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AVOIDING FAILURE: ACHIEVING SUSTAINED BENEFITS FROM ADVANCED PROCESS CONTROL APPLICATIONS

Al-Ghazzawi is a process control and simulation specialist candidate in Saudi Aramcos Advanced Process Control Unit, Process & Control Systems Department. He has an MS degree in control engineering from King Saud University and has been with Saudi Aramco for nine years. His experience includes process automation projects, multivariable control implementation, inferential modeling and data analysis. Al-Ghazzawi has published several papers in international journals and conferences, as well as the Saudi Aramco Journal of Technology. Anderson is a process control specialist in Saudi Aramcos Advanced Process Control Unit, Process & Control Systems Department. He has a BS in Chemical Engineering from Brigham Young University in Provo, Utah. Anderson has more than 23 years of experience in process and process control, including multivariable control, compressor controls and digital control systems in the chemical, gas and refinery industries. Anderson has been a Saudi Aramco employee for 18 years. For six years, he was with Dow Chemical, working on process and advanced control projects. Al-Soudani is an advanced process control engineer in Saudi Aramcos Automation and Control Systems Unit of the Yanbu Refinery. He has a BS in chemical engineering from the King Fahd University of Petroleum and Minerals. Al-Soudani has eight years of experience with Saudi Aramco in the fields of process modeling, dynamic simulation and process control. He has published several papers in international journals.

Ashraf A. Al-Ghazzawi

James E. Anderson

Tareq M. Al-Soudani

ABSTRACT
The oil, gas and chemical manufacturing industries have poured significant investment into advanced process control (APC) over several years to optimize operations. These control technologies include multivariable model predictive controls that bridge process models, control and unit optimization. Within a few years, these control applications often lose their ability to provide optimal profitability due to a variety of reasons. These include process modifications, changes in raw material and product specifications, the commissioning of new downstream units, the degradation of regulatory controls, a lack of training, insufficient monitoring and a business detachment among planning, engineering and operations. This paper presents an example of control remediation projects Saudi Aramco has undertaken and completed to bring the installed APC back to achieving their full potential benefits. This paper also describes the factors that led to the deterioration of control benefits, steps taken to rectify the problems, many challenges that face such efforts, how they were overcome if at all and finally, the strategies implemented to avoid future failures.
Advanced Process Control Installations

From 1994 - 2003


70 60 50 40 30 20 10 0 Total Failed
Applications Controllers

Fig. 1. APC applications in Saudi Aramco.

INTRODUCTION
In 2001, Saudi Aramco initiated an accelerated program to implement APC applications at various company-operated refining and gas processing facilities. For the purposes of this paper, multivariable model predictive control (MVC) is synonymous with advanced process control (APC). The terms can be used interchangeably. A number of APC projects have been completed, and more projects are expected to be commissioned in the next three to five years. Although tremendous resources are allocated to implement these projects, Saudi Aramco is paying considerable attention to the support and performance monitoring of previously-installed APC applications. The need for postimplementation support has been prompted by the inability of some applications to sustain the original benefits achievable after the initial installation. Saudi Aramcos first APC implementation was commissioned in 1994. A few other APC projects were completed at other facilities in the following years. The companys experiences with these initial projects are not different from those of other international oil companies; a few applications operated successfully for some time before service factors began decreasing, and eventually, they fell into disuse due to unsatisfactory performance. Fig. 1 shows the total applications and controllers installed in Saudi Aramco since 1994, along with the applications and controllers that have required remediation due to their failure to perform. Note that an application may be

comprised of several controllers. Fig. 1 indicates that from 15 to 20 percent of the APC installations have failed. Failure is defined as complete disuse of an APC application. The companys experience with APC applications over 10 years raised the need to focus on the performance monitoring and continuous support of these applications, rather than only focusing on the implementation of new projects. This reached a critical stage when management began to question the value of new APC applications after they saw previous ones in their operating plants providing little benefit and sometimes accompanied by negative comments from console operators. The next section describes factors that led to the eventual failure of some applications, followed by the steps Saudi Aramco has taken to minimize or avoid future APC application performance problems. One considerable concern is the degradation of the performance of APC applications that may never completely fail but are performing suboptimally. The three-fold motivation behind this renewed support focus is based on: 1. Protecting the original APC investment; 2. Capturing the original and full economic benefits that are usually sustainable from year to year and generally have a rate of return many times over the original investment; and 3. Capturing the intangible benefits that are oftentimes difficult to quantify, such as increased process stability, greater operational reliability, increased safety and reduced equipment wear.

