Folding Every Asset Into One Class and One Interval

• (1) The jet fuel line. The API 570 program covers metallic piping within the facility. The 3 mile buried run to the berth is a pipeline and belongs to a pipeline integrity program, not the piping inspection program. The inspector's job is to get the boundary defined in writing (typically the battery limit / first block valve at the fence) and confirm in the records that no section falls into a gap between the two programs. Coverage gaps at battery limits are a classic finding.
• (2) The impulse tubing. Metallic tubing is within the scope of the piping program, so it cannot be excluded on the grounds that it is small. Its inspection is visual and vibration-focused plus thickness where accessible; small-bore tubing fails by fatigue and vibration, not by general thinning, so the method matters more than the interval.
• (3) The FRP line. Nonmetallic piping is outside the scope of API 570. That does not make it uninspected: the owner-user must document a separate program for it (manufacturer data, applicable composite practices) and record the basis. Dropping it silently into the metallic piping program without an engineering basis is the wrong answer.
• (4) The flare header. In scope, and high consequence.

The response to the instruction is a written scope statement listing what is in the program, what is out, and where the responsibility for the excluded items sits.

It is not defensible. Classification is a consequence-of-failure judgment made per line or circuit, not a budget category. Inputs are the fluid (flammability, toxicity, reactivity), the operating pressure and temperature, the inventory, the potential for a release to reach people or to cause environmental harm, and how quickly the release could be detected and isolated.

• Jet fuel (in-plant portion) - flammable, large inventory, loading operations with frequent human presence: high consequence.
• Gasoline impulse tubing - small inventory, but a leak on a 300 psig gasoline line is a fire risk and a fitting failure can be a spray release; it is not a Class 3 item.
• Flare header - flammable vapor, plus wet corrosive service and deadlegs. A release here can be large and is hard to isolate: high consequence.
• Dilute sulfuric acid FRP - the consequence is environmental (pit, soil, sewer), which still counts.

Two further points. First, the class maximum interval is a ceiling, never a target; the actual interval is set from remaining life and can only be shorter. Second, a blanket Class 3 with one long interval implicitly assumes a near-zero corrosion rate for every circuit, and nothing in the folder supports that - most of these assets have no established rate at all.

The inspector should return the instruction with a proposed classification table and the consequence rationale documented, and note that what the budget actually buys is inspection coverage, not a classification.

The flare header is a wet, corrosive, intermittent-flow system with stagnant branches, which drives the location list:

• The two deadlegs, including the stagnant end and the connection where the deadleg meets the flowing header. Deadlegs do not see flow, so they accumulate condensate and corrode where the rest of the header does not; they are also a frequent location for the first leak.
• Low points and the bottom of the header, where aqueous condensate with H2S and other acid gases collects.
• Supports and contact points, where external water collects and coating breaks down.
• Small-bore connections and branch stubs on the header, for vibration fatigue as much as for corrosion.
• Upstream relief valve discharge lines / tailpipes, which see the same wet environment and are often forgotten.
• Insulated sections, if any, for corrosion under insulation.

The plan also needs a first survey to establish a baseline, because a header of this type usually has no reliable thickness history - and the starting assumption should be an unknown rate with a correspondingly short first interval, not the class maximum.