Don Cooper 0:00
Welcome, everyone, to this special episode of the Industrial Innovators Podcast. Today, we have a special guest and a special topic to update all of our listeners on some new developments in the area of engineered composite pipe repair. And my guest today is my very own second in command, the general manager, integrator, and technical leader at Innovator Industrial, Chris Coombs. Chris, how are you doing?
Chris Coombs 0:32
I’m doing well, how are you?
Don Cooper 0:35
I couldn’t be happier, my friend. So, Chris, way back in 2009, when I actually started Innovator, I had written down a goal that one day we were going to figure out and get regulators to approve engineered composite pipe repair. And my concept at the time was like a CRN, the same way you would get a registration number on a leak repair enclosure or a hot tap fitting. Now, many, many years have passed, and we’ve had some significant advances in this approach. But it took a different path than we thought. What has happened?
Chris Coombs 1:28
Yeah, you know, it took a different path for sure. But I think when you look back, I think it took the only path it could have. Thinking about the difference between when we design an enclosure, we’re actually following a process for designing a category ah, fitting. And there are rules and regulations in place about designing that fitting. And then when we get the CRN, that’s what we’re actually getting. We’re getting a registration of the design of a physical component. Thinking about composite engineering composite systems, it’s not so much designing a physical component as it is restoring the integrity to an existing asset. And for that, it’s more about registering the application of the repair or more accurately the alteration than it is about registering a design. And that’s why we’ve taken over the industry and ABS has taken the approach of classifying this as an alteration and looking case by case versus registering specific designs for repair.
Don Cooper 2:41
So instead of registering designs for individual companies, the industry came together with ABS leading it and created a working group to come up with an agreeable process and strategy for how the industry could take advantage of the capabilities of engineered composite systems.
Chris Coombs 3:07
They did. So it’s been about a year since engineered composite systems, and ECS is the term. And, you know, before I go any further, we always talked about leak repair enclosures, and there were 10 different names for leak repair enclosures. I think we may have even listed them on this podcast on a different episode. And with ABS’s involvement, that transformed into an engineered pressure enclosure. So the new acronym was EPE for leak repair enclosures. So today, the new acronym for composite repair is ECS, which stands for engineered composite system. About a year ago, ABS introduced AB 539, which is the engineered composite systems for pressure equipment alterations. That means that this activity has been adopted by legislation in Alberta and also adopted by legislation in Saskatchewan, two provinces that were part of the industry group and part of the process for determining what needed to happen and how to deliver it. So that’s where we are today. We now have a document AB 539 that not only lists out what you need to do to register both your procedure and your application, it also instructs you on how to design and how to produce and manufacture the materials required to meet AB 539 for engineered composite systems.
Don Cooper 4:42
So this new regulation helps facility owners and all their integrity teams and all their maintenance teams understand their responsibilities.
Chris Coombs 4:54
It does. It’s actually very well-written. And I think having the input from the industry, which ABS is always very good at, is reaching out, forming these groups. And the way this document is written, I think just over time, like ABS is also getting better at writing these documents. And it’s very clear on how it identifies if you’re an owner-user, if you’re a manufacturer, a designer and installer, a supplier, and it breaks down everyone’s accountability, everyone’s responsibility inside of this process, to not just what you’re responsible for, but also the actions that you will take. So it’s written very well.
Don Cooper 5:37
So if you’re an owner, I mean, you know, there, you mentioned installers, designers, manufacturers, suppliers. I mean, you actually fill a bunch of those roles in one way or another, don’t you?
Chris Coombs 5:50
Yeah, absolutely. Yeah. You know, there are basically three parties involved when I think about it. There’s an owner-user who, at the end of the day, has ultimate care of the pressure equipment at their facility. So, you know, you’re going to hire an approved contractor, you’re going to ensure that they have competent people to do the work. And this is any project, any repair, you know, not just composite. And you’re going to do your due diligence in accordance with your process. But at the end of the day, you have the ultimate care and responsibility of that equipment. And that’s no different than engineering composites. So ABSA is very, very intent on the owners accepting responsibility and performing the actions that reflect that. And maybe we’ll go into it a little later. But just quickly, like the owner is responsible for a risk assessment, the owner is responsible for an integrity assessment where they identify the root cause of the failure. A lot of the work before the ECS is designed is the responsibility of the owner. Then we’ll shift to, you know, we call it the designer, the manufacturer, or the supplier. It’s typically one company, and these companies manufacture the products, design the PCs, and supply it. So that’s, you know, that could be any number of vendors throughout North America, throughout Europe. And then it’s where we come in, which is the installer. So we develop procedures for the installation of the composite, and we execute it and ensure that all the training and competency for the crew is where it needs to be.
Don Cooper 7:36
So the installers need to focus on their installation procedures, their training, and competency and registering their procedures with ABSA, with T SAS, and, you know, hopefully, eventually, with all the other regulatory organizations across Canada. What does the owner need to focus on?
Chris Coombs 8:03
Yeah, so, you know, the very first thing they would do, I mean, this is just pretty basic. We’ll get into the important stuff. But, you know, it’s grabbing this AB 539 and just familiarizing yourself with it because, like I said, it does lay everything out. The most important thing from an owner’s perspective is that they include this type of alteration. So the ECS, the engineered composite system, they include it in their quality management system as a type of alteration. I keep wanting to say repair because we are repairing damaged piping, and we’re restoring structural integrity. So you might hear me say repair a few times. But the technical or the definition of what we’re doing from a legislation standpoint is an alteration. So any owner-user has an AQ P with ABSA, and we refer to this as an 8000-level AQ P. So inside of that quality management system, they’re going to explain to ABSA how they intend on repairing their piping, how they intend on altering their piping or any pressure equipment. And that’s really all ABSA needs. They just want to be able to they don’t want to tell anybody what to do. They want to enforce the legislation. And they want owners to say, hey, this is what I intend to do. This is how I intend to repair my equipment, alter my equipment. That was a big actually a big delay. I think that getting composites approved in the first place was everyone was waiting for somebody else to act. It’s kind of like an ABSA stance is, hey, I don’t tell you how to repair your equipment. You tell me how you repair it, and I’ll see if it’s in line with legislation or not. So kind of going back to it, the first thing that an owner would have to do is decide that an ECS alteration is a method that they want to use to repair their piping and write that process into their quality management system. The really great thing about it is it’s very similar, and so many points crossover with the engineering pressure enclosure. So AB 521 would be a familiar document for anyone involved in the maintenance of the pressure equipment from a leaking standpoint. And you can leverage so much of what you wrote inside of that aspect to transfer over into composites. It’s very similar.
