Appendix G

Hydrodec of North America, LLC

Mechanical Integrity Program

1.0 Scope

Hydrodec’s Mechanical Integrity Program (MIP) is intended to ensure equipment does not fail in a
way that causes a release of highly hazardous chemicals. Hydrodec’s MIP covers the proper design,
fabrication, construction / installation, and operation of equipment throughout the entire process
life cycle. Although maintenance is a major part of an MIP, MIP is not just maintenance. Other
activities are involved such as training and quality assurance. The Hydrodec MIP covers these areas:

 Management system
 Identification and categorization of covered equipment
 Applicable codes and standards
 Inspection and testing
 Correction of deficiencies in equipment

The scope of Hydrodec of North America’s Mechanical Integrity Program covers selected process
equipment, process piping, rotating equipment, and instrumentation and is intended to prevent the
release of highly hazardous chemicals.

2.0 Computerized Maintenance Management System (CMMS)

The Hydrodec of North America Canton Plant uses a computerized maintenance management
system (CMMS) (TabWare PM Module) to help administer the maintenance function. Specifically,
the CMMS system is used to:
 Initiate and track preventive maintenance work orders
 Initiate and track corrective maintenance work orders
 Maintain or reference job plans
 Track equipment repair history
 Track work order backlog

3.0 Vessels

3.1 List of Equipment

3.1.1 A complete list of covered equipment is shown in Appendix A. Note that the
bulk hydrogen tank is owned by the supplier (Praxair) and the supplier is
responsible for inspection and maintenance activities associated with this tank.
Hydrodec personnel visually monitor this tank and associated hardware and
notifies Praxair in the event of any unusual observations.
3.2 Selection Criteria
3.2.1 Vessels were selected for inspection based on a combination of the following
criteria: Service, pressure, temperature, material of construction, historical
experience, risk factor (probability and consequence of failure) and location in
the process.

3.3 Description of Inspection

3.3.1 Vessels will receive both a Visual Inspection and an Ultrasonic Thickness Test.
3.3.1.1 Visual Inspection

A visual inspection is applicable to all pressure vessels and tanks

covered under the mechanical integrity program. A direct visual
inspection shall be conducted where access is sufficient to place the eye
within 24 inches of the surface to be examined and at an angle not less
than 30 degrees to the surface to be examined. In the event a direct
visual inspection is not achievable, a remote visual inspection shall be
conducted of the required surfaces. This method of visual inspection
may use visual aids such as mirrors, telescopes, borescopes, fiber optics
cameras or other suitable instruments. Such systems shall have a
resolution capability at least equivalent to that obtainable by direct
visual inspection

3.3.1.2 Ultrasonic Thickness Testing

Ultrasonic Thickness Testing is applicable to pressure vessels and tanks

that are manufactured from any material provided the sound velocity
and a suitable calibration block are available.

A sufficient number of measurements on each pressure vessel or tank

shall be made to ensure that areas having possible wall thickness
degradation problems are found. If wall degradation is suspected on a
pressure vessel or tank, a detailed mapping of the suspected area(s)
shall be performed.

The acceptance criteria for a particular pressure vessel or tank are

determined by evaluating the measured thicknesses against the original
design thickness of the vessel. Calculations may be necessary to
disposition results. It is not the responsibility of the inspector to
determine the acceptance criteria for ultrasonic thickness tests. Final
assessment on equipment acceptance will be made by Hydrodec
Engineering management.

3.4 Inspectors and Qualifications

 Personnel performing inspections in accordance with this procedure shall be qualified
and certified in accordance with American Society for Nondestructive Testing (ASNT) SNT-1A
standards. (No. SNT-TC-1A)

 An NDT Level I individual should be qualified to properly perform specific calibrations,

specific NDT and specific evaluations for acceptance or rejection determinations
according to written instructions and to record results. The NDT Level I should receive
the necessary instruction and supervision from a certified NDT Level II or III individual.
 An NDT Level II individual should be qualified to set up and calibrate equipment and to
interpret and evaluate results with respect to applicable codes, standards and
specifications. The NDT Level II should be thoroughly familiar with the scope and
limitations of the methods for which he is qualified and should exercise assigned
responsibility for on-the-job training and guidance of trainees and NDT Level I
personnel. The NDT Level II should be able to organize and report the results of NDT
tests.
 An NDT Level III individual should be capable of developing, qualifying and approving
procedures, establishing and approving techniques, interpreting codes, standards,
specifications and procedures, as well as designating the particular NDT methods,
techniques and procedures to be used. The NDT Level III should be responsible for the
NDT operations for which he is qualified and assigned and should be capable of
interpreting and evaluating results in terms of existing codes, standards and
specifications. The NDT Level III should have sufficient practical background in applicable
materials, fabrication and product technology to establish techniques and to assist in
establishing acceptance criteria when none are otherwise available. The NDT Level III
should have general familiarity with other appropriate NDT methods, as demonstrated
by an ASNT Level III Basic examination or other means. The NDT Level III, in the methods
in which he is certified, should be capable of training and examining NDT Level I and II
personnel for certification in those methods.

