures
9-2
Example Qualitative Risk Ranking Results for Procedure Determination
9-3
Example Roles and Responsibilities Matrix for the AIM Procedure Program
10-1
Definition of Quality-Related Terms for Asset Integrity Management
10-2
Typical Design Code Applications
10-3
Repair, Alteration and Rerating
10-4
Sample of Codes and Standards Having QA Requirements Applicable to Repair, Alteration and Rerating
10-5
Example Roles and Responsibilities Matrix for the QA Program (Existing Facility)
11-1
Acceptance Criteria Resources
11-2
Examples of Acceptance Criteria for Common Asset Types
11-3
Example Roles and Responsibilities Matrix for Equipment Deficiency Resolution
12-1
Codes/Standards/Practices for Pressure Vessels
12-2
Codes/Standards/Practices for Atmospheric/Low-Pressure Storage Tanks
12-3
Codes/Standards/Practices for Process Piping
12-4
Codes/Standards/Practices for Pressure-Relieving Devices
12-5
Codes/Standards/Practices for Instrumentation and Controls
12-6
Codes/Standards/Practices for Pumps
12-7
Codes/Standards/Practices for Compressors
12-8
Codes/Standards/Practices for Turbines
12-9
Codes/Standards/Practices for Fans and Gearboxes
12-10
Codes/Standards/Practices for Fired Heaters and Furnaces
12-11
Commonly Used NFPA Codes for Fire Protection Systems
12-12
Codes/Standards/Practices for Refrigeration Equipment
12-13
Standards and Regulations for Selected Safety Equipment
12A-1
Asset Integrity Activities for Pressure Vessels
12A-2
Asset Integrity Activities for Storage Tanks
12A-3
Asset Integrity Activities for Piping Systems
12A-4
Asset Integrity Activities for Pressure Relief Valves
12A-5
Asset Integrity Activities for Rupture Disks
12A-6
Asset Integrity Activities for Conservation Vents and Other Low Pressure/Vacuum Relief Devices
12A-7
Asset Integrity Activities for Flame/Detonation Arresters
12A-8
Asset Integrity Activities for Emergency Vents
12A-9
Asset Integrity Activities for Vent Headers
12A-10
Asset Integrity Activities for Thermal Oxidizers
12A-11
Asset Integrity Activities for Flare Systems
12A-12
Asset Integrity Activities for Explosion Vents
12A-13
Asset Integrity Activities for Safety Instrumented Systems and Emergency Shutdowns
12A-14
Asset Integrity Activities for Pumps
12A-15
Asset Integrity Activities for Fired Heaters, Furnaces and Boilers
12A-16
Asset Integrity Activities for Switchgear
13-1
Summary of Resources Required for AIM Program Development Activities
13-2
Typical Initial Implementation Tasks by Activity
13-3
Examples of Ongoing QA Activities
14-1
AIM Program Leading-Indicator Metrics
14-2
AIM Audit Approach
14-3
AIM-Related Regulatory Citations
15-1
Summary of Analytical Techniques
15-2
Sample RCM FMEA Worksheet
15-3
IEC 61511 Safety Integrity Levels
PREFACE
The American Institute of Chemical Engineers (AIChE) has been closely involved with process safety and loss prevention issues in the chemical and allied industries for nearly 50 years. Through its strong ties with process designers, constructors, operators, safety professionals and members of academia, AIChE has enhanced communications and fostered continuous improvement of the industry’s high safety standards. AIChE publications and symposia have become information resources for those devoted to process safety and environmental protection.
AIChE created the Center for Chemical Process Safety (CCPS) in 1985 after the chemical disasters in Mexico City, Mexico and Bhopal, India. The CCPS is chartered to develop and disseminate technical information for use in the prevention of major chemical incidents. The Center is supported by more than 150 sponsor companies that provide the necessary funding and professional guidance to its technical committees. The major product of CCPS activities has been a series of guidelines to assist those implementing various elements of a process safety and risk management system. This book is part of that series.
Ensuring the initial and ongoing integrity of process equipment, including instrumentation and safety systems, has become known as asset integrity management or AIM. Asset Integrity and Reliability is a fundamental component of successful, risk-based process safety programs. However, facilities continue to be challenged to develop and maintain successful AIM programs. CCPS’ Technical Steering Committee commissioned these guidelines, as an update and expansion of the previous CCPS document Guidelines for Mechanical Integrity Systems, to continue assisting facilities in meeting this challenge. The change in terms from mechanical integrity to asset integrity reflects international usage, consistent with the elements in CCPS’ more recent Guidelines for Risk Based Process Safety*, and a recognition that a much broader set of assets needs to be properly designed, installed and maintained at process facilities than those requiring “mechanical” integrity.
In addition, the term equipment is often associated with an individual piece of equipment such as a pump, compressor or vessel. The term asset better reflects how equipment and its associated instrumentation, utilities and connections function together as a system and the integrity of which must be maintained holistically as a system.