C O N T R I B U T I N G FA I L U R E FA C T O R S O F A P C A P P L I C AT I O N S
There are seven leading factors that contribute to poor performance or failure of installed APC applications based on Saudi Aramcos experience: 1. Lack of properly-trained support personnel;

60 SAUDI ARAMCO JOURNAL OF TECHNOLOGY SUMMER 2004

Fig. 2. Kerosene stripping steam controller valve stiction trend.

2. Significant process modifications and enhancements; 3. Lack of performance monitoring of APC applications; 4. Poor tuning and models; 5. Unresolved basic control problems; 6. Lack of standards and guidelines to direct APC support personnel; and 7. Lack of collaboration and alignment among the organizations associated with the operation of the APC application. Each of these factors is further developed in the following sub-sections.

modifications and enhancements come from a variety of sources, including different feedstock material, changing business targets and product specifications, new equipment, changes in upstream or downstream operations and de-bottlenecking projects. These items may result in new limits and constraints which, if not properly addressed, reduce the ability of the application to effectively control and optimize the plant. The entire design of the APC application may need to be re-considered depending on the modifications performed.

L A C K O F P R O P E R LY- T R A I N E D P E R S O N N E L
This includes a deficiency of dedicated and competent process control engineers to support, monitor and maintain installed APC applications. This deficiency naturally leads to poorly-trained operations and other engineering staff, since the process control engineer is the main trainer of APC technologies within a facility. Statistics compiled by Solomon & Associates show that more than 75 percent of the process industry believes that the lack of trained and experienced control engineers, as well as trained operators, is always a limitation to capturing control long-term benefits.

LACK OF PERFORMANCE MONITORING OF A P C A P P L I C AT I O N S


The old adage, A thing not measured is a thing not controlled is worth keeping in mind when considering performance monitoring. As the focus of the APC engineer turns more and more from project implementation to controller maintenance, a monitoring and diagnostic tool is required to effectively check the health of APC applications and to provide troubleshooting capabilities. Saudi Aramco has, to date, used four different APC products in its multivariable control implementations. The vendors of these products offer various performance-monitoring packages that differ widely in functionality. A monitoring tool is essential to check APC status and diagnose problems in a timely fashion. Remediation efforts can then be taken to keep the APC applications on-line with optimal results.

S I G N I F I C A N T P R O C E S S M O D I F I C AT I O N S AND ENHANCEMENTS
In a competitive environment, it is assumed that continuous process modifications and enhancements are required to meet product demands and corporate profitability. These modifications generally increase model and inferential error by impacting the dynamic models that were initially developed from actual plant testing for the APC. These

POOR TUNING AND DEGRADED MODEL QUALITY


A multivariable predictive control application typically contains dozens of tuning parameters that may require

SAUDI ARAMCO JOURNAL OF TECHNOLOGY SUMMER 2004 61

periodic adjustments. Inappropriate choices of weighting factor, priorities, move suppressions, step sizes, economic cost factors, etc. will cause controller problems. Good model quality is critical to optimal performance. Poor model quality may be the result of non-linearities not taken into account, poor initial identification of models, unmeasured disturbances and process changes as discussed earlier. Model problems may also be the result of including models that should not be included (due to very small gains) or vice versa, or not including models that should be included.

This has resulted on occasion in missed opportunities for knowledge transfer and confusion on how to best structure support. A clear set of APC guidelines is needed that cover areas of project execution procedures, pre-audit and project justifications, post-audits, operator guidelines, plant control engineer guidelines and performance monitoring.
LACK OF ORGANIZATIONAL COLLABORATION AND ALIGNMENT

U N R E S O LV E D B A S I C C O N T R O L P R O B L E M S
The base or regulatory control layer consists of the field sensors and final control elements, such as valves. This layer includes the basic control on the distributed control system, (DCS) such as the proportional, integral and derivative (PID) controller. It may also encompass other forms of advanced regulatory control, such as cascade, ratio and constraint control. Common problems in this area include faulty instrumentation, non-functional analyzers, valve stiction and hysteresis, and unsatisfactory performance of the DCS-based regulatory controls. Fig. 2 shows the effect of valve stiction on the regulatory controls performance of a kerosene stripping steam controller in a crude distillation unit that was recently remediated.
LACK OF STANDARDS AND GUIDELINES TO DIRECT APC SUPPORT PERSONNEL