Don Cooper 10:33
Right. And so, if you’re already leveraging enclosure leak repair methods, engineered pressure enclosures, and you’re familiar with AB 521, then that can be your roadmap to add this part to your manual to cover AB 539.
Chris Coombs 10:56
Absolutely, absolutely. And, you know, I think the biggest hurdle that an owner might face, and I haven’t been on that side. So this is really only my perspective. And I know when it comes to even the statement I made earlier about ultimate care and responsibility of the pressure equipment, like nobody’s going to take that lightly. However, when writing this section into their manual, it’s focusing on the aspects that they control and then allowing the designer to do their part and allowing the installer to do their part. So what I mean by that is, in conversations with some owners in the beginning, struggling, trying to write their program to be precise, prescribing how to design a compass instead of writing procedures on how you will review design or how you will select the designer, two completely different things. And I can’t imagine somebody who is not actually a designer of composites writing a document on how to design composites, and that’s a big shift that I think owners don’t really take advantage of, focusing on.
Don Cooper 12:11
I remember some of those owners that were talking with us a few years ago. And they wanted catalogs of all our engineer composite system designs for every kind of example. And we’re like, why do you need this? Because they were thinking or trying to build their program around controlling the designer and controlling the installer. Maybe even not controlling, but telling them how to do their part of expertise when what they really needed to focus on is how are they going to evaluate the designer? How are they going to evaluate and make sure that the designer and the installer and the supplier were compliant with regulation?
Chris Coombs 12:55
Exactly. And, you know, I think when you carve out that, then the hurdle or what maybe seems like, “I’ll never have time to write this section,” you can strip it down and just really focus on what you are going to do in line with your responsibilities. And then how are you going to hold the other parties to their responsibilities, and how far it becomes more about evaluation and quality assurance as opposed to directing the work?
Don Cooper 13:26
Exactly. And how AB 539 is written, the language lends really well to transferring that language right into your manual. As long as you’re not trying to redesign or rewrite the document, then you have a very good template to start with. Okay.
Don Cooper 13:51
And so, the owner’s responsibility is to add this to their quality manual and to make sure that they understand their part in risk assessment and root cause. And a much simpler approach to quality assurance for the other parties.
Chris Coombs 14:15
Yeah, absolutely. The things that they write in their manual and then how to implement that, focusing on, like I mentioned before, focusing on the integrity assessment, focusing on maintenance and monitoring, focusing on risk assessment, and focusing on removal. Those aspects are things that the owner is going to follow inside of their own management of change procedure. And they’re going to write, they’re going to change that language to reflect what they do internally. They’re not going to change their risk assessment process to something that’s different from what they do for any type of defect or for any type of repair. They’re going to leverage what they do in control and then lean on the other parties and how the document is written to enforce their size. That’s really the approach to getting this moving.
Don Cooper 15:12
Right. Now, you mentioned that AB 539 covers installers and designers and us, and what other parties will likely do or try to do. But not everyone can just jump in and start. You can’t do a two-day course and decide you’re going to be a composite systems installer designer, can you?
Chris Coombs 15:39
No, absolutely not. You know, I guess there are a couple of ways to address this topic. But, you know, ultimately, this is not something that you just decide one day that, “I’m going to go repair some pressure equipment,” no different than if an owner hires a contractor to come out and repair, you know, to repair a section of piping using traditional welding methods. So they’re going to weld a sleeve, something like that. And the response from the contractor is, “Okay, sure. I’ve actually never done that before. But why don’t I’ll develop the procedure, and then we’ll test it, and they’ll come out, and I’ll do the repair for you.” I mean, that’s just not going to happen, right? The owner is going to say, “From a competency standpoint, the difference between training and competency is obviously not there.” So, from an ECS standpoint, I think, from an owner’s perspective, aligning yourself with a contractor that actually lives and breathes composite on a daily basis, like this is part of what they do, it’s incorporated into their daily activities, that’s where you’re really going to get the benefit. Because this contractor now is going to have already registered procedures that you can take advantage of, they’re going to have the training is going to be complete, but they’re going to have the competency and the experience to back it up. And that’s really where the benefit is going to come in. And while you can’t just pick it up one day and install it. To that point, one of the biggest concerns from ABSA in the beginning was how the installer, the quality of the installation affects the effectiveness of the repair. And they had trouble quantifying that. They had trouble writing that into their documents. I can’t read the skill of these, it depends on the skill of the installer. So we put a lot of checks and balances in place for how to determine competency. But at the end of the day, the ability of the installer does greatly impact the success of this type of repair.
Don Cooper 17:55
Yeah, I mean, you touched on something there that I am passionate about. And I see this as a problem in our industry as we’ve added more and more regulations and more and more controls. Everyone is seeking a certification, and tradespeople call it, “I got a ticket.” Well, having a training session in any sort of specialized service doesn’t give you any license to do anything other than to be a helper to someone who is competent. And competency in any service, and engineered composite systems is a critical one, is key because there are so many applications, there are different types of materials, surface preparation, different wrapping methods, and it takes years to develop the competencies. Competency equals many different procedures proven that you can do it on your own over time before you are left to do it on your own as the competently technician. And I’ll just speak for myself. I’ve been involved in composites, composite systems for 18 years.