Inspections can be carried out by Level I technicians and above, however, reports and
evaluations must be conducted only by Level II and Level III inspectors

3.5 Timelines and Schedules

3.5.1 Base-line ultrasonic thickness inspections were conducted and recorded in 2015
prior to plant commissioning. Ultrasonic vessel inspections will initially be
scheduled every three years. If no changes in thickness or surface quality
manifest themselves in two consecutive inspections, the inspection interval may
be changed to 5 years. A change in inspection interval will require an MOC
(Management of Change).
3.5.2 A monthly visual inspection of the covered vessels will be conducted by one of
the following individuals: Senior Process Engineer, Operations Supervisor, or the
 Plant Manager. A checklist will be used to record the inspection and any
deficiencies recorded and addressed in the CMMS.

4.0 Piping Systems

4.1 List of Piping Systems

4.1.1 A complete list of covered Piping is shown in Appendix B

4.2 Selection Criteria

4.2.1 Piping Systems were selected for inspection based on a combination of the
following criteria: Service, pressure, temperature, material of construction,
historical experience, risk factor (probability and consequence of failure) and
location in the process.

4.3 Inspection Description

4.3.1 Piping Systems will receive both a Visual Inspection and an Ultrasonic Thickness
Testing.
4.3.1.1 Visual Inspection

A visual inspection is applicable to all piping systems selected under the

mechanical integrity program. A direct visual inspection shall be
conducted where access is sufficient to place the eye within 24 inches of
the surface to be examined and at an angle not less than 30 degrees to
the surface to be examined. In the event a direct visual inspection is not
achievable, a remote visual inspection shall be conducted of the
required surfaces. This method of visual inspection may use visual aids
such as mirrors, telescopes, borescopes, fiber optics cameras or other
suitable instruments. Such equipment shall have a resolution capability
at least equivalent to that obtainable by direct visual inspection.

4.3.1.2 Ultrasonic Thickness Testing

Ultrasonic thickness testing is applicable to piping systems that are

manufactured from a metallic and non-metallic material provided the
sound velocity and a suitable calibration block are available. Thickness
measurement locations must be identified at points on a component or
along a piping system where the inspections are made. Details of
complete insulation removal or insulation plug removal for ultrasonic
thickness testing inspection on pipes and components so equipped shall
be specified on the PM work order. If wall thinning is suspected, a
detailed thickness mapping of the suspected area(s) shall be performed.
 The acceptance criteria for a particular piping system are determined by
evaluating the measured thicknesses against the original design
thickness of the piping system or component. Calculations may be
necessary to disposition results. It is not the responsibility of the
inspector to determine the acceptance criteria for ultrasonic thickness
testing. Final determination of the acceptance of a piping system will be
performed by the Senior Process Engineer or the Plant Manager.

4.4 Inspectors and Qualifications

Personnel performing inspections in accordance with this procedure shall be qualified

and certified in accordance with American Society for Nondestructive Testing (ASNT) SNT-1A
standards. (No. SNT-TC-1A)

Inspections can be carried out by Level I technicians and above, however, reports and
evaluations must be conducted only by Level II and Level III inspectors

4.5 Timelines and Schedules

4.5.1 Base-line ultrasonic thickness inspections were conducted and recorded in 2015
prior to plant commissioning. Ultrasonic thickness inspections will initially be
scheduled every two years. If no changes in thickness or surface quality
manifest themselves in two consecutive inspections, the interval may be
changed to three years. A change in inspection interval will require an MOC.
4.5.2 A monthly visual inspection of the covered piping systems will be conducted by
one of the following individuals: Senior Process Engineer, Operations
Supervisor, or the Plant Manager. A checklist will be used to record the
inspection and any deficiencies recorded and addressed in the CMMS.

