Ei performed a forensic analysis of the site’s AutoCAD database, along with efficient MOC documentation (hard copy) and field spot checks, to support a facility improve their best-in-class Management of Change (MOC) program through performing targeted, data-based MOC validation (QA/QC) checks.
How (Overview of Project)
This site utilized AutoCAD P&ID format drawings, which differs from “flat” AutoCAD in that all of the equipment, instrumentation, process lines, and objects in each drawing are exportable to spreadsheet via AutoCAD’s “Data Manager”.
Additionally, this site has implemented Ei’s Intelligence™ plugin for AutoCAD P&ID, which allows for process stream data to be incorporated into each P&ID data stream, and automates regulatory applicability interpretation for each object using this stream and chemical data.
Step 1: P&ID Data Review
Using an export of the site’s AutoCAD “data manager”, along with applicable information generated from Ei’s Intelligence™ AutoCAD plugin, the Ei Project Manager was able to generate a report of applicable equipment changes. For the scope of this project, the site was interested in impacts to the following classes of equipment: Hand-Actuated Valves, Control and Motor-Operated Valves, Relief Valves, and Instrumentation Systems.
Step 2: MOC Documentation Gap-Analysis
The site’s MOC documentation (MOC packages) for the review period were reviewed against the P&ID data change reports generated in step 1. This site was including redlines (either in CAD or in hand-written format) with their MOC packages. Any changes flagged in the P&ID data which were not identified in an MOC package were flagged for follow-up via electronic P&ID redline.
Step 3: Field Verification
Leveraging the reports and applicability information generated from the Ei Intelligence™ plugin, a one-week site visit was coordinated by an Ei engineer who performed field-verification of the items flagged by the data reports in each of the 8 units at the plant to each of the added items were incorporated in the site’s inspection database. The electronically redlined P&IDs generated in Step 2 were loaded into an intrinsically safe Surface Pro 4 tablet, allowing the field engineer access to the site’s equipment databases, along with electronic searchable P&IDs.
Ei's P&ID-data review identified hundreds of asset change (included newly added and removed equipment) stemming from recent MOC and turnaround activities. Many of these CAD additions were identified as being added through the Pre-Startup Safety Review (PSSR) field walk which included updating redlines to the plant's As-Built P&IDs. Using the thorough P&ID-data review as a starting point, a handful of changes were identified through the MOC-document review which field-verification was required.
This approach offered many benefits compared to other methodologies of MOC or asset-inventory QA/QC reviews:
- A More Thorough Review - Leveraging the site's robust PSSR process (and workflow to update their as-built P&IDs with changes), we were able to identify all asset-changes with a high level of confidence, offering a single source of truth for the subsequent asset databases which were reviewed.
- Increased Field Efficiency - Searchable P&IDs with pre-screened equipment additions were easily field-verified, resulting in an extremely efficient onsite field-review process.
- Lessons Learned for Continuous Improvement - Any gaps identified were communicated to relevant plant personnel, which were used as data points to engage in a Root Cause Analysis process which served to further improve the site's MOC process moving forward.
Inventory and compliance issues can arise with a term common in process engineering: non-steady state operations. During any MOC-related change as the plant, an industry-leading best practice is to undertake MOC process validation: ensuring the plant’s workflow and notification system for change management is robust.
Through focusing on a single “source of truth” at a plant - the P&IDs - and leveraging data related to P&ID changes associated with the P&IDs, facilities are beginning to operate more reliability and cost-effectively.