Don Cooper 19:17
And I have gone through training and certification with every single major supplier of composite repair in the world, every one of them.
Don Cooper 19:34
And I think I’ve, somewhere in a filing cabinet, I’ve got five different certificates, and I am not competent to wrap my waterline in my bathroom wood composite. I know the theory, and if I brushed up on the procedures, I would re-familiarize myself, but I would never be competent to go out and perform this work for a client. I did the training to understand the differences in the product and in the differences in the solutions. I never did the training with the intent that I was going to be the lead competent technician to do that work. So my reasons for doing the training were different. But the point here is that the training course does not give any capability to go perform the work under this regulation. It’s just not enough.
Chris Coombs 20:28
And no, no, definitely not. Competency is a big topic in the group. And something I spent a lot of time on. So we all actually had to, you know, there was, I don’t know, maybe there were 20-25 people in the group together. And some of those people were designers, some of them were engineers, some of them were material specialists. And then we had some execution people, some quality control people, so a broad group. And the document, you know, if you look through the document, you’ll see it has all those aspects. It has design, it has QA, it has inspection. So we broke it up into different aspects based on skill set and based on what we were all kind of passionate about. And the competency section was one that I would not let go, guys, and I felt so strongly about it. There’s a number of, you know, in order to start, so we talked about starting. So sure, there’s an initial training event to get you started and to get you familiarized with that material. What’s happening now is we take that one step further. So if you picture, you think about the engineering composite procedure, similar to a welding procedure. This is how I am going to wrap your plate. This is how I’m going to weld these two pieces of metal together. That’s what the procedure tells you. But what people want to see is, well, can you do that? And can you do it over and over? Can you repeat it? And that’s where the qualification comes in. So something that we’ve added to competency is the PQ or Performance Qualification Record. So now, not only do we write the procedure, we have to demonstrate that the people that are doing the installation can repeat that same type of installation in other circumstances. So with every procedure, we have to provide a qualification report. And that just further cements that this is not only the procedure designed for your application, but it’s been tested, and it’s proven effective. So that again, now we’re still just getting started. Then we have similar, again, similar to other practices in the industry, like taking on things like an engineering logbook, where we document all the repairs for an installer, whether they were successful or not, the pressure, the temperature was there, through holes, did the heavy use stopgap. All these things go into determining someone’s competency and just building them up throughout the levels for composite repair.
Don Cooper 23:03
So similar to using something that a lot of listeners would be familiar with. Someone can go to trade school, go to Nate or wherever, and they can learn welding. And they might even eventually become a journeyman welder. But then Company X hires them. And Company X has five welding procedures. In order for that person to be authorized to work to those procedures, they’ve got to have a track record, they’ve got to well coupons, coupons got to be tested. And they’ve also, you know, then they’re also tracking effectively success and repair rates over time to build that person’s competency up so that when a client says, “Hey, I want someone to weld Inconel,” the contractor can say, “Here’s my procedure, it’s registered, here are my qualified welders, and here is their performance track record to prove their competency.”
Chris Coombs 24:04
That’s what you need. That is exactly what you need to be effective but also be compliant with the new regulation to install ECS. And like I mentioned before, if that is not a main focus of the installer, then you’re just going to get somebody who’s doing it in the moment for the activity versus maintaining it on a regular basis.
Don Cooper 24:30
I think there’s an interesting pivot point there, you know, because you and I have been involved in composite systems for a long time. And we’ve seen a lot of contractors and owners and other organizations doing this with what I would call at best a training event. And because it was never regulated, it has a reputation of being abandoned, as not being an engineered system for restoring the integrity of the piping system because people have used it as, like plumber’s tape to patch up something. This process is something very different than “I’ve got a pinhole leak, wrap some fiberglass around it.”
Chris Coombs 25:24
Absolutely. You know, and even thinking about that. So there’s, I said in the beginning, there’s a lot of similarities between AB 521 and AB 539. So one for engineered pressure enclosures and the other for engineered composite systems. There’s also a lot of similarities in how they can be used, not just in the legislation, and how they can be used. So you can use an ECS to repair a pinhole leak, you can use an ECS because you have a thinning section that’s through-holed and repair that. But that’s not the main advantage of a system like this. So, you know, there’s leak repair. In my mind, there’s leak repair and then there’s asset longevity. And it’s about, you know, leak repair versus leak prevention. And that’s where I really think the ECS stands alone as opposed to EPS. There’s a place where you can use them interchangeably, and maybe your decision to use them is based on cost. A great decision to use an ECS over an enclosure would be the weight. You know, if you get into a large-diameter piping and you’ve just got a pinhole leak. So now we’re talking leak repair. And, you know, I still think the preferred method of leak repair is an enclosure. But if you’ve got to put 1,000 pounds of steel on your pipe to repair that pinhole leak, you know, maybe there’s a better option, which is where a composite comes in. So you can evaluate the two. But if you truly want to take advantage of what ECS has to offer, you’re thinking about asset life, you’re thinking about extending the life of your asset, wrapping it before it experiences that panel. And then using that information to identify other assets, other places, other pipelines within your facility that can be wrapped and really take your maintenance program from doing repairs to just permanently repairing sections of piping when it suits you, versus fixing a leak as a cop.
Don Cooper 1 27:47
When you get a leak, you’re forced to deal with it. And you’re always in reactive mode. But leveraging this new capability, you can be much more proactive. You can do a lot of things, right? You can prevent leaks, one, you can make decisions around which piping systems need to be replaced on a project or on a turnaround, which ones you can extend the life of for some defined life, right?