This document contains approaches and resources for designing, developing, implementing and improving AIM programs. Even the best AIM programs cannot guarantee that incidents will not occur. However, an effective AIM program, integrated with other elements of process safety management, can significantly reduce risks associated with operations involving hazardous materials and energies.
This document only addresses asset integrity for fixed facilities in the process industries. Transportation aspects including pipeline integrity are not covered, although many of the same principles apply.
Notes
*
American Institute of Chemical Engineers,
Guidelines for Risk Based Process Safety,
Center for Chemical Process Safety, New York, NY, 2007. References in this book are at the end of each chapter.
ACKNOWLEDGMENTS
The Chemical Center for Process Safety (CCPS) thanks all of the members of the Asset Integrity Management (AIM) Subcommittee for providing technical guidance in the preparation of this book. CCPS also expresses its appreciation to the members of the Technical Steering Committee for their advice and support.
The chairman of the AIM Subcommittee was Eric Freiburger of Praxair. Mike Broadribb of Baker Risk was co-chair. The CCPS staff consultant was John F. Murphy. The AIM Subcommittee had the following contributing members:
Andrew Basler, Mallinckrodt
Matt Hedlund, Eastman Chemical
Kevin Blackwell, Honeywell
Tom Sandbrook, Chemours
Russ Davis, Mistras Group
John Traynor, Evonik
Jonas Duarte, Chemtura
Chris Urbanowich, Petrobras
Unwin Company (Columbus, Ohio) prepared this document under contract with CCPS. Robert W. Johnson was the lead contract author, with input from Steven W. Rudy.
Acknowledgement is also given to Robert W. Ormsby, who was the CCPS staff consultant at the beginning of this project; to Tom Folk, who prepared the detailed outline for the AIM Subcommittee; and to ABSG Consulting Inc., which prepared CCPS’ precursor to this publication, Guidelines for Mechanical Integrity Systems.
CCPS gratefully acknowledges the comments submitted by the following peer reviewers, whose insights and suggestions helped ensure a balanced perspective. It should be noted that the peer review was based on a final draft of this document and, as such, the peer reviewers did not provide comments on the final published manuscript.
Robert A. Bartlett, Pareto Engineering & Management Consulting James M. Broadribb, Wood Group
Robert A. Bartlett, Pareto Engineering & Management Consulting Hugh Hemphill, Chevron
Mark Jackson, FM Global
Adrian Sepeda, Process Safety & Risk Management
Razzack Syed, Praxair Inc.
David Thaman, PPG
Terry A. Waldrop, AIG
FILES ON THE WEB
The following files are available to purchasers of Guidelines for Asset Integrity Management. They are accessible from the AIChE/CCPS website at http://www.aiche.org/sites/default/files/book-downloads/AIMsupplements.pdf using the password AIM2017. Users of this information are responsible for determining the suitability of these resources to their particular AIM program.
Chapter 8 (AIM Training) Resources
Sample skills/knowledge list for an electrician
Sample skills/knowledge list for a mechanic
Chapter 12 (Equipment-Specific) Resources
Instrumentation and controls:
– Process control systems
– Critical alarms and interlocks
– Chemical monitors and detection systems
– Conductivity, pH, and other process analyzers
– Burner management systems
Rotating equipment:
– Reciprocating compressors
– Centrifugal compressors, including specific protection systems (e.g., pressure cutouts)
– Process fans and blowers
– Agitators and mixers
– Electric motors
– Gas turbines
– Steam turbines
– Gearboxes
Electrical systems:
– Transformers
– Motor controls
– Uninterruptible power supplies (UPSs)
– Emergency generators
– Lightning protection
– Grounding systems
Chapter 15 (AIM Tool) Resources
Presentation papers related to analysis approaches:
–
Risk-Based Approach to Mechanical Integrity Success on Implementation
–
An Insurer’s View of Risk-Based Inspection
–
RCM Makes Sense for PSM-Covered Facilities
–
Lessons Learned from a Reliability-Centered Maintenance Analysis
Resources for performing equipment failure analyses:
– Additional detailed information on the analysis steps
– An equipment failure analysis checklist
Resources for performing root cause analyses:
– SOURCE™ Investigator’s Toolkit
– Root cause map
– Causal factor chart and fault tree templates
AIM program audit resources
Presentation paper —
Improving Mechanical Integrity in Chemical and Hydrocarbon Processing Facilities - An Insurer’s Viewpoint
1Introduction
This chapter introduces asset integrity management (AIM), including the scope and objectives of AIM programs throughout a facility life cycle and the relationship of AIM to other process safety elements. The last section in this chapter outlines the structure of this document.
Since a successful AIM program involves leadership, managers, engineers, operating and maintenance personnel, contractors, suppliers and support staff, this document was prepared for a wide range of audiences and potential users. AIM is an integrated product of proper equipment, dependable human performance and effective management systems. Guidelines are given for developing, implementing and continually improving an AIM program that includes these areas of focus. Behind these focus areas needs to be an involved, supportive management. Consequently, this document also includes guidance to those supporting the program.