Successful APC implementation requires a team effort by members representing the operations, maintenance and engineering organizations of a process facility. The synergy among these groups is critical to sustaining long-term APC benefits. Engineering relies on field instrument personnel to maintain field sensors and elements. Operations relies on engineering for training and providing clear control objectives. Engineering relies on operations to keep the controllers on-line and to provide feedback on controller performance. It is important that each team member know his responsibilities as related to APC operation along with expectations of other team members. Any omission of cohesiveness among the organizations usually results in a loss of business direction. The impact on APC is manifested through a reduction in operating degrees of freedom within the controllers, disallowing full optimization.

A N A LY S I S O F D E G R A D E D P E R F O R M A N C E O F A P C A P P L I C AT I O N S
Saudi Aramco has experienced one or more of the above problems on various APC installations, which eventually led to their complete disuse. Table 1 shows the four APC applications, as shown in fig. 1, that have required remediation to return them to optimal operation. The table also shows which factors contributed most to the APC 3 Faulty instrumentation Lack of proper field sensors No continuity of support personnel APC 4 Improper design No continuity of support personnel Lack of instrumentation Process modifications addition of feed to overhead receiver

One of the problems identified by Saudi Aramco in the implementation and support of APC applications has been the lack of consistency across several projects and postinstallation support. Project steps performed at one plant may not be accomplished at another for various reasons. APC 1 Feedstock changes Changed type of distillation trays Lack of continuous operator training Start-up of previously mothballed downstream facilities No continuity of support personnel Increased condensing capacity APC 2 Poor inferential models Start-up of previously mothballed downstream facilities Lack of collaboration Feedstock changes

Table 1. Failure factors on APC applications.

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No. 1

Practice/Stategy APC Engineers Development Program

Failure Factors Addressed Lack of properly-trained support personnel Significant process modifications and enhancements Unresolved basic control problems Poor tuning and models Lack of properly-trained support personnel Lack of standards and guidelines to direct APC support personnel Lack of collaboration and alignment among the organizations associated with the operation of the APC application Lack of performance monitoring of APC applications Significant process modifications and enhancements Poor tuning and models Unresolved basic control problems Lack of collaboration and alignment among the organizations associated with the operation of the APC application Lack of standards and guidelines to direct APC support personnel Lack of performance monitoring of APC applications Lack of collaboration and alignment among the organizations associated with the operation of the APC application Unresolved basic control problems Significant process modifications and enhancements Lack of standards and guidelines to direct APC support personnel Unresolved basic control problems Lack of properly-trained support personnel Lack of collaboration and alignment among the organizations associated with the operation of the APC application

Central Engineering Support Organization for APC

On-line performance monitoring of APC applications

Corporate APC Standards and Guidelines

Team Alignment Process

APC Community of Practice

Table 2. Addressing preventive practices to APC failure factors.

degradation of the controllers performance. Furthermore, other challenges encountered during the implementation and support of some of these applications were related to the project execution methodology in which vendors were in complete control of all project phases, with minimal participation from company engineers. This resulted in very little, if any, hands-on experience and technology transfer. Other obstacles were related to a lack of appreciation and understanding of APC from the various entities within the operating facility, and therefore, absence of a dedicated team within the plant to coordinate and facilitate project activities.
STRATEGIES FOR AVOIDING APC FAILURES

Aramco has implemented six ways to avoid future failures: 1. APC engineers development program; 2. Central engineering support organization for APC; 3. On-line performance monitoring of APC applications; 4. Corporate APC standards and guidelines; 5. Team alignment process; and 6. APC community of practice (CoP). Table 2 shows how each of these practices is mapped to address one or more failure factors. These strategies and practices are discussed in further detail in the following subsections.
APC ENGINEERS DEVELOPMENT PROGRAM

The companys experience with varying degrees of performance degradation with APC applications raised the need to focus on various strategies that would counter the identified failure factors as discussed. Consequently, Saudi

It is well known that investments in process control applications have to be accompanied by investments in process control users and staff to reap and sustain benefits from applications such as APC. In 1998, Saudi Aramco launched the APC Engineer Development Program to

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APC Engineers in Development

LEVEL 1 APC ENGINEER Daily monitoring and support of APC applications. Ensure that economic objectives are current. Respond to operations, questions and concerns. Provide periodic training for console operators. Perform minor modifications to APC applications. These include tuning and minor model modification. Assist in the identification and justification of APC applications. Provide feedback to plant management on performance and value of installed APC applications. Serve as liaison among Operations, Maintenance and Engineering.