Chris Coombs 28:20
Yeah, you know, as, again, maybe some of our owner and actually, I’d love to hear from, you know what I mean? Like, it almost be like you say something incorrect, just so an owner could, if there was an owner listening or somebody involved in the inspections, in one of those facilities could correct me. And I’m like, because I think that would be amazing. But if you think about having an inspection, you have a monitoring plan. And throughout that monitoring plan, you identify a section of piping that is starting to lose integrity. It’s not nearly leaking yet, it’s not even below T-Min, you know, it’s nothing like that. But you notice something that is starting to degrade. So because it, you know, I feel like then that asset is going to be elevated to another level of inspection. So maybe the frequency picks up. Right, so now the frequency’s picked up, the amount of man-hours going into inspecting that asset has picked up, all of these things have a cost to eventually at some point, either you’re going to make it to a turnaround or that line is going to leave it the way I see it. So instead of continuing to escalate the inspection activities, you could just wrap that asset, remove it out of your inspection loop, and then focus your inspection activities somewhere else to identify another asset and then continue to do the same. So not only are you putting the integrity back in, you’re preventing a leak. But you also now can just kind of breathe easy and remove that asset from the inspection protocol altogether.
Don Cooper 29:56
No, well, it allows you to be much more proactive and redeploy all your monitoring and inspection focus elsewhere. Once you decide, “I’m going to use my inspection resources and my repair resources to just make this a non-issue.” You know, we both have friends who are involved in the UAE at our client facilities. One friend of mine, in particular, he was responsible for something like 185,000 UT measurements per year, looking for and monitoring, you know, so that the facility could predict and trend failures. And this is exactly what we’re talking about. They had an army of people who were doing inspection on a regular basis, just looking for wall loss. I would imagine, and I don’t even need to imagine, I know, every major client has that sort of a program in place. And so this is no longer just a maintenance tool. It becomes a new strategy within your asset reliability program.
Chris Coombs 31:09
Exactly, exactly. And I think, you know, those conversations, I think, are still very new. So I don’t believe those conversations are happening yet today, right? Like this is now in legislation. You know, it’s started, some owners are starting to get comfortable. We’ve registered three, we’ve registered our eight, we’ve registered one procedure to pending, with three specific applications. So that’s kind of where we’re sitting today. And owner users are starting to get very comfortable with the process and leveraging the material. But I don’t think the conversations are happening at that asset integrity level. It’s still happening at a maintenance level. And that’s where I really think this could really benefit our clients.
Don Cooper 31:57
I think that’s where it can transform their business and the way that they do a lot of things. Because traditionally, we’ve always engaged with clients when they’re already at the point of no return. They’ve got to fix the piping, sometimes they’ve already got leaks, or they know that they’re only going to get two or three more months. And that’s the point where they are talking to us. But instead of being at 80% loss with a failure predicted within 30 or 60 days, through their monitoring program, they could trend, “Hey, we’re at 50%, we’ve got a year. We could take this out of the turnaround scope and extend, deal with the loss of integrity and extend the life of this asset for a defined life.” You know, a lot of people ask, “Well, how long can it last?” So can you touch on what defined life means and what clients can do with this system, though?
Chris Coombs 32:56
I can. And if you know, thinking about it, so before I jump in, I feel like ABSA, as I said in the beginning, did an amazing job with how this document was written and how composite was entered into legislation. They were very open to listening to the parameters in terms of pressure and temperature. And I think they, you know, what they adopted, I think fits really well in the industry. There were also areas where they were very conservative. So they were conservative inside the scope, applicability. So where you can use it in terms of when it’s classified as normal fluid service and Category D and different things like that. They were also very conservative on the removal date. And in this case, they stuck with what they knew, which was a one to two-year removal of an EP. So while I go in to talk about design life, I wanted to highlight that within legislation, there is a one to two-year commitment to remove the composite. That doesn’t mean that it can’t get extended. So then we’ll move into defined life. The defined life means that a composite repair can be designed to last however long you want it to last. So we can design a repair around a two-year lifespan, we can design a repair around a five-year lifespan. Repairs can be designed for permanence, to design a repair for a permanent repair. That sounded off. To design an ECS for a permanent repair requires a 50-plus-year lifespan, and all that is capable within an ECS, and it’s all about understanding what the requirements of the unit are, you know, what the asset life is, how long would an owner want to get out of that asset, how long do they need to get out of it, and when, you know, when is it available for them to repair. So that’s really what a design life means. It’s, instead of how long can it last, it’s selecting a date in the future and then designing the repair to meet that date.
Don Cooper 1 35:11
So the capability of the materials and the design of that individual repair with a variety of different materials can meet the needs of the client based on what they say, “Hey, I want to get five years out of this,” and then we could design it that way. Now, you said that within the regulation, it has this two-year registration? And you also mentioned the possibility or the process for extension. Can you touch on that a little bit?
Chris Coombs 35:44
Yeah, absolutely. You know, inside the registration, so we talked a little bit about some of the big things in the beginning, like an integrity assessment, which would be a root cause analysis, then you do a risk assessment. And a risk assessment, as you know, a lot about, you know, what happens in the unit if something like this fails? What are the risks to personnel? What are the risks to the environment? And also, what are the risks to the personnel during the installation as well, you know, making sure everything can be done safely. One of the, and I want to come back to this a little later when we talk about the conservative nature of the documents and how that may be can hold people back. But let’s get back to that. So try to stay on point here, I’ll bring you back to that yet. So inside the risk assessments, you know, so you identify that like in this next two years, here are the risks of failure. And that gets accepted as part of the registration. But along with that, there’s a maintenance and monitoring plan. So what that means is, I’m going to perform a visual assessment of this repair at x frequency, and ABSA doesn’t dictate what the frequency must be. That all fits into the risk assessment. So if you, if a client accepts the risk of doing a visual inspection and maybe something that we refer to as a tap test, so a tap test is actually tapping the repair at various places to feel for different types of failures like bonding failures, to feel for soft spots and different things in there to indicate that there’s been a leak or something. So there’s different types of inspection that you can do through maintenance and monitoring, even up to like performing an x-ray. So if the timing is right, and maybe that unit was down, but not scheduled for repair, then you could perform an x-ray on the composite, you could get a really good look at the defect underneath. And you could determine that the defect has grown, either still within the parameters of the design or is expected to grow outside the parameters of the design. With all that in place, if you then redo your risk assessment, and you either increase or keep your maintenance and monitoring plan the same, you can apply for an extension and easily get another two years. And you could continue that process until you can’t, until you can no longer demonstrate an equivalent level of safety within the repair. Okay.
Don Cooper 1 38:25
So the essence is, much like the rest of their monitoring and risk assessment of all their assets, if they have a plan in place, then there was the possibility that if we, if someone designed that for a 10-year repair and they registered it and had a risk mitigation process in place for two years, then the possibility and the systems are in place there to extend that registration in increments that make sense throughout the risk assessment process.
Chris Coombs 38:52
Absolutely. I’m kind of thinking and no one to get. We have any ABSA listeners. This is not meant to get anyone in trouble and a lead in here or lead into the next point, I think a little bit here. But first ABSA doesn’t want you to ask, they don’t want to say, “Hey, can I put this for 10 years?” I believe what they want to see is, “I intend to put this on for 10 years. And here’s how I intend to make it safe.” It’s a completely different conversation. But if you ask, “Hey, can I do this?” they’re gonna say no. And we experienced that. I think everyone experienced that at another level of business. The difference between asking and the difference between, you know, stating your intention to do something, we’re always going with that is one of the hurdles, I think, to people adopting composites is the conservative nature of the scope where you can install it. For instance, if you have a through-hole defect, legislation AV 539 will only allow you to install that on Category D systems, which is essentially water. What I really admire ABSA for in this case is that they really lean into the intent versus the black and white of the language. So, case in point, we registered just last month a through-hole defect on hydrocarbons because we were very clearly able to show an equivalent level of safety. And no other means was effective as an ECS to repair. So because we met the basic intent of what ABSA was looking for, they reviewed it on a case-by-case basis, and they accepted that as an acceptable procedure. And I think if you just look at the black and white of the document, you could be missing many opportunities to leverage composites. But if you really focus on the intent and you say, “This is what I want to do, I accept the responsibility, here are the risks,” ABSA is always going to review and listen to that application.
Don Cooper 41:08
And that level of capability to go through that process, to show the rigor, the focus on safety, and designing the whole thing, you know, owners can’t get that from someone who is just assigned to go install the composite. What do you think owners should do in terms of the way that they are aligning themselves with, you know, in the document, it talks about installers and designers and the owner, what’s a great strategy for an owner to make sure that all of those things are aligned for consistent performance so they can get those kinds of results?
Chris Coombs 41:53
The first thing that came to my head, it’s kind of funny, it was kind of thinking like the easy button in a sense. But, you know, it’s about picking somebody that makes that section of the document easier on you. Right? If you have to really work with your contractor to understand how they prove competency. If you have to really work with them to help them develop their procedures, then you’re, you know, I think you’d be doing yourself a disservice. Whereas there are contractors out there just like Innovator, where that’s been such a focus for us for the last 10 years that we have this, you know, this type of documentation readily available. It’s already written into our quality management system. It was written into our Quality Management System before composites were adopted in legislation, in preparation for this. So just making sure that you select somebody who, I guess, is at the forefront, versus just always reacting to what the changes are in the industry.
Don Cooper 43:03
Yeah, this is this kind of work. This is, you know, it’s an engineered composite system. It’s not a task. No, or this is not, this is not, hey, I’ve got you know, and I, and I’ll respect to all the general contractors out there, but this is not deciding. Here’s one of 10 people who can install some valves for me. I think this is a you know, it’s new, but and there’s, there’s a level of competency required, but from easy to do for owners, they gotta gotta align themselves with an installer design team who just knows how to do this better than they could ever, ever know. And that way, they’ve just got to focus on the quality assurance and risk assessment and, you know, monitoring their assets do what they do best?
Chris Coombs 43:53
Absolutely. Yeah. I couldn’t agree with that more. And it should be easy. It should be easy for the installer to produce the level of ITP that’s acceptable by EPSA. It should be easy for the installer to produce the proof of competency that’s acceptable by EPSA. It should be easy to register these applications. And if it doesn’t feel easy, then you know, that may be a sign that you might, you know, need to look for that easy button.
Don Cooper 44:25
Right. Let’s, you know, lead into the registration process because this is not just the owner.
Chris Coombs 44:36
No, it isn’t. There are really two parts to it. And we I think we touched on it, but it’s great to just get it specifically. It’s a two-part registration process. There is what we refer to as the EC S P S. Engineered composite system procedure specification. So think of that like your welding procedure and P QR code book that has to get registered in advance. So we pick a material in terms of a composite material, you look at a range of applications. So I, you know, off the top of my head, you got, you know, half-inch diameter piping all the way up to 36-inch or 48-inch diameter pipe. The great thing about composites is that it doesn’t matter what the diameter is. And it also doesn’t really matter too much on what the pressure is, however, the legislation has placed the 500 psi limit on lots of fruit. So that kind of helps us narrow in on the procedures of where you can, or where you can build how you can build it. But the first thing an installer would do, and this has to be kind of on their own, like this doesn’t need to be client owner user prompted, they register those procedures, and you register enough procedures to kind of cover a gambit of what you may face in the field. That’s step one. Step two is then simply about the application. And the easiest way to say it, as I think I’ve already mentioned it, is we’ve got an application that we want to repair. And we’re going to show you that we can do it with composite with an equivalent level of safety as traditional means. And then inside of that, there are all the steps that need to happen, which was essentially the RIMR process that everyone was familiar with that got added to leak repair enclosures is what we’re following for composites.
Don Cooper 46:35
And that involves both the owner and the installer, going, you know, participating together to register that alteration, and the design and that whole process, right?