1.1 BACKGROUND AND SCOPE
For decades, AIM activities, in one form or another, have been a part of industry’s efforts to prevent incidents and maintain productivity. Industry initiatives, company initiatives and regulations in various countries have helped both to define AIM program requirements and to accelerate implementation of AIM programs. AIM is already ingrained in the culture of many process plants, as well as facilities in other related industries. AIM activities are essential for process facilities to maintain economic viability.
AIM has been a part of international process safety regulations for many years, including the Seveso Directive and its implementations in Europe (Reference 1-1) as well as Offshore Installation (Safety Case) regulations (Reference 1-2). Since 1992, a major incentive for process industries in the United States to implement AIM programs has been the Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard, 29 CFR 1910.119 (Reference 1-3). This was followed by the Environmental Protection Agency (EPA) risk management program (RMP) rule, 40 CFR 68 (Reference 1-4). These performance-based regulations each contain a mechanical integrity (MI) element that defines the minimum requirements of a program through six subelements that address:
Equipment to be maintainedWritten MI proceduresMI trainingInspection and testingEquipment deficienciesQuality assurance.Specific requirements are not prescriptively stated in these regulations, but the sub-elements represent time-proven practices for an effective AIM program. The details of each sub-element are left to the discretion of the facility to develop and implement. All PSM- and RMP-covered U.S. facilities in operation since the regulations were issued have been required to audit compliance with these requirements at least every three years. Many of these audits reveal that companies continue to have significant opportunities to improve their AIM programs.
This document was written primarily for process industry facilities. However, most of the content applies to other industries as well. Although this document was written in the United States, a conscious effort has been made to keep the book applicable to facilities worldwide.
1.2 WHAT IS ASSET INTEGRITY MANAGEMENT?
For the purposes of this book, asset integrity management (AIM) is a management system for ensuring the integrity of assets throughout the life cycle of the assets. In this context, an asset is a process or facility that is involved in the use, storage, manufacturing, handling or transport of chemicals, or the equipment comprising such a process or facility. Examples of assets include off-shore and on-shore extraction and processing equipment; process and auxiliary tanks, vessels and piping systems including their internal components; control systems; safety systems; buildings and other structures; and transport containers. The selection of which assets are “important” is discussed in Section 1.3 and in Chapter 5.
AIM is a product of many activities, usually performed by many people. When these activities are done well, AIM can provide the foundation for a safe, reliable facility that minimizes threats to the workforce, the public and the environment. Effective AIM is also consistent with good business practices.
AIM programs vary according to industry, regulatory requirements, geography and plant culture. However, some characteristics appear to be common to effective AIM programs. For example, they:
Include activities to ensure that assets are designed, procured, fabricated, installed, operated, inspected, tested and maintained in a manner appropriate for its intended application.Clearly designate assets to be included in the program based on defined criteria.Prioritize assets to help optimally allocate financial, staffing, storage space and other resources.Help plant staff perform planned maintenance and reduce the need for unplanned maintenance.Help plant staff recognize when equipment deficiencies occur and include controls to help ensure that equipment deficiencies do not lead to serious incidents.Incorporate applicable codes, standards and other recognized and generally accepted good engineering practice (RAGAGEP).Help ensure that personnel assigned to perform AIM activities are appropriately trained and have access to appropriate procedures for these activities.Develop standard work roles and consistent activities.Maintain service documentation and other records to enable consistent performance of AIM activities and to provide accurate asset information to other users, including other process safety and risk management elements.This document provides guidance for developing an AIM program that includes all of these characteristics.
To present sound guidance for developing and/or improving AIM programs, this document evaluated lessons learned by the process industries. It does not give just one way of managing the integrity of assets, since there are many ways to approach the implementation of an AIM program, and other resources will be needed to develop a full program. Where appropriate, this book gives strengths and weaknesses of different approaches. Company management will need to recognize which approaches best suit their facility and company needs.
Having a successful AIM program is consistent with the business case for process safety. Benefits of AIM programs that can provide greater value for the business include:
Improved equipment reliability and availabilityReduced frequency of asset failures that lead to safety and environmental incidentsImproved product consistencyImproved maintenance consistency and efficiencyReduced unplanned maintenance time and costsReduced operating costsImproved spare parts managementImproved contractor performanceCompliance with regulatory requirements.Each of these objectives may have associated costs, such as more detailed procedures, a larger warehouse or improved computer systems, so that companies may need to prioritize their objectives.
One AIM program development approach that is not advocated in this book is to focus only on compliance with regulations. Compliance is one outcome of an AIM program; however, the primary focus of such a program needs to be on the management of risk, in order to deliver the benefits that an AIM program can provide. The requirements for compliance are often vague and subject to misinterpretation. Furthermore, requirements are subject to change via legislated modifications or new interpretations of existing legislation. In addition, a compliance-only program may miss out on many of the benefits of a more holistic approach, such as improved profitability and reduced risks for employees, the facility and the neighboring community. A more holistic approach can help to:
Present the AIM program as a company priority, rather than just something the company is forced to do; this approach also helps to ensure compliance, since personnel are less likely to take shortcuts.Create synergies with equipment and process reliability initiatives that could improve results and/or lower costs.Address risks to employees, community and the business.Therefore, the more holistic approach helps ensure compliance with governing regulations and is often the greater business value than the minimum compliance effort. Although compliance with federal, state and local regulations is often a motivating factor for a facility, following the guidelines in this document can help a facility develop, implement and/or improve an AIM program that:
is effective in containing and controlling hazardous materials and energies,enables the facility to operate reliably andis in compliance with regulatory requirements.1.3 WHAT ASSETS ARE INCLUDED?