LEVEL 2 APC ENGINEER Service Level Agreements with plants. Support new APC projects implementation. Provide contract and procurement support and assistance. Provide support for major APC modifications. Coordinate and provide training for level 1 and level 2 APC engineers. Provide higher requirement needs of APC expertise and support. Coordinate software upgrades and new releases. Track industry trends in APC technology and evaluate new products.

60 50 40 30 20 10 0 1999 2000 2001 2002 2003 2004 2005 2006


Fig. 3. Number of APC engineers enrolled in the development program.

develop adequate in-house skills and resources to properly implement, support and maintain APC applications to achieve sustained benefits from installed applications at the companys Kingdom-wide facilities. The program objectives are: 1. Develop competent and self-reliant APC engineers at Saudi Aramco facilities capable of supporting and maintaining existing applications, in addition to identifying future APC applications opportunities at their facilities; 2. Implement APC applications at various company facilities as hands-on training for program participants; and 3. Ensure that APC application benefits are acquired and continuously sustained within the company. The APC Engineers Development Program is structured to provide a combination of both classroom training and hands-on experience. The major emphasis is on gaining field experience from active participation in the implementation and support of APC applications. The development program was significantly revised in 2002. The course curriculum was revised, and more emphasis was given to hands-on experience as the company pursues more in-house implementation projects. New classroom and e-learning training courses were added to the program, and a few of the core courses were revamped. New course material was developed during the program revision, and state-of-the-art process control education simulation tools are now used to enhance the learning process. In addition, advanced topics, such as distillation control and inferential models development were included in the curriculum. New candidates for the development program have been solicited every year since the program began. Presently,

Table 3. Duties and responsibilities of Level 1 and Level 2 APC engineers.

Saudi Aramco has 34 engineers enrolled in the program. Another recent improvement was the development of a set of APC Engineer Competencies to identify the skills an APC engineer needs to master. Competencies were developed to be aligned with individual development plans for program participants, and specific recommended assignments are outlined for every skill on the list. The role of Saudi Aramcos central engineering organization, Process & Control Systems Department (P&CSD), was expanded in the program. In this new role, P&CSD APC specialists and consultants conduct the majority of the training courses in the curriculum, serve as mentors for program participants, create the hands-on learning opportunities for program candidates and continue to supervise and administer the program. Fig. 3 shows the past and future planned growth of APC engineers. Eventually, Saudi Aramco will need an estimated 55 APC engineers. The majority will provide Level 1 support in plants, with about 12 others supplying second level support from a central engineering organization.

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No. 1

KPI Title ON and OFF status

Description Flag used to indicate whether or not MVC is turned on and being used to control a process unit. This is a Real Time indication only. Is a historical trend of the ON/OFF status for a controller. This KPI will have the ability to see a numerical value (in percent %) and a trend over a selectable time period of day, week or month. To measure how effectively the MVC is being utilized during the time it is in service. This KPI will have the ability to see a numerical value (in percent) and a trend over a selectable time period of day, week or month. Charts showing the number, distribution and identification of actively constrained Control Variables (CVs) and Manipulated Variables (MVs) over a time period. To monitor how well the controller is keeping key CVs at target and reducing variance in variables. This KPI will include standard deviations for CVs, CV target errors and CV limit errors. Verification of model quality by measuring unbiased predictions and prediction errors. Verification of inferential quality by trending inferential calculations against synchronized lab results. Track number of times that operator limits are changed over a one-week period. Excessive changes indicate trouble. To determine if the CV and MV steady-state targets are cycling. Cyclic trends are indicative of problems. To provide an indication of the economic benefits achieved by the MVC application.

Service Factor

Utilization Factor

Constraint Analysis

CV Statistics

Model Quality

Inferential Quality

Limit Change Frequencies for MV/CVs. Steady-State Targets Trend

10

Economic Benefit

Table 4. High-level APC performance key performance indices.