Chris Coombs 46:46
It does yet. You know, I think I’ve mentioned it starts with integrity assessment. So why is your pipe leaking? Or why is it failing? Like, do you know what the root cause is? And because if you don’t, then how do you know this repair will actually make any difference? Right. So that’s where it starts, then it moves into a, it moves into the risk assessment, like I mentioned before maintenance and monitoring, and the removal and the removal date. One of the something new that got added that many owners are not maybe not used to is that there’s the UDS so UDS is the user design specification. Like we commonly refer to this as a datasheet. So we go out and we collect the datasheet, all the parameters that are required to design a composite system. In this case, the owner must stamp the UDS. So that’s a new requirement, above anything that we’ve reused to in EPS, where they need to actually stamp the input parameters to confirm that they’re correct. So that the designer can then go ahead and follow the process to design the system.
Don Cooper 48:02
I liked that process, to be quite honest because, you know, whether it’s whether it’s an EPE or a hot tab, sometimes it can be a challenge to get the right information from the owner because they’re getting it from three or four different people trying to find materials and thicknesses and corrosion allowances. And, and, and then sometimes, and sometimes if the right conversations are not happening, they’re giving you an opinion versus actually going and getting the right information. So I actually think that that’s a really good step in making sure that everyone understands the critical importance of collecting the right data.
Chris Coombs 48:43
Yeah, for sure.
Don Cooper 48:47
This isn’t new technology?
Chris Coombs 48:50
No, no, it isn’t. And I’m not even going to pretend that I know, you know, like the entire history of IT. I can tell you that. I’ve been installing it personally for 15 years. And not just installing composites, as you know, like what we referred to earlier as band-aids and different things, installing engineered composite systems for 15 years, and installing them on pipelines inside of process facilities, pressure piping, non-pressure piping, we’ve been, you know, this has been around and proven successful for a long time. And I think that’s an important understanding to have. Because for some, oh, that, you know, with adoption into legislation, will give people the idea that it’s new. It’s just accepted. I don’t think, you know, absolut, I’ve never introduced it into legislation or recommended it for introduction if it didn’t have, if it wasn’t backed by years of experience by years of success. In other jurisdictions, like even, you know, the, the Alberta energy regulator, you know, leveraging composites for pipeline work inside of that 6x. Two, and then all across North America all across Europe, composites are used worldwide very effectively.
Don Cooper 50:20
Yeah, I mean, you know, this is new legislation, new regulations to allow process facilities to leverage and use our competent systems. But as you say, this has been a, there’s robust language in the pipeline codes at 662. In Canada, there is robust language in the post-construction codes on their Azmi that has, that covers composite repairs for a long time. And, you know, similarly, on an international level, there, there is robust language and procedures and processes in place under ISO regulations. And so, globally, this is, you know, different organizations have been using this for years and years and years, following one or more of those guiding regulatory codes to use this successfully. We’re just, we’re just now getting there. We’re on the on the process side. That’s regulated in cyber Canada.
Chris Coombs 51:17
Yeah, absolutely. You know, like certifying certifying authorities, you know, like Lloyds and and, and DNV. And those types of organizations, you know, they’ve been issuing type approvals on composites for many years, you know, verifying that installers and manufacturers have been installing lining, and you know, this to those specifications. So it’s definitely not new to the industry.
Don Cooper 51:48
Of course, owners right now, you know, we’re in the post-turnaround phase of the calendar year, which tends to be the planning phase for the next set of projects and the next set of turnarounds, and they’re making decisions right now, around what piping they should include in their projects and turnarounds for replacement, you know, and there have there getting pressures around availability of craft based on the schedules of these events, about costs. How can owners think about this solution in the way that they are planning their piping replacements in 2022?
Chris Coombs 52:34
I think, you know, I think there’s a number of different ways to think about it. So even from the things that you mentioned. So resource, I think resource allocation is one of the biggest things that’s not considered when, you know, when you consider installing composites, in past conversations that I’ve had, somebody would weigh the cost of permanent repair versus the cost of the alteration with composite. And, you know, every time the cost of the composite is going to be less than the cost of the permanent repair, but however, you know, maybe they’re looking at it like, well, if I got to spend up to 50% or if I got to spend 30% of the current repair, it makes more sense to repair permanently, so I’ll just schedule for tomorrow. And I get that thinking. But if you then have a resource crunch, if there are schedule conflicts with your turnaround team, if there’s a lack of manpower, or lack of inspection resources, there’s so many of these items can be alleviated by extracting some of these either identified degrading pipelines, and pulling them forward in a scope or, you know, letting them go through a turnaround to then wrap after just essentially taking them out of the turnaround repair scope. And completely restoring the integrity through composite, not taking any risk at all, you’re completely restoring that integrity. And now you can allow for the continued operation of that asset. I almost think of it like a return on investment conversation. Right. So if you purchase something, and you expected to get 10 years out of that asset, and you purchased it because you were going to get a return on investment at the 10-year mark or so much at 10 years. But now you’re repairing it in year five and year six and year seven. And then in year seven, you’re just completely scrapping and rebuilding it, well then that wasn’t a very good investment. However, if you decide to use composites in your six or seven to get you to that 10-year, now you’ve made a small change, and you’re gonna get a much better return on investment on that particular asset. And I think that’s how people should maybe think about it, or a different way for people to think about it than just what does it cost to composite? And what does it cost to repair? And just do those two evaluations?
