Corresponding DOE Programs and Requirements

DOE-HDBK-1101-2004

Equipment in contact with HHCs forms the first line of defense in preventing uncontrolled

catastrophic HHC releases. The second line of defense is typically a combination of containment

and safety systems. For example, controlled releases of chemicals may be made to surge or

overflow tanks, to diked areas or controlled drainage systems, or through pressure relief valves

or vents to scrubbers, filtration systems, or flares. Second line systems also include chemical

detection systems and fire detection and suppression systems. The mechanical integrity program

must ensure that components in both primary and secondary lines of defense are designed,

installed, and operated properly.

Corresponding DOE Programs and Requirements

Most contractors already have preventative maintenance programs for their facilities. These

programs must comply with maintenance management requirements contained in DOE O

420.1A, FACILITY SAFETY, and DOE O 430.1B, REAL PROPERTY ASSET

MANAGEMENT which address most requirements of the Mechanical Integrity element with

little modification. DOE's quality assurance program described in DOE O 414.1A Chg 1,

QUALITY ASSURANCE and DOE G 414.1-2, QUALITY ASSURANCE MANAGEMENT

SYSTEM GUIDE FOR USE WITH 10 CFR 830.120 AND DOE O 414.1A Chg 1 helps to

ensure that process equipment meets specifications and is properly installed. Configuration

control and management requirements found in DOE O 430.1B also help ensure the mechanical

integrity of process equipment. The DOE safety analysis process can help to focus mechanical

integrity programs on safety critical systems, components, and structures.

Documentation Requirements

Written procedures are required for maintenance operations including the inspection, testing,

maintenance, and repair of process equipment. Inspections and tests must be documented and

must include the date, the name of the person performing the inspection or test, identification of

the equipment examined or tested, the nature of the test or inspection, and results. Deficiencies

must be corrected before the equipment is returned to service, or it must be tracked to ensure that

corrective action is taken in a safe and timely manner. A system must be in place to track,

address, and close out deficiencies identified during inspection and testing. Routine maintenance

activities should also be documented.

Documentation of the training of maintenance workers on the process, related hazards, and

applicable procedures should be consistent with documentation requirements noted in Section

2.5.

Minimum Implementation Criteria

Maintenance and quality assurance programs are crucial for fabrication, installation, and repair

of process equipment. When inspection and testing identify conditions outside of safety limits,

deficiencies must be repaired before operations are resumed. If it is not possible to stop

operations, actions must be taken to ensure safe operations so that corrective actions can be made

in a safe and timely manner. The program to ensure the mechanical integrity of process

equipment should contain: