Forgery and Errors in Critical Material Supply and Installation
The supply chain for alloy materials is complex and appropriate safeguards and inspections must be performed from the source of raw material through the entire fabrication, shipping, warehousing and installation process. Intentional forgery of documentation and materials has occurred in the refining and petrochemical industry and can impact other industries relying on alloy materials.
A number of years ago, I presented a paper called “The Top 10 Myths of Reliability Management.” The number 1 myth was “You can trust your contractor.” Trusting a contractor is like handling a firearm. You may think its unloaded, but you better take the right steps to make sure. As Ronald Reagan said “trust but verify.” At the end of the day, it’s the operating company that is responsible to assure the right materials of construction are used in the process. This cannot be delegated. The operating company is responsible.
Myth 2 was “Don’t worry about Myth 1, you can sue the contractor.” This is like closing the barn door after the horses are on the loose. In our industry, this would be after there is an accident, injury, fire or significant loss of production. Legal action is extraordinarily expensive, consumes company resources and can take years to resolve with an uncertain outcome. It is much better to have systems and processes in place to prevent these incidents.
CASE HISTORY 1
Operating companies must be sure their suppliers are diligent in assuring materials of construction meet all industry requirements and that documentation is authentic. A number of years ago, through our plant inspection and positive material identification (PMI) processes, we determined documentation and stamping of Chinese supplied bolts were incorrect. ASTM A-193 Grade B7 fasteners were stamped ASTM A-193 Grade B16. Documentation was also forged. Using the B7 bolts in a high temperature B16 service could have resulted in a flange leak or joint failure. Fortunately, this issue was discovered and traced to an unauthorized change to a foreign supplier in violation of company sourcing standards. Extensive evaluation of when the change was made and where the bogus fasteners were in service or in the warehouse was completed. Significant restrictions were placed on the purchasing process including additional on-site inspection, PMI and visits to foreign source manufacturers.
CASE HISTORY 2
Another similar issue occurred with the discovery of weld neck flanges supposedly meeting ASME B16.5 specifications. Upon close inspection, the flanges, again from a Chinese vendor, were actually slip on flanges with pipe welded on to the slip on flange and machined to look like a B16.5 forged flange. A corporate Technical Directive was issued to the plants to inspect all recent projects and the warehouse for these fake flanges. A few were actually discovered in a project under construction and replaced before commissioning. Issues have also been discovered with laminations and other defects of alloy plate used for vessel fabrication. Fortunately, the inspection and PMI processes have discovered these issues.
CASE HISTORY 3
It is important the organization has strict engineering standards, pipe specifications, field positive material identification and installation practices. An incident occurred in a TDI plant on a pump handling a product with deadly phosgene. A plug blew out of the pump on startup after maintenance resulting in a phosgene release. The plug that was blown out was highly corroded and determined to be carbon steel. The other plugs and materials of construction were Monel. It was determined poor specifications, training and installation procedures contributed to the release.
These case histories demonstrate the vigilance needed in procurement, fabrication, inspection and installation to assure materials of construction in our plants meet specifications. Approved vendors lists can help mitigate the risk, but they don’t completely eliminate it. Approved vendors and their suppliers may be subject to fraud and forgery. Some operators have banned materials from certain countries of origin as another method to reduce the risk from fraudulent materials. Field PMI of installed alloy materials and field visual inspection of carbon steel materials vs. piping specifications is the last line of defense.
Becht can support all aspects of your piping and pressure vessel programs. This includes piping specification development, supplier audits, engineering requirements, fitness for service evaluations and repair requirements. Becht has held more than 125 positions in Codes and Standards organizations including serving as the Chair for the ASME B31.3 Process Piping Committee for a number of years. The majority of Becht personnel came from operating companies allowing us to view problems from an Owner’s perspective. Please contact us if you need assistance in this area or other areas of plant reliability management.