Don Cooper 55:11
Yeah, and I think there’s a lot of Pete, you know, clients pay a premium to get 10,000 meters of piping replaced in a turnaround in a six-week window. And inevitably, they start D scoping based on criticalities. And then they start having to think about, you know, can we get that, can we pull this piping out and do it in the next turnaround, or can we put it on a project list for 2023-2024? A lot of those decisions can become a lot easier if you don’t have that time crunch of, “I’ve got to do all this in six weeks,” versus a big chunk of this work can now be done in the three months before the turnaround or the three months after the turnaround. And they can focus on the most critical activities for the time and the resources in the schedule that they have. I think it gives planning and integrity another whole capability that doesn’t force them to do some of these kinds of replacements in kind in a short window when, you know, no matter what seems to happen, every single owner in Canada seems to want to do a turnaround in the same weeks in the spring or the same weeks in the fall. There are all sorts of strategies around them trying to figure out how to coordinate that better. But, you know, I never seem to see it being successful. And what I hear about 2022 is from a turnaround craft standpoint, we’re 1000 short for the spring.
Chris Coombs 56:48
You know, absolutely. I don’t even fully begin to understand what those cost implications are going to be for our owners. I’m sure they’re worried about it, and they’re figuring it out right now. But, you know, one way to impact your turnaround schedule is to, you know, identify pipelines that can be extracted out from that repaired via composite, put back into operation, and, you know, scheduled for 2025 or sometime down the road, that, and you can really be strategic about what you repair, what you need to repair, and how you allocate your resources, I think, and that even goes from inspection all the way through to the craft that are going to do the replacement.
Don Cooper 57:38
Yeah, there’s an awful lot of different strategic byproducts of having this capability from your inspection and your monitoring teams, your asset teams, your turnaround teams, your maintenance teams. All of a sudden, this work can give you a lot more flexibility in how you’re dealing with asset integrity and life and return on investment on all those investments, which are the best places to spend the money to get the best return, right? That’s it. That’s it.
Chris Coombs 58:09
And you know, if you’re only, I mean, I don’t know if you’ve got a line that you’re continuously having to replace, and maybe this is not a scenario, but if you’ve got something that you’re replacing every other turnaround or something like that, then you know, like, maybe the answer is not to continue doing that. It’s like we can double the life, let’s get you through two, or let’s double or triple that life that you’ve been getting out of your asset to then really take advantage of that return.
Don Cooper 58:44
We talked a lot about Alberta. And you know, we’re referring to AB 539. And that’s an Alberta process. But Saskatchewan and T-SAS, we’re in were an embedded part of this industry working group. Where has Saskatchewan and T-SAS gotten to in terms of adopting these processes? And by virtue of that, how can Saskatchewan owner facility owners take advantage of this process?
Chris Coombs 59:14
Yeah, fortunately, it’s exactly the same. They don’t need to do anything different because the adoption in the legislation is the same, and the adoption of AB 539 is the same. So the exact same document applies in Saskatchewan. It covers the exact same responsibilities for owners, installers, and designers. It’s literally the same process.
Don Cooper 59:38
You’re just submitting it to a different regulatory authority. Yep. Awesome. So everyone in Saskatchewan who is listening, all of this engineered composite system process applies to you right now at your facilities. Anything else happening in Canada with other jurisdictions? Are anyone kicking the tires? What can you share with all of our other listeners who aren’t fortunate enough to be in Alberta and Saskatchewan relative to engineered composites?
Chris Coombs 1:00:12
I’ve been a little disconnected from the rest of the jurisdictions, as we saw, we hyper-focused, we got the and we jumped on it, and they got hyper-focused on what was happening in Alberta and Saskatchewan. What I believe is going to happen next, this adoption for ECS, I believe it’s going to go throughout Canada. And I think it will start with, kind of like what I mentioned before, owners not necessarily asking but not doing and asking for forgiveness either. It’s making a decision that using an ECS is the right repair for this application. So let’s take an owner in Ontario, for instance. I believe that if they decide and have the intention to use an ECS, following the process, very similar to what they do for EPS or very similar to what Alberta has outlined for ECS, it will get adoption and acceptance in Ontario as well. If we take that route, but waiting for, I think, legislation to change or for someone to just decide when they will, I don’t think that’s going to be the route. I think you can not even necessarily be forced, just demonstrated that this is an effective and safe repair method. And we demonstrate that through applications. And I believe they’ll be accepted.
Don Cooper 1:01:44
You know, you and I have gone in and sat with regulatory jurisdiction teams. And the pushback that we got is, well, the owners don’t want this. No one has ever said that they want this. And so if the owners in a particular jurisdiction are waiting for legislation to change, it’s not going to happen. I think we, you know, just based on the feedback we’ve gotten, it’s got to be owners who go to the regulators and say, “I want to do this.” And now you have a framework to follow it. And at least then, I see it as happening is one of two things: either they will take on some pilot projects from owners to say, “Hey, you know, we’re going to follow this process that Alberta and Saskatchewan have followed,” because many of the owners that might be in a different jurisdiction, you know, many of them have facilities in Alberta and Saskatchewan, and they’re going to be adopting it here. So it’s going to be a little bit easier for the ones who happen to be multi-jurisdictional facility owners. But based on what regulators have said to us, waiting for the regulator to make the change, I think it’s actually the asset teams at those facilities coming up with a plan and approaching the regulator, saying, “We want to follow this method and do these repairs.” And that might take the route of some individual pilot projects, or they may get together as an industry group and look at that legislation and those guidelines and either adopt them in kind or adopt them with modification. But I do think it starts with the asset teams with the owners being proactive to say, “We want to do this.”
Chris Coombs 1:03:32
Yeah, I absolutely agree. And that was absent, it’s very clear with us on that. And, you know, it was, think back, it was a little funny, and they say, “You know, we hear a lot of ‘I want to do this’ and ‘we should do this,’ but we don’t see any action. Where’s the action?” Right? And that was a lot of what they said in the beginning. And I honestly think the action is deciding that an ECS is the repair that I want to do. And then doing the work. Like I said, Don’t ask, “Can I do it?” Do the work, do the risk assessment, show the equivalent level of safety, and then present that as the repair. Even today, I believe that would be accepted in any jurisdiction in Canada based on what’s happened over the last couple of years.