CENTRAL ENGINEERING SUPPORT ORGANIZATION FOR APC

ON-LINE PERFORMANCE MONITORING OF APC APPLICATIONS

The proven economic benefits associated with advanced process controls deployment prompted the central engineering organization of Saudi Aramco to organize an Advanced Process Control Unit. This units mission is to provide superior leadership in the application of APC technologies to capture and sustain profitable opportunities. The units vision is to be the recognized center of excellence in the application of APC technologies within Saudi Aramco. This unit has 13 APC engineers that provide consulting expertise for the planning, implementation and support of APC applications to all company facilities. These engineers are considered second-level support engineers, providing overall support to the Level 1 APC engineers that reside in the plants. Table 3 lists the duties and responsibilities of both first and second level APC engineers.

An organizations employees can never be sure of the success and effectiveness of its APC program without monitoring the performance of APC installations. Appropriate measures or key performance indicators (KPIs) must be defined, calculated from validated data and archived for retrieval by APC engineers that are responsible for ensuring that the APC applications are optimal. Saudi Aramco is piloting an APC performance-monitoring package that is based on internally defined metrics that provide high-level monitoring of multivariable controllers. The ideal single measurement for APC performance would be a comprehensive KPI that shows the economic performance of the APC. This would be the only necessary metric. However, in reality, due to rapid dynamics of a real process and industrial economics, any such economic measurement would only be very approximate and, oftentimes, a misleading indicator of the performance and

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Fig. 4. APC CoP website.

value of the APC. Therefore, several KPIs are required and, when used together, can be interpreted to give a reasonable picture of APC performance. Saudi Aramco has layered these KPIs in at least two layers, defined as a high-level layer and a lower tier. They should be simple and portray concise information. MVC is a complex control technology that is composed of many

components and sub-components. Monitoring such technology can be complex as well. The challenge is to identify KPIs that are of a high enough level to indicate controller degradation without confusion and without overburdening APC support engineers. They should provide immediate key statistics with the ability of the engineer to solicit additional information through lower-level KPIs

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APC Standard/ Guideline APC Execution Plan

DESCRIPTION This guideline covers the typical execution steps of a multivariable control implementation project. It starts with the preliminary design step and goes through commissioning, as-built documentation, and touches on training. It describes each step in detail and includes deliverables and personnel requirements. The Pre-APC audit guideline covers the assessment of the regulatory control layer, as well as identifies the process units where significant benefits may be realized from APC. This guideline provides the methodology to establish the pre-APC base case, as well as an estimate of the tangible APC benefits with an acceptable degree of accuracy. This guideline covers the routine tasks required by the APC support engineer to monitor and troubleshoot the installed application. Routine APC support tasks are associated with the four periods: daily, weekly, monthly and annually. The guideline describes in full detail the various tasks required by support engineers during the four periods. Post-audit studies characterize how well an advanced process control (APC) project satisfied its objectives. The post-audit guidelines present different approaches to benefits estimation as well as several guidelines to ensure a consistent basis of comparison between the before-and-after APC process information. To reap the most benefits from an APC application, it is necessary to monitor and analyze the APC application performance; in evaluating an APC project, it is necessary to evaluate the applications control, process and economic performance measures. This guideline also emphasizes the need to highlight intangible benefits, along with those that can be clearly quantified.

on-demand through trends and drill-down processes if the higher-level indices indicate a problem. The additional drill-down information and historical data could well be provided by either the original MVC product vendor or a third-party application. The high-level KPIs should be readily available at the engineers desktop through webenabled technology. Table 4 shows a set of 10 high-level KPIs identified by Saudi Aramco.

C O R P O R AT E A P C S TA N D A R D S A N D GUIDELINES
To address planning, implementation and support requirements for APC applications, Saudi Aramco developed a set of standards and guidelines to assist plants and central engineering staff in supporting installed applications. These guidelines cover APC routine monitoring and troubleshooting requirements, performance monitoring, post-audit and evaluation. These guidelines constitute the Saudi Aramco APC standard used to implement and support APC applications. Table 5 shows a list of APC standards and a brief description of their scope and purpose. Some are in the final phases of completion. It is important to note that these are not necessarily separate document standards, but rather topics or sections within a single standard.