One of the key questions when embarking on an AIM program is to identify the facility assets to include in the AIM program. This question is introduced here and further examined in Chapter 5.
As can be seen in the next section on AIM life cycle, an AIM program consists of two major parts:
Properly designing and installing the facility’s assets before startupMaintaining the ongoing integrity of the assets over a lifetime of facility operation.The question of what assets to include in an AIM program is likely to be different for these two major tasks. For the first part, it would be generally considered as necessary to correctly design and properly install all facility assets before startup. However, it is recognized that greater care or rigor is likely to be taken in the design and installation of some assets that are considered as critical to safe or reliable operation of the facility. For example:
A building that is within an identified potential vapor cloud explosion blast zone (Reference 1-5) and is intended to be blast resistant will require more rigor in its specification, design and construction than a general-purpose maintenance warehouse outside of the blast zone.A piping system for transferring a liquefied flammable gas that has the potential for cold embrittlement of common piping materials will require more rigor in its specification, design and installation than standard cooling water piping.Nevertheless, even the maintenance warehouse and cooling water piping will perform important functions, so their proper design and construction is still warranted.
From a programmatic point of view, the more difficult question pertains to the second major AIM task; namely, maintaining the ongoing integrity and reliability of site processes, including production, utility and support system assets, over a lifetime of facility operation. The question for this task can be rephrased as “What facility assets do we need to maintain, and to what degree of rigor?” A closely related question is “With limited resources, and sometimes needing to deal with unforeseen circumstances, we may not be able to always keep up with every scheduled maintenance task. How do we manage this situation?” These questions have been answered, implicitly or explicitly, in many ways:
Breakdown Maintenance. By this approach, no or minimal inspections, testing and maintenance are performed on facility assets. Repairs are made to equipment only when failure of the equipment is evidenced by a release of material or energy or a failure of the equipment to allow process operations to continue. Although breakdown maintenance requires the least effort in planning, performing, and documenting ITPM activities, it has numerous drawbacks from the perspectives of safety, reliability, maintenance planning and compliance.
Compliance Maintenance. This approach performs only those Inspection, Testing, and Preventive Maintenance (ITPM) tasks required by applicable codes and regulations (and perhaps specific company requirements), at minimal frequencies, with all other maintenance being performed on a breakdown basis.
Risk-Based Maintenance. Analysis tools such as risk-based inspection (RBI) and reliability-centered maintenance (RCM) are used to prioritize maintenance activities and establish ITPM frequencies in such a way as to meet risk-based safety and/or reliability goals. While more planning effort is required than breakdown or compliance maintenance, both on initial and ongoing bases, risk-based approaches can incorporate operating history into the planning process and, in some cases, adjust ITPM plans where data are available to support these adjustments and thereby optimize use of resources. However, risk-based tools are more often used to supplement other approaches rather than to be the primary means of determining what assets are to be maintained.
Prioritized Maintenance. Taking into account the realities of resource limitations and unplanned repairs, this approach identifies some assets as safety-critical equipment (SCE) or critical equipment and performs no-excuse, no-exception planned maintenance on all such equipment, while conducting necessary ITPMs on all other assets as appropriate but with allowances for task or schedule slippage. The concept of SCE and the selection of assets to receive prioritized maintenance are fully discussed in Chapter 5.
Comprehensive Maintenance of All Assets. This approach seeks to maintain every facility asset according to its pertinent manufacturer’s or supplier’s recommended tasks and frequencies, as well as by all applicable RAGAGEP and regulatory requirements. While comprehensive maintenance is ideal, it is not often successfully implemented in practice. Some supplier-recommended tasks and frequencies tend to be conservative or even excessive, and company resources rarely are sufficient to plan and perform all specified tasks at the required frequencies, especially when unforeseen circumstances arise.
Some combination of these approaches is often employed. For example, a facility using a risk-based approach is not likely to totally ignore compliance requirements, even when meeting those requirements is not indicated as being necessary to meet risk-based goals. Another facility might perform comprehensive maintenance on some assets and relegate all others to breakdown maintenance.
1.4 AIM LIFE CYCLE
Integrity needs to be built into a facility’s assets and planned operation before the facility is started up. This asset integrity is then maintained over time by proper facility operation; by ITPM activities; by managing tasks; and by learning from experience. When failures do occur or deficiencies are detected, integrity is re-established by proper repairs or replacements.