Don Cooper 1:04:19
Perfect, and hopefully, we can start to see owners in other areas moving in that direction, and then regulators working alongside them to make that happen. So this just becomes a nationwide process. Chris, this whole process with engineered composite systems, from a regulatory, compliance, and competency standpoint, really focuses on safety, good engineering, and good quality assurance on all those aspects. I think it’s important for regulators to focus on intent and safety. But what else have you looked at doing or done to streamline and optimize the way this is done, the way that this work is carried out, so that it can improve cost-effectiveness and productivity, and bring additional value?
Chris Coombs 1:05:18
Yeah, for sure. So first off, a lot of the innovation in the material, the product, the material, a lot of that comes on the manufacturer’s side of things. However, we play a part in that as well when we approach jobs and different techniques for installation, for instance. It can cause a manufacturer to revisit a process or revisit how things are done. So there’s a continuous feedback loop between an installer who’s really invested and the manufacturer to improve the techniques for installation, the layer count, the curing process. All of that stuff is a continuous improvement process. One of the major advances that we’ve made is when it comes to surface preparation. And surface preparation, I really started to focus on surface preparation. Not when I first started, and I think this is a bit of a story, I guess. But when you take an engineer, when you take a composite training event, they will tell you that the pipe needs to be prepped. And they will show you in your design what the anchor profile or the roughness needs to be for that prep. They don’t teach you how to prep it, and they don’t really emphasize the importance of that prep. It’s all about the technique on how to install, and you’re probably given some sandblasted piping components to wrap, so you know, ideal conditions. Then you go out into the field, and maybe you’re hand prepping piping, and you’re using, ideally, mechanical equipment like something like a bristle blaster to achieve your anchor profile. But that was a big gap and why a lot of failures happened in the beginning with contractors not being familiar with composites. So we really leaned into the importance in the training and the inspection of surface preparation. That was a big thing for us. So then we started to work inside AB 539 and the new legislation. You have to be very particular about how your procedure is qualified. So if you’ve qualified a procedure with hand prepping tools, then that’s how you have to install it in the field. And if you qualify a procedure with sandblasting, you have to install it that way in the field. For most composite installing companies, that’s a third-party activity. So you’re either leaning on your client and bugging them to bring in a third-party blaster that they already have a contract with, or you’re seeking one out. You’re qualifying them from a safety aspect, you’re qualifying them from a quality aspect. A lot of that takes time and resources to make sure that you select the right third-party contractor. So what we’ve done is we’ve taken all of our expertise and emphasis on surface prep, and we built our own grid blasting skid that we can take with us to any project that requires more than a hand prepping tool. So if we’re doing fittings, if we’re doing an elbow or tee, a lot of that’s still going to be handcrafted. But when we do now, when we do large volume piping repairs with composites, we have our own composite grid blasting skid that we take out with us every time, and our team is trained on how to use it following a competency system as well. And then we can execute the jobs much faster and also deliver that productivity and savings back to the client because we’re not including that third-party contractor and all the time and resources that go into qualifying that person.
Don Cooper 1:09:20
You’re eliminating two or three people out of the project and all the complexity of coordinating because it’s actually the same team who is doing the prep and the install in this approach, right?
Chris Coombs 1:09:33
Exactly. So if there were two major wins from our perspective, it’s that what you just described, but then think about it from an ownership standpoint. When a third-party grip blaster is hired to blast the pipe and then when we wrap it, they’re leaving. Now we can inspect that and ensure that they blasted it to the right criteria. But I think it takes a different form when the person who’s been blasting is also the person who’s responsible for the repair. It just really increases that accountability that you’re going to do it right. Not only are you going to do it right, you know how it needs to be done because you’re also an expert in installation as well.
Don Cooper 1:10:15
Yeah, I mean, it’s a simple optimization of that process, but I think it has a whole bunch of different benefits for the owner: productivity, savings, quality, accountability. And ultimately, the installers are inspecting and looking for a particular surface prep and a particular anchor profile. Now they can make sure that they get it without any rework.
Chris Coombs 1:10:43
Absolutely. Alright.
Don Cooper 1:10:46
Great conversation, Chris. Lots of owners out there are going to be curious. They are probably all trying to figure out how they can start to leverage this, how they can develop their process, how they can implement this system. How can you help them?
Chris Coombs 1:11:05
You know, as an installer, we can be that easy button when it comes to all the installer responsibilities and accountabilities inside the new legislation, inside AV 539. That’s just to give it like we can ensure that we’re providing competent people and we’re providing the level of detail. We’re ensuring that you’re compliant for those areas. I think that’s a basic level of how an installer can help. But because we were so involved in the industry group and developing the document and understanding the intent of it, I think we can help you at any stage. If you’re struggling with creating the wording for your own Quality Management System or somewhere in between that and the execution, and whatever stage it’s in, we can help. If it’s just getting you started, if it’s helping you pick the right pilot project internally for you to start, or if it’s just walking with you through the registration process or through your own Quality Management System and writing that section of the document, I think we can help in a number of ways.
Don Cooper 1:12:27
The Easy Button from start to finish. Whatever help you need, we can lend a helping hand. Right?
Chris Coombs 1:12:56
Exactly. Even now, absolutely. We’ve got there, and it’s now about executing within the scope that was carved out. And in a very short time, we’re going to be pushing for more. We’re going to be pushing for those through-hole defects that are non-Category D to be added to the legislation. We’re going to be pushing for that design length for that five-year design life and not just being held to one or two. But this is the starting point, and it’s a great place to start with more adoption and more use and more need to extend those asset lives. We’re going to get much more freedom to use this product inside Alberta and throughout Canada.
Don Cooper 1:13:42
Awesome, exciting times for the industry, and looking forward to helping lots of clients do this. Alright, thanks, Chris. Thanks for being on the show.
Chris Coombs 1:13:53
Yeah, no problem. Anytime.
