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API Ballot: [Ballot ID] – API 510 & API 570, Deferrals, Rev05Ballot ID:[tbd]Ballot ID - 4250Scorecard 570-096 and 570-097Item No(s)Title:API 510 & API 570, DeferralsDate:August 22, 2017Name:John Harville (entire team includes; R.Konet, J.Reynolds, S. Bollinger, M.Smith, P.Blanda,D.Wang, A.Morey, J.Monroe, C.Paschke, J.Krynicki, T.Poulassichidis)Company: Phillips 66Phone: 1 Provide a clear definition of the terms “deferral” and “due date” as well as clear/concise rulesrelated to developing and/or invoking a deferral process.Source:Industry practice, SCIMI scorecard items 570-096, 570-097 and comments on Ballot ID 3826(Std 570 Spring 2016 ballot items).Revision:5Impact:This change will impact both API 510 and API 570. For consistency sake, the verbiage is identicalbetween 570 and 510 (only exchanging the word “piping” for “pressure vessel” whereappropriate) API is managing this change as one single ballot for both code documents.This proposal was previously included in ballot No 3826 titled “Std 570 Spring 2016 ballot items”.Negatives for that ballot were not resolvable and it was felt that the proposal did not fully addressthe scorecard items/concerns that originally prompted the proposal. Further discussions withinthe SCIMI resulted in a number of additional revisions to the originally balloted verbiage and theRationale:proposal below was agreed to at the Spring 2017 meeting. For consistency sake, this ballotaffects two standards (API 510 and API 570) with details seen below. Also for consistency, whenthis ballot passes, the SCIMI will forward the final deferral verbiage to the SCAST forincorporation into API 653.Proposal:The changes (end result) are identical in both API 510 and API 570. The following pages showthe changes to each document in detail.API 510 (10th Edition, Addendum 1) Revise table of contents as necessary Revise existing definition for “inspection deferral” Add new definition for “due date” Revise §6.7 “Deferral of Inspection Due Dates”API 570 (4th edition, Addendum 1) Revise table of contents as necessary Add new definitions for “deferral” and “due date” Slight revision to verbiage in §6.1 to eliminate ambiguity. Revise §7.13 “Inspection Deferral or Interval Revision”Color Key of changesBlue ballot commentary/guidanceBlack existing (unchanged) verbiage)Red new verbiageRed strikethrough deleted verbiagePage 1 of 6

API Ballot: [Ballot ID] – API 510 & API 570, Deferrals, Rev05API 510 Proposed ChangesTable of Contents – rename 6.7 to “Deferrals”6.7 Deferrals of Inspection Due Dates ##Revise the existing definition of “inspection deferral” and add new definition for “due date”.3.1.34 (term is changing from “inspection deferral” to “deferral”. So put in alphabetical order andrenumber as appropriate)inspection deferralA documented work process using risk assessment to defer an inspection beyond its due date for aspecific period of time. See 6.7. An approved and documented postponement of an inspection, test orexamination. (see 6.7)3.1.XXdue dateThe date established by the owner-user and in accordance with this code, whereby an inspection, test,examination or inspection recommendation falls due or is to be completed. The date may be establishedby; rule-based inspection methodologies (e.g. fixed intervals, retirement half-life interval, retirement date),risk-based methodologies (e.g. RBI target date), fitness for service analysis results, owner-userinspection agency practices/procedures/guidelines, or any combination thereof.Section 6.7 – Revise the entire section as follows. Note: for ease of voter/commenter readability, theexisting 6.7 verbiage was stricken and replaced in its entirety with the following;Strike:6.7 Deferral of Inspection Due DatesInspection tasks for equipment and pressure relief devices (not set by RBI) that cannot be performedby their due date can be risk assessed and deferred for a specific period of time, where appropriate. Adeferral procedure shall be in place that defines a risk-based deferral process, including a correctiveaction plan and deferral date, plus necessary approvals, if inspection of a piece of pressure equipmentis to be deferred beyond the established interval. That procedure should include:1) concurrence with the appropriate pressure equipment personnel including the inspector andappropriate owner/ user management representative;2) any required operating controls needed to make the extended run;3) need for appropriate nonintrusive inspection with NDE, if any, as needed to justify the temporaryextension; and4) proper documentation of the deferral in the equipment records.Notwithstanding the above, an inspection or pressure relief device servicing interval may be deferredby the inspector, without other approvals, based on a satisfactory review of the equipment history andappropriate risk analysis, when the period of time for which the item is to be deferred does not exceed10 % of the inspection/servicing interval or six months, whichever is less.For equipment with RBI intervals, the existing risk assessment should be updated to determine thechange in risk that may exist by not doing the originally planned inspection. A similar approval processused for equipment with non-RBI intervals should be used to document the change in risk levels.Deferrals need to be completed and documented before the equipment is operated past the scheduledinspection due date and owner/user management apprised of the increased risk (if any) of temporarilyoperating past the scheduled inspection due date. Pressure equipment operated beyond theinspection due date without a documented and approved deferral is not permitted by this code. Thedeferral of scheduled inspections should be the occasional exception not a frequent occurrence.Page 2 of 6

