These little safety devices cause such big troubles because of pure ignorance. I continue to have silly debates with very smart people about meeting the absolute bare minimums from so many different recognized and generally accepted good engineering practices (RAGAGEPs). As of today, I have written about Hydrostatic Relief Valves 84 times.
This week, I am back in my process safety saddle, helping a client with a release and a flash fire that seriously injured three (3) workers. Had it not been for their FRC PPE program we implemented several years ago, this could have easily been a triple fatality. Needless to say, I was confused when my old boss told me OSHA and EPA were asking a lot of questions and taking issues with the fact that the piping that failed did not have an HRV in place; however, the PSI RV data stated one was there, and the P&ID stated one was there AND the PHA listed the HRV for the “blocked in scenario.” If you have ever wanted to see how OSHA issues Willful Citations, here is a perfect example.