Thus, managing asset integrity begins well before a new process/facility is started up and extends throughout the facility lifetime until final decommissioning. It recognizes that the functional integrity of equipment can degrade over time by corrosion, erosion, fatigue and various other mechanisms (i.e., “aging plants”; see Reference 1-6), so these mechanisms need to be understood, detected, and corrected before containment, control, or the ability to respond to an abnormal or emergency situation is lost. The primary AIM life cycle activities can be summarized as shown in Figure 1-1. These life cycle activities are detailed in Chapter 3.
1.5 RELATIONSHIP TO OTHER PROGRAMS
A practical AIM program will fit within a facility’s existing process safety and risk management program, as well as other initiatives such as for reliability and quality improvement. Personnel charged with developing and administering the AIM program can optimize the process by taking advantage of existing programs and by knowing which people and groups of people are responsible for related activities. Table 1-1 illustrates potential interfaces with other facility programs.
AIM starts with a well-designed facility, with clear expectations with respect to expected facility performance. CCPS provides input to design practices and considerations from a process safety perspective in Guidelines for Engineering Design for Process Safety, Second Edition (Reference 1-7). Other activities essential to managing asset integrity include the proper procurement, fabrication, construction, and installation of assets, as discussed in Chapter 3.
Figure 1-1. Summary of AIM activities throughout a facility life cycle
AIM is also an integral part of an ongoing, risk-based process safety management program. It is part of the “Managing Risks” pillar of CCPS’ risk-based process safety model (Reference 1-8). Significant relationships with other process safety elements are shown in Table 1-2. As can be seen from this table, nearly all parts of a risk-based process safety program have some bearing on managing asset integrity.
1.6 RELATIONSHIP TO RAGAGEP
Codes, standards, and practices, which are sometimes termed “recognized and generally accepted good engineering practice” (RAGAGEP), are an important resource for an AIM program. RAGAGEP stems from the selection and application of appropriate engineering, operating, and maintenance knowledge when designing, operating, and maintaining process facilities with the purpose of ensuring safety and preventing process safety incidents.
RAGAGEP involves the application of engineering, operating or maintenance activities derived from engineering knowledge and industry experience based upon the evaluation and analyses of appropriate internal and external standards, applicable codes, technical reports, guidance, or recommended practices or documents of a similar nature. RAGAGEP can be derived from singular or multiple sources and will vary based upon individual facility processes, materials, service, and other engineering considerations.
TABLE 1-1.Example AIM Interfaces with Other Facility Programs
TABLE 1-2.Relationships between AIM Activities and Risk-Based Process Safety Elements
RBPS PillarRBPS ElementAIM Activities Related to RBPS ElementCommit toProcess Safety CultureAll AIM activitiesProcess SafetyCompliance with StandardsUse standards and RAGAGEPProcess Safety CompetencyInvolve competent personnelEnsure required inspector and technician certificationsWorkforce InvolvementDevelop procedures for critical maintenance activitiesStakeholder OutreachUnderstand Hazards and RiskProcess Knowledge ManagementIdentify assets to be included in AIM program Develop ITPM planIncorporate new knowledgeHazard Identification and Risk AnalysisIdentify assets to be included in AIM program Develop ITPM planManage RiskOperating ProceduresDevelop procedures for critical maintenance activitiesSafe Work PracticesDevelop procedures for critical maintenance activitiesPlan and perform ITPMs and repairsASSET INTEGRITY AND RELIABILITYAll AIM activitiesContractor ManagementTrain employees and contractors Ensure required inspector and technician certificationsAudit contractor work on assetsTraining and Performance AssuranceTrain employees and contractorsManagement of ChangeUpdate ITPM plan when equipment conditions changeAdjust ITPM frequencies, test methods, training and procedures if warrantedKeep asset information up to dateOperational ReadinessConfirm assets as installed meet design specificationsConduct baseline tests and inspectionsConduct of OperationsPlan and perform ITPMs and repairs Promptly address conditions that can lead to failureReview inspection/test recordsEmergency ManagementPlan and perform ITPMs and repairsLearn fromIncident InvestigationInvestigate chronic failuresExperienceMeasurement & MetricsCollect, analyze and archive dataAuditingDevelop written AIM programManagement Review and Continuous ImprovementInvestigate chronic failuresThe term RAGAGEP comes from U.S. process safety regulations that require its documentation and usage:
“The employer (owner or operator) shall document that equipment complies with recognized and generally accepted good engineering practices” [OSHA 29 CFR 1910.119(d)(3)(ii) and EPA 40 CFR 68.48(b) and 68.65(d)(2)].“Inspection and testing procedures shall follow recognized and generally accepted good engineering practices” [OSHA 29 CFR 1910.119(j)(4)(ii) and EPA 40 CFR 68.56(d) and 68.73(d)(2)].RAGAGEP gives generally approved ways to perform a specific engineering, inspection or maintenance activity. It may address:
Equipment design and construction, such as specifying a piping system or fabricating a pressure vessel.In-service activities, such as inspecting a storage tank or servicing a relief valve.An established work process, such as risk-based inspection (RBI), reliability-centered maintenance (RCM) or specifying and implementing safety instrumented systems (SIS).RAGAGEP incorporates broad industry experience and technical input and represents the consensus of a relevant organization or technical community. Therefore, it provides a valuable starting point for an AIM program.