API Ballot: [Ballot ID] – API 510 & API 570, Deferrals, Rev05Replace with:6.7 DeferralsInspections, tests or examinations for pressure vessels and associated pressure-relieving devices thatcannot be completed by their due date, may be deferred for a specific period of time subject to therequirements in the following sub-sections.Pressure vessels or pressure-relieving devices that are operated beyond the due date without avalid deferral in accordance with these requirements, is not permitted by this code. Deferrals shouldbe the occasional exception, not a frequent occurrence. All deferrals shall be documented.The guidance of an inspector, engineer or corrosion specialist should be obtained beforerequesting, granting, consenting to, or approving a deferral.6.7.1 Simplified DeferralA simplified short-term deferral may be approved by the owner-user if ALL of the followingconditions are met;a) The current due date has not been previously deferred.b) The proposed new due date would not increase the current inspection/servicing intervalor due date by more than 10% or six months, whichever is less.c) A review of the current operating conditions as well as the pressure vessel or pressurerelieving device history has been completed with results that support a short-term/onetime deferral.d) The deferral request has the consent of the owner-user inspector and an appropriateoperations management representative(s).6.7.2 DeferralDeferral requests not meeting the conditions of a Simplified Deferral above, shall follow adocumented deferral procedure/process that includes the following minimum requirements;a) Performing a documented risk-assessment or updating an existing RBI assessment todetermine if the proposed deferral date would increase risk above acceptable riskthreshold levels as defined by the owner-user. The risk assessment may incorporate thefollowing elements;- Fitness for service analysis results- Consequence of failure- Applicable damage mechanism susceptibilities and rates of degradation- Calculated remaining life- Historical conditions/findings from inspections, tests and examinations and theirtechnical significance- Extent and/or probability of detection (i.e. effectiveness) of previous inspections,tests or examinations as well as the amount of time that has elapsed since theywere last performed- Considerations for any previous changes to inspection or test intervals (e.g.reductions in interval due to deteriorating conditions)- Disposition(s) of any previous requests for deferral on the same pressure vessel orpressure-reliving device- Historical conditions/findings for pressure vessels or pressure-reliving devices insimilar service if availableb) Determining if the deferral requires the implementation of, or modification to existingintegrity operating windows or operating process control limits.c) Reviewing the current inspection plan to determine if modifications are needed tosupport the deferral.d) Obtaining the consent and approval of appropriate pressure vessel personnel includingthe owner-user inspector and appropriate operations management representative(s).e) Updating the pressure vessel or pressure-relieving device records with deferraldocumentation before it is operated beyond the original due date.Page 3 of 6

API Ballot: [Ballot ID] – API 510 & API 570, Deferrals, Rev05API 570 Proposed ChangesTable of Contents – rename 7.13 to “Deferrals”7.13 Inspection Deferrals or Interval Revision ##Add new term/definition for “deferral” and “due date”.3.XXdeferralAn approved and documented postponement of an inspection, test or examination. (see 7.13)3.XXdue dateThe date established by the owner-user and in accordance with this code, whereby an inspection, test,examination or inspection recommendation falls due or is to be completed. The date may be establishedby; rule-based inspection methodologies (e.g. fixed intervals, retirement half-life interval, retirement date),risk-based methodologies (e.g. RBI target date), fitness for service analysis results, owner-userinspection agency practices/procedures/guidelines, or any combination thereof.Section 6.1 – 1st paragraph, last sentence. Revise to read; .See 7.13 for more information and requirements on overdue inspections, and inspection deferrals,and inspection interval revisions.Section 7.13 – Revise entire section as follows;Note: for ease of voter/commenter readability, the existing 7.13 verbiage was stricken and replaced in itsentirety with the following;Strike7.13 Inspection Deferral or Interval RevisionInspection tasks for piping circuits and pressure relieving devices that cannot be performed by theirdue date can be risk assessed and deferred for a specific period of time, where appropriate. A deferralprocedure shall be in place that defines a risk-based deferral process, including a corrective actionplan and deferral date, plus necessary approvals.For equipment with RBI intervals/due dates, the existing risk assessment should be updated todetermine if the change in risk is acceptable by not doing the originally planned inspection.If inspection of a piping circuit is to be deferred beyond the established interval. that procedure shouldinclude:a) concurrence with the appropriate piping personnel including the inspector and appropriateowner/user management representative;b) any required operating controls needed to make the extended run;c) need for appropriate nonintrusive inspection with NDE, if any, as needed to justify thetemporary extension; andd) proper documentation of the deferral in the piping or PRD records.Notwithstanding the above, an inspection or pressure relieving device servicing interval may bedeferred by the inspector, without other approvals, based on a satisfactory review of the equipmenthistory and appropriate risk analysis, when the period of time for which the item is to be deferred doesnot exceed 10% of the inspection/servicing interval or six months, whichever is less.Page 4 of 6