5.0 Rotating Equipment

5.1 List of Rotating Equipment

5.1.1 A complete list of covered rotating equipment is shown in Appendix C

5.2 Selection Criteria

5.2.1 The specified Rotating Equipment were selected for inspection based on a
combination of the following criteria: Service, pressure, temperature, material
of construction, historical experience, risk factor (probability and consequence
of failure) and location in the process.

5.3 Inspection Description

 5.3.1 Inspections for Rotating Equipment will be performed using the manufacturer’s
recommendations for inspections and preventative maintenance.

5.4 Timelines and Schedules

5.4.1 Inspections and preventative maintenance will be performed in accordance with
the Manufacturer’s recommendations.
5.4.2 A monthly visual inspection of the covered rotating equipment will be
conducted by one of the following individuals: Senior Process Engineer,
Operations Supervisor, or the Plant Manager. A checklist will be used to record
the inspection and any deficiencies recorded and addressed in the CMMS.

6.0 Instrumentation

6.1 List of Instrumentation

6.1.1 A complete list of instrumentation is shown in Appendix D

6.2 Selection Criteria

6.2.1 The specified Instrumentation were selected for inspection based on a
combination of the following criteria: Service, pressure, temperature, material
of construction, historical experience, risk factor (probability and consequence
of failure) and location in the process.

6.3 Inspection Description

6.3.1 Inspections for Instrumentation will be performed using the manufacturer’s
recommendations for inspections and preventative maintenance.
6.3.2 Inspections will be performed by either the Controls Engineer or the Instrument
technician. Persons performing inspections will follow the instructions in the
manufacturer’s manual.
6.3.3 Calibrations will be performed by either the Controls Engineer or the Instrument
technician. Persons performing calibrations will follow the instructions in the
manufacturer’s manual.

6.4 Timelines and Schedules

6.4.1 Preventative maintenance and calibrations will be performed in accordance

with the Manufacturer’s recommendations
6.4.2 A monthly visual inspection of the covered instrumentation will be conducted
by one of the following individuals: Controls Engineer, Instrument technician,
Senior Process Engineer, Operations Supervisor, or the Plant Manager. A
checklist will be used to record the inspection and any deficiencies recorded and
addressed in the CMMS.
Appendix A. List of Covered Equipment

Plant 1 Plant 2 Plant 3 Facility

CP-114 CP-114 CP-114 VE-840

Henek Vacuum
CP-124 CP-124 CP-124 Chamber

Henek Overflow
CP-213 CP-213 CP-213 Chamber

CP-214 CP-214 CP-214

HX-111 HX-111 HX-111

HX-121 HX-121 HX-121

HX-211 HX-211 HX-211

RA-113 RA-113 RA-113

RA-123 RA-123 RA-123

SC-213 SC-213 SC-213

SC-214 SC-214 SC-214

TK-245 TK-245 TK-245

TK-251 TK-251 TK-251

VE-117 VE-117 VE-117

VE-127 VE-127 VE-127

VE-201 VE-201 VE-201

VE-202 VE-202 VE-202

 VE-203 VE-203 VE-203

VE-212 VE-212 VE-212

Appendix B. List of Covered Piping

Plant 1 Plant 2 Plant 3 Facility

CO117 & CO127 CO117 & CO127 CO117 & CO127 Hydrogen Storage
piping piping piping Piping

