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Replacement in kind

  • 1.  Replacement in kind

    SENIOR MEMBER
    Posted 26 days ago

    Hello all,

     

    CCPS defines Replacement-in-kind as:

    An item (equipment, chemical, procedure, etc.) that meets the design specification of the item it is replacing. This can be an identical replacement or any other alternative specifically provided for in the design specification, as long as the alternative does not in any way adversely affect the use of the item or associated items.

     

    A batch facility had a 1500 gallon glass lined reactor (Pfaudler) that was in service for many years and needed to be replaced.  A written design specification was not available for the old reactor but it did have a U-1 form.  The replacement was a 1500 gallon glass lined reactor (DeDietrich) with its own U-1 Form.  The MAWP for the two vessels were identical.  Functionally they were equivalent for our purposes but there were slight differences.  In most instances the replacement vessel was better.  Differences include wall thickness on the replacement vessel was slightly thicker, there were fewer nozzles on the replacement vessel, and the replacement vessel was older.

     

    I didn't considered this to be replacement-in-kind but I would love to be told I'm wrong.  What is your opinion?

     

     

     

    "For a long time, people were saying that most accidents were due to human error and

    this is true in a sense but it's not very helpful. It's a bit like saying that falls are due to gravity." 

    "What you don't have, can't leak..."

    "Try to change situations, not people..."

                                                                               Dr. Trevor Kletz

     

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  • 2.  RE: Replacement in kind

    Posted 25 days ago

    my 2c
    I would not give (or seek) a simple broad-brush answer. Clearly, it is critically important to manage any potential impacts of the swap.
    Reactor replacement being >> complex than say, replacing a single ball valve (or centrifugal pump),

    To arrive at an answer, I would use a management of change process (hereafter MOC) to evaluate and document the changes where they exist. The MOC should include all potential impacts, such as operability, process, maintenance, location, accessibility, critical operating parameters and certainly documentation (drawings, procedures, and anything else I'm missing).
    The purpose would be to capture, evaluate and mitigate all differences and potential impacts.

    Do not overlook system modifications such as: location or number of temperature probes, agitation, instruments, valves (location or type). Where there are few differences and few changes, the MOC process documents those facts. If there are differences, the MOC documents those, and follow-up actions are assigned.


    Sim Hogan 

    Principal Engineer I

    Learn as if you were going to live forever;  live as if you were going to die tomorrow.


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  • 3.  RE: Replacement in kind

    LIFE MEMBER
    Posted 25 days ago
    I think you could make a legal argument that the new vessel met the design intent of the older reactor and was, therefore, a replacement in kind.  But like Sim, I much prefer to treat it as a change, because sometimes the supposed improvements have unexpected or unintended consequences.  For example, the thicker wall implies greater weight.  Is the support structure strong enough to handle the new, heavier vessel?  You said the new vessel has fewer nozzles.  That sounds like a good thing to have fewer leak points.  But were the old nozzles ever used for anything?  Perhaps those old nozzles were not used normally, but they were essential for maintenance access or other non-routine activities.  The new vessel was presumably built to modern code.  Is it only going to be hydrotested to 1.3 x MAWP vs. the older vessel 1.5 x MAWP?  Does that have any implications on relief valve sizing for the system or your risk assessment of overpressure scenarios?  I could go on.  But I feel much better that your MOC team had a look at it and concluded "no hazards of the change" vs. just calling it RIK.

    One anecdotal story.  Company in a similar situation replaced a stirred reactor vessel, but the two bottom nozzles were asymmetric, instead of symmetric as they were on the original reactor.  Reactant feed line branched, so 50% was fed into each nozzle.  This had worked perfectly for decades.  However, as a result of the asymmetric nozzle positions on the new reactor, the reactor agitator induced circulation from the outer nozzle, through the feed piping, back to the inner nozzle whenever reactant was not being charged. (One check valve on the discharge of the feed pump, but no check valves in the piping at the feed nozzles.)  Thus when feed resumed, the entire reaction occurred at the tee where the feed piping branched, not at the two nozzles into the reactor.  Without the themal mass and agitation in the reactor vessel, the reaction ran away and there was a major incident.  This is only one of a dozen examples in my personal experience where presumed RIK situations actually resulted in incidents.  So I tend to be agnostic when folks want to claim RIK per the regulatory definition, but it's not realllly a like-for-like replacement.

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    Donald Lorenzo PE
    Director, Training Solutions
    ABS Group
    Knoxville TN
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  • 4.  RE: Replacement in kind

    SENIOR MEMBER
    Posted 19 days ago
    Thank you for your responses.  You confirmed my thoughts.

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    James Graham
    Director, Environmental Affairs & PSM/Compliance
    GEO Specialty Chemicals, Inc.
    Ambler PA
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  • 5.  RE: Replacement in kind

    LIFE MEMBER
    Posted 19 days ago

    Hello James,

    You are not wrong.

    Guideline for replacement-in-kind should use it with caution. Though the two reactors are glass lined and of the same capacity, they are of different design details and their materials of construction are not mentioned. I believe the details are all included in the respective U-1 Form. Thicker vessel wall thickness not necessarily of superior design as it has to consider the thermal expansion and heat transfer coefficient should jacketed heating medium be used. Fewer nozzles on replacement vessel again have to consider if there is missing key connection such as for draining or venting, and to associated processes up-stream or down-stream. Replacement vessel of older age, or reused of reconditioned vessel has to thoroughly examine its metallurgy prior to using it. The entire consideration is part of management of change process.    



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    NG H Kiang Lucas PE, CEngSpore
    General Manager
    Petrochemical Corporation of Singapore
    Singapore
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  • 6.  RE: Replacement in kind

    SENIOR MEMBER
    Posted 19 days ago
    In CCPS parlance, is there a difference between "replacement-in-kind" and "like-for-like replacement"? The definition cited by James Graham does not meet the standard of equivalence implied by like-for-like replacement, at least not in my specialism of functional safety. There is a lot more to equivalence than just meeting a specification, especially when embedded software is involved - for example, in smart transmitters.

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    Peter Clarke CFSE
    Managing Director
    xSeriCon
    Hong Kong
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