In some cases, a country, state, or locality may mandate the use of RAGAGEP. For example, an authority may adopt an NFPA code for its jurisdiction. In addition, many companies internalize standards, often based on RAGAGEP, which are provided by the manufacturer or licensor of a process. Some companies have developed their own internal standards based on company and industry operating experience.
Broad industry experience is not always available for new technologies or for unique or highly specialized processes. In situations where RAGAGEP does not exist, the design of physical facilities or work processes needs to use the best available technology that is relevant to the situation, then take extra care in the design process since the depth of experience may be lacking. This extra care may include additional hazard identification and risk analysis efforts to ensure adequate preventive and mitigative layers of protection are in place to deal with abnormal situations that may develop. Extra inspections, testing and detection methods may also be warranted, during both commissioning and facility operation, until actual operating experience is gained.
To effectively use RAGAGEP, facility management needs to determine which practices are available and then assess the applicability of each practice to its facility. Regardless of the consensus reached to publish RAGAGEP, most standards were not written for a facility’s specific equipment, specific chemical application, specific locale or specific operations culture. Some facilities with successful AIM programs are establishing their own data records to help determine (or to validate) the ongoing applicability and use of each standard.
Several chapters of this book address the applicability and use of RAGAGEP in more detail. Descriptions of these practices and approaches are included, such as for determining an inspection interval or technique, but the actual RAGAGEP is not repeated in this book. New and revised codes, standards and recommended practices continue to evolve; therefore, it is advisable for companies to have management systems in place to keep up with the new standards and with changes to existing standards. This is further discussed in Section 2.2.5.
1.7 STRUCTURE OF THIS DOCUMENT
These guidelines begin with four chapters that help set the groundwork for an AIM program. Chapter 2 discusses roles and responsibilities for management and other company personnel and examines the ongoing activities that management undertakes to help ensure AIM program success. Chapter 3 gives an overview of AIM activities from a life cycle perspective. Chapter 4 summarizes asset damage and degradation mechanisms to be understood, evaluated, detected and managed in an AIM program. Chapter 5 reviews considerations a facility may have when defining the equipment to include in its program and prioritizing safety-critical equipment.
Once a basic understanding is gained and the goals, objectives and scope of the AIM program is determined, facility management needs to develop and implement systematic activities related to AIM. These include:
Inspection, testing, and preventive maintenanceTraining of all affected personnelAIM procedures developmentQuality managementEquipment deficiency resolutionAuditing of the AIM program.Each of these activities is addressed in turn in Chapters 6 through 11 and Section 14.2. As illustrated in Table 1-3, Chapters 6 through 11 describe management systems for addressing assets as they are originally designed and installed, as they are maintained over time, and as they are repaired or replaced.
Specific details for these activities depend on facility culture, regulatory obligations and company priorities. Therefore, relatively little prescriptive information is included in this book. Rather, this document presents approaches that have worked in different industries and in facilities of various sizes.
Chapter 6 discusses inspection, testing and preventive maintenance (ITPM). In this document, “preventive maintenance” refers to those activities that are not inspections or tests and that are performed to prevent the failure of equipment within the AIM program. Lubrication of rotating equipment is one example of a PM task meeting this definition. Established approaches for developing test and inspection plans, such as risk-based inspection, are further detailed in Chapter 7.
Chapter 8 covers activities to ensure personnel competency, with the focus on AIM-related training. Chapter 9 addresses the procedures needed for AIM. Quality management activities involving initial design and fabrication as well as ongoing repairs and alterations are discussed in Chapter 10. Chapter 11 covers equipment deficiency recognition and resolution.
TABLE 1-3.Chapters Addressing Management Systems for AIM Activities
To a large extent, the implementation of AIM activities depends on the specific types of assets involved. Because many codes, standards and other guidelines are written for specific types of equipment, this document contains a section dedicated to the specific approaches applicable to different equipment categories. Chapter 12 is dedicated to the equipment-specific aspects for the management systems covered in Chapters 6 through 11. Activity tables in Chapter 12 and in the electronic resources accompanying this document are presented in a format similar to Table 1-3. Many available codes, standards and practices are listed in this section. Key aspects derived from them, such as time intervals between inspections, are also listed, but the reader is encouraged to consult the referenced documents for more detailed information.
Chapter 13 reviews issues commonly encountered while implementing an AIM program, including budgeting and resources. Frequently, these resources include a computerized maintenance management system (CMMS). Many commercial CMMS packages are available, although some in-house programs are also effective. Chapter 13 includes basic information typically included in any CMMS that is installed as part of an effective AIM program.
The remaining two chapters contain supplemental information related to AIM programs. Chapter 14 discusses performance metrics that apply to AIM program activities, then offers suggestions for continual assessment and improvement of an AIM program. Continuous improvement is needed to ensure that effective AIM programs continue to operate at a high level. Some improvement can be attained simply by asking the right questions (i.e., auditing) and following up to address any identified weaknesses. Performing improvement activities on a regular basis can be expected to result in continuous improvement.