Hydrogen
VE-117 Piping VE-117 Piping VE-117 Piping Compressor Piping

Ve-127 Piping Ve-127 Piping Ve-127 Piping VE-840 Piping

RA-113 Offgas RA-113 Offgas RA-113 Offgas Vent Line to

Piping Piping Piping Thermal Oxidizer

RA-123 Offgas RA-123 Offgas RA-123 Offgas

Piping Piping Piping

RA-113
Inlet/Outlet RA-113 RA-113
Piping Inlet/Outlet Piping Inlet/Outlet Piping

RA-123
Inlet/Outlet RA-123 RA-123
Piping Inlet/Outlet Piping Inlet/Outlet Piping

SC-213 Piping SC-213 Piping SC-213 Piping

SC-214 Piping SC-214 Piping SC-214 Piping

VE-201 Piping VE-201 Piping VE-201 Piping

VE-202 Piping VE-202 Piping VE-202 Piping

VE-203 Piping VE-203 Piping VE-203 Piping

VE-212 Piping VE-212 Piping VE-212 Piping

TK-245 Piping TK-245 Piping TK-245 Piping

Appendix C. List of Covered Rotating Equipment

Plant 1 Plant 2 Plant 3 Facility

CO-117 CO-117 CO-117 CO-824

CO-127 CO-127 CO-127 CO-825

CO-826

PU-842
Appendix D. List of Covered Instrumentation

Plant 1 Plant 2 Plant 3 Facility

FE-01103 FE-02103 FE-01103 FE-02103 FE-01103 FE-02103 PT-84003

PV-11705 PV-12705 PV-11705 PV-12705 PV-11705 PV-12705 LT-84005

PIT-11705 PIT-12705 PIT-11705 PIT-12705 PIT-11705 PIT-12705 LT-84002

XV-11706 XV-12706 XV-11706 XV-12706 XV-11706 XV-12706 LS-84008

FE-11702 FE-12702 FE-11702 FE-12702 FE-11702 FE-12702 LS-84007

LS-11701 LS-12701 LS-11701 LS-12701 LS-11701 LS-12701 LS-84006

FV-11702 FV-12702 FV-11702 FV-12702 FV-11702 FV-12702 XV-84201

XV-11717 XV-12717 XV-11717 XV-12717 XV-11717 XV-12717 XV-84001

TE-11310 TE-12310 TE-11310 TE-12310 TE-11310 TE-12310

PIT-11102 PIT-12102 PIT-11102 PIT-12102 PIT-11102 PIT-12102

TE-11101 TE-12101 TE-11101 TE-12101 TE-11101 TE-12101

FE-11312 FE-12312 FE-11312 FE-12312 FE-11312 FE-12312

LV-11306 LV-12306 LV-11306 LV-12306 LV-11306 LV-12306

XV-11313 XV-12313 XV-11313 XV-12313 XV-11313 XV-12313

XV-20310 XV-20311 XV-20310 XV-20311 XV-20310 XV-20311

TE-11201 TE-12201 TE-11201 TE-12201 TE-11201 TE-12201

TE-11202 TE-12202 TE-11202 TE-12202 TE-11202 TE-12202

TE-11203 TE-12203 TE-11203 TE-12203 TE-11203 TE-12203

PIT-11314 PIT-12314 PIT-11314 PIT-12314 PIT-11314 PIT-12314

PIT-11303A PIT-12303A PIT-11303A PIT-12303A PIT-11303A PIT-12303A

PIT-11303B PIT-12303B PIT-11303B PIT-12303B PIT-11303B PIT-12303B

PV-11303 PV-12303 PV-11303 PV-12303 PV-11303 PV-12303

LS-11302 LS-12302 LS-11302 LS-12302 LS-11302 LS-12302

LS-11301 LS-12301 LS-11301 LS-12301 LS-11301 LS-12301

LIT-11306 LIT-12306 LIT-11306 LIT-12306 LIT-11306 LIT-12306

TE-11309 TE-12309 TE-11309 TE-12309 TE-11309 TE-12309

XV-20109 XV-20107 XV-20109 XV-20107 XV-20109 XV-20107

XV-20110 LV-20102 XV-20110 LV-20102 XV-20110 LV-20102

PIT-20105 TE-21205 PIT-20105 TE-21205 PIT-20105 TE-21205

TE-20104 LS-21203 TE-20104 LS-21203 TE-20104 LS-21203

LS-20103 LS-21201 LS-20103 LS-21201 LS-20103 LS-21201

LS-20101 LIT-21202 LS-20101 LIT-21202 LS-20101 LIT-21202

LIT-20102 XV-21204 LIT-20102 XV-21204 LIT-20102 XV-21204

PIT-21305 LV-21202 PIT-21305 LV-21202 PIT-21305 LV-21202

PIT-21405 XV-21307 PIT-21405 XV-21307 PIT-21405 XV-21307

LIT-21302 LIT-21402 LIT-21302 LIT-21402 LIT-21302 LIT-21402

LS-21303 LS-21403 LS-21303 LS-21403 LS-21303 LS-21403

LIT-20201 XV-21308 LIT-20201 XV-21308 LIT-20201 XV-21308

PIT-20202 PV-20202 PIT-20202 PV-20202 PIT-20202 PV-20202

LV-20201A LV20201B LV-20201A LV20201B LV-20201A LV20201B

PIT-20307 LIT-20302 PIT-20307 LIT-20302 PIT-20307 LIT-20302

PIT-20305 FE-20312 PIT-20305 FE-20312 PIT-20305 FE-20312

PIT-30002 TE-20401 PIT-30002 TE-20401 PIT-30002 TE-20401

FE-11718 FE-11718 FE-11718