Pre-APC Audits

Routine Monitoring and Troubleshooting Guideline

TEAM ALIGNMENT PROCESS


This is a planning process that helps establish highperformance teams that work effectively to achieve desired results. Through this process, team members work harmoniously toward a common mission and vision. Throughout the team alignment process (TAP), team members identify a number of high-leverage items that will assist in the transition toward the teams vision. Recent APC implementations at Saudi Aramco gas plants have greatly benefited from the TAP sessions that were held at the projects kick-offs. Project team members worked together in developing a project mission and vision statement, and they established a set of team norms to ensure team members are all committed and accountable to achieve their common purpose.

Post-Audits for APC Applications

APC COMMUNITY OF PRACTICE


As a part of the Saudi Aramco Knowledge Management initiative, an APC Community of Practice (CoP) was launched in 2003. The objective of the APC CoP is to establish a medium in which people can share knowledge and expertise, and are committed to contributing to the growth of the APC expertise within Saudi Aramco through a common mission and purpose. Saudi Aramco recognizes

Table 5. APC standards and guidelines.

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that such communities are leading-edge practices for creating and sharing knowledge. APC is a strategic tool for maximum profitability when implemented in refining and gas processing facilities; as stated earlier, the presence of competent support personnel is a fundamental requirement for achieving benefits from such applications. The CoP role is more than a common database where information is stored; it is viewed as one of the fundamental initiatives that will assist Saudi Aramco in becoming a recognized leader in the implementation and support of APC applications. Fig. 4 shows a screen capture of the APC CoP website. The APC CoP knowledge base structure includes: Standards and guidelines; Best practices; Technology alerts; Software tools and downloads; Lessons learned; FAQs; Success stories; Community events; Technical information; APC projects information; and People and contacts information. Events sponsored by the CoP include: Discussion forums; Technical exchange meetings; and Meet the experts sessions.

for avoiding APC application degradation has provided a successful methodology for protecting the original APC investment and ensuring the continuance of the high benefits achievable year after year with APC.

N O M E N C L AT U R E
Advanced process control Advanced process control unit Community of practice Distributed control system Frequently asked questions Key performance indices Multivariable control Process & Control Systems Department Proportional, integral, derivative controller Team alignment process APC APCU CoP DCS FAQ KPI MVC P&CSD PID TAP

ACKNOWLEDGMENTS
The authors would like to express gratitude and appreciation to Saudi Aramco management for their support during the preparation of this paper.

REFERENCES
Anderson, J.E., (1998). Robust Technologies Reduce Implementation and Maintenance Cost of a Multivariable Controller on a Crude Unit, proceedings of the Middle East Petrotech Conference, Manama, Bahrain. Anderson, J.E., (2001). Advanced Process Control Training: A Plan for Saudi Aramco to Achieve and Sustain Benefits Obtainable from Advanced Process Control Applications, Proceedings of Middle East Petrotech Conference, Manama, Bahrain. Ayral, T.E and S.J. Melville, (1993). Getting the Best Return on Your Process Control Investments, ISA Transactions. Friedman, Y.Z., (1992). Avoid Advanced Control Project Mistakes, Hydrocarbon Processing Journal. Al-Ghazzawi, A., J. Anderson and T. Al-Soudani, (2003). Avoiding the Failure: Achieving Sustained Benefits from Advanced Process Control Applications, proceedings of the Middle East Petrotech Conference, Manama, Bahrain. Solomon Associates, Inc., (1994). Worldwide Study of Optimization Process Control and On-Stream Analyzers in the Refinery Industry, Houston, Texas.

S U M M A RY A N D C O N C L U S I O N S
APC applications improve the profitability of plant operations. After APC applications have been installed and are operational, ongoing support of the APCs is required for long-term sustained benefits. Identified factors that contribute to controller degradation and eventual failure include a lack of knowledgeable and competent APC engineers, process modifications without associated controller modification, no performance monitoring to diagnose under-performing controllers, poor tuning and models, basic control problems, no defined standards and guidelines for APC work, and a lack of collaboration and alignment among the organizations associated with the operation of the APC applications. Saudi Aramco has adopted six specific strategies and practices to overcome these common failure factors. These encompass training, personnel development, organizational support, monitoring, formal guidelines, and open sharing of expertise and experience. At Saudi Aramco, the implementation of these practices

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