This document closes by providing an overview of other asset management tools that can be used to help make decisions related to AIM activities. Because of the extensive resource requirements for most AIM programs, risk-based decision making can be effectively employed to prioritize resource allocation. Various texts have been written on applicable tools for making these decisions. Chapter 15 includes an overview of many of the tools and references available in these resources.
CHAPTER 1 REFERENCES
1-1 EU Directive 2012/18/EU of 4 July 2012 on the Control of Major-Accident Hazards Involving Dangerous Substances (“Seveso III”), European Parliament and EU Council, 2012.1-2 HM Government, The Offshore Installations (Safety Representatives and Safety Committees) Regulations 1989, Statutory Instruments, 1989 No. 971, Health and Safety, UK, 1989.1-3 Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119, U.S. Occupational Safety and Health Administration, Washington, DC, 1992.1-4 Accidental Release Prevention Requirements: Risk Management Programs, 49 CFR Part 68 U.S. Environmental Protection Agency, Washington, DC, 1996.1-5 Center for Chemical Process Safety, Guidelines for Evaluating Process Plant Buildings for External Explosions, Fires, and Toxic Releases, Second Edition, American Institute of Chemical Engineers, New York, NY, 2012.1-6 U.K. Health and Safety Executive, “Managing Ageing Plant: A Summary Guide,” Research Report RR823, HSE Books, www.hse.gov.uk, October 2010.1-7 Center for Chemical Process Safety, Guidelines for Engineering Design for Process Safety, Second Edition, American Institute of Chemical Engineers, New York, NY, 2012.1-8 Center for Chemical Process Safety, Guidelines for Risk Based Process Safety, American Institute of Chemical Engineers, New York, NY, 2007.2MANAGEMENT RESPONSIBILITY
Many people within a facility’s maintenance, operations and engineering organizations will likely be involved with the facility’s asset integrity management (AIM) program. An individual’s involvement may range from brief encounters to career-length stewardship responsibilities, and the involvement may occur during any or all phases of the assets’ life cycle. In successful AIM programs, supervisors and managers emphasize how each person contributes to preventing incidents and improving process reliability. Such an approach is evident when personnel are working within the facility’s risk management system and using effective knowledge, skills, resources and procedures associated with the AIM program.
This chapter discusses ways in which supervisors and managers can contribute to the ultimate success of the AIM program through communication and effective application of knowledge, skills and resources. For the purposes of this chapter, supervisors and managers include all personnel with supervisory and/or management responsibilities within engineering, maintenance, operations and related departments, as well as those charged with overall facility leadership.
2.1 LEADERSHIP ROLES AND RESPONSIBILITIES
One of the best ways that the leadership of a facility can help prevent incidents is to provide visible and active involvement in the facility’s hazard management system. Key responsibilities of managers and supervisors in the AIM program are:
Establishing the direction and scope of the AIM program at the corporate level, beginning with the cultivation of a corporate culture in which managing asset integrity is an essential operating task for the facility.Ensuring that knowledgeable people with the proper training and certifications are performing appropriate activities using effective engineering and decision-making tools and methods.Instilling the expectation that the business plan will be fulfilled only within the safe operating limits of the equipment as dictated by its condition.Ensuring that AIM program activities (e.g., inspections and tests) are being executed and managed on schedule and as planned, inspection/test results are being captured and analyzed, and corrective actions are being appropriately completed.Ensuring that appropriate controls are implemented and maintained within the facility’s hazard management system for all related AIM activities.Providing the necessary resources to accomplish all of the above, including the use of third parties where needed.The primary control mechanisms for these actions are:
Establishing clear organizational roles, responsibilities and accountabilities for AIM activities, including independence of the testing and inspection organizations, to ensure that site management is receiving current and accurate information on the status of the site AIM program.Creating reporting mechanisms for condition of assets, AIM program status, asset failures and integrity-related incidents.Ensuring that effective audits of the AIM program and the overall hazard management system are conducted, with the audit results being reviewed by corporate leadership, and with identified gaps being resolved in a deliberate and risk-informed manner while having appropriate interim risk-control measures in place.Each of these three control mechanisms is described further in the following sections. Similar responsibilities and control mechanisms apply to the leadership of contractor companies, such as those involved in engineering design, construction, inspections, and repairs, with the added necessity of effective interfaces and communications between the operating company and the contractor companies.
2.1.1 Organizational Roles and Responsibilities
AIM is best directed and controlled at the corporate level to ensure consistent implementation and to help establish a positive process safety culture, whereas execution is the operating facility’s responsibility. A good practice is to establish an AIM corporate center of excellence, tasked to establish corporate AIM standards and drive efforts to continuously improve the safety and reliability of facility assets.
Process Safety Culture. The first tenet of CCPS’ Vision 2020, demonstrating what perfect process safety will look like when it is championed by industry, is a committed culture in which the executives are personally involved, managers drive excellent execution every day, and all employees maintain a sense of vigilance and vulnerability. To create a committed culture, leadership needs to tangibly demonstrate a commitment to process safety from the senior executive team through its line management, so that all employees embrace it and recognize that “it could happen here.” Process safety culture is also the first CCPS element of risk-based process safety (Reference 2-1).
Facility Responsibility. The operating facility’s responsibility is to ensure that AIM activities are an integral part of the day-to-day operations involving operators, maintenance personnel, inspectors, contractors, engineers, and others involved in designing, specifying, installing, operating and maintaining facility assets. Due to limited resources or other considerations, it may be necessary or even desirable to have multi-skilled maintenance personnel and/or have properly trained operators perform some routine inspections, tests and preventive maintenance tasks such as visual inspections and pump lubrication.
Knowledgeable Personnel. An essential role for a facility’s management is to ensure that knowledgeable people are available and assigned to provide the expertise for implementing the AIM program. For example, technical personnel at the facility or available to the facility can direct personnel from various departments to the correct codes, standards and practices for a given application throughout the life cycle of the facility’s assets. The life cycle includes process equipment design/engineering, fabrication, procurement, receipt, storage and retrieval, construction and installation, commissioning, operation, inspection, condition monitoring (CM), functional testing, maintenance, repair, modification and alteration, decommissioning, removal and re-use.
Outsourced AIM Activities. Some of the technical aspects of the AIM program can be outsourced if a facility has limited internal expertise. However, it is important that site management maintains ownership of the AIM program. Ownership means that it is the responsibility of facility management to ensure the AIM program is properly designed and maintained. This can be done with proper auditing and management review.
Response to Recommendations. Management personnel have the responsibility to demonstrate further commitment to the AIM program by supporting the recommendations made by technical personnel and by inspectors and auditors. Facility leadership can provide the guidance and direction to ensure that the technical and inspection roles are accepted by everyone within the facility. For example, as custodians of the equipment’s condition-based safe operating limits, the technical staff will likely have significant input into decisions regarding whether equipment with known deficiencies will continue to be operated. The technical staff and the inspectors provide the input that enables facility management to manage the facility assets while maintaining safe operations.
Audits and Self-Assessments. Management review of the AIM program is essential to ensure that the program is working properly and producing the desired results. If it is not, management has the responsibility to identify deficiencies, develop corrective actions and ensure that the actions are implemented in a timely manner. Management can combine metrics, incident reports, personal observations, direct questioning, audits results and feedback on various topics to make their assessment.
Independence of the Inspection Function. Persons charged with performing inspections and tests on safety-critical equipment are often part of a more or less formalized inspection authority and/or inspection department. It is good practice to provide some independence to the inspection function such that it is not fully embedded in the maintenance department. For example, the leader of the inspection group may report directly to the facility manager and may be given authority to shut down a unit if an incipient catastrophic failure is detected or a safety-critical system fails inspection.
Importance of the Planning Function. An important but often overlooked role is the maintenance planner. Most large facilities could not function efficiently without this role. Computerized maintenance management systems can facilitate the planning function; however, human judgment is still needed to deal with abnormal situations and resource conflicts.
2.1.2 Roles and Responsibilities Matrix
The roles and responsibilities for program management and implementation can be assigned to personnel in various departments. A comprehensive program document effectively communicates to facility personnel the management systems and roles associated with the AIM program. Many facilities find it a practical necessity to create and maintain a more detailed written AIM procedure in order to sustain all AIM activities. The written program can document roles and responsibilities for various levels of involvement for different aspects of the AIM program. Some people will be directly responsible and accountable for an activity, others may participate in the development or implementation of the activity, and others may need only to be aware of the activity or its results.
A convenient method for displaying these varying roles and responsibilities is in a matrix format. Such a matrix correlates different activities with different job positions by indicating the job position(s) responsible for each activity, as well as the level of participation required of other personnel.
An example matrix showing roles and responsibilities for managing an asset integrity (AI) program is provided in Table 2-1. This matrix lists program activities in the left column and typical job positions by department in the top row. Cells containing letter designators indicate the job position(s) responsible for the activity and the levels of participation for other job positions. This matrix uses the following letter designators:
R indicates the job position(s) with primary responsibility for the activityA indicates the job position(s) to approve the work or decisions involvedS indicates the job positions that typically support the responsible person(s) and may participate in the performance of the activityI indicates the job positions that are likely to be informed of the activity results, may be asked to provide information, or may have minor participation in the activity.This matrix format will be used to present more specific roles and responsibilities in subsequent chapters of this document. Note that a RASI chart or matrix of this nature can on occasion be expanded to a RASCI chart, with the C standing for consulted.
2.1.3 Reporting and Communication Mechanisms
Reporting mechanisms are necessary to provide appropriate and timely information concerning past performance as well as to alert personnel at various levels within and external to the company that AIM activities are necessary to ensure continued asset integrity.
External Communications. Communication of AIM-related information to external stakeholders including regulatory authorities can take the form of public progress reports or posted trend information, or be part of a larger document such as a company annual report. Reference 2-2 is an example of an annual public report of safety performance for one industry that includes three AIM-related key performance indicators (KPIs): major releases, findings of noncompliance for verified safety-critical parts, and safety-critical maintenance backlog.
