Bryan Haywood

ASME PCC-1 offers training guidance for personnel assembling and disassembling flanged joints

A RAGAGEP, which is often overlooked for pipe flanges but is fair game for OSHA and EPA to reference, is ASME PCC-1, Guidelines for Pressure Boundary Bolted Flange Joint Assembly.  The RAGAGEP outlines the training personnel needs to safely assemble and disassemble flanged joints in hazardous material(s) piping circuits.  A facility with flanged piping should…...

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QA/QC for flanged joints

Training and qualified personnel must assemble flanged joints in hazardous materials piping systems (see Appendix A of ASME PCC-1). Consideration should be given to establishing a finished joint examination process as part of the facility’s QA/QC assurance program.  A leak or failure in a piping system can be a minor inconvenience for low-consequence fluids, or…...

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API 574 expands coverage to include a new section on piping support systems

There are many different pipe support designs, types, and styles. They include hanger type, support shoes, saddles, bearing surfaces (e.g., structural members, concrete plinth blocks, etc.), spring type, dummy legs (trunnions), slide plates, sway braces/snubbers/struts, stands, sleeves, rollers, straps, clamps, and restrictive guides or anchors. An understanding of the function and design of pipe supports…...

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Insurer not required to pay for fire where sprinkler was off

Here is the summary of the Apeals Coourts decision, and this was NOT a red tag program issue.  This was an INSPECTION and CORRECTION issue!!! Here is the summary of the decision from the United States Court of Appeals for the Seventh Circuit. Appellants Fun F/X II, Inc. and Cao Enterprises II, LLC (collectively “Fun…...

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PIFs and Error Traps

Performance Influencing Factors (PIFs) is another term, from across the pond, for error traps.  You will see me use these terms interchangeably in my HF postings, as I was formally trained to use the term PIFs, but these days it seems we use the term trap.  But after spending a year working with an organization…...

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Was it “technical failure” or “human error”?

In light of the tragedy in Greece this week, I think it is time to share this video from Lund University’s College of Human Factors Engineering again.  Be sure to check out all of Johan Bergström’s videos on YouTube.  A term in HFE seldom gets mentioned during accident investigations, as most will say it, “muddies…...

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API 574 now covers MI inspection/testing on hoses

Flexible hoses are often used to temporarily transfer hydrocarbons and other process fluids to facilitate turnaround activities (clearing equipment, de-inventorying, purging, etc.) and transfer process fluids/products to rail cars and/or/or tanker trucks for shipment. Flexible hoses may also be installed within process piping systems to mitigate the effects of thermal expansion, vibration, or movement during…...

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Flanged piping connections and a RAGAGEP’s inspection basics

Facilities should have a written program to ensure flanges are properly made up. Proper makeup of every flange in a piping system is important for reliability. Proper makeup includes: … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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API 574 defines “Critical Check Valves” and 570 scopes their necessary inspection

The ever-controversial “check valve” has now been defined as to when it should be formally included in the piping MI inspection process.  As we have discussed many times, if we claim a check valve in our PHA and/or SOP as a “safeguard,” then by all means, this valve has been defacto identified as a “safety…...

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For toxic endpoints, are milligrams per liter (mg / L) equivalent to parts per million (ppm)? (EPA RMP FAQ)

The endpoint concentrations for regulated toxic substances under the risk management program rule (40 CFR Part 68 Appendix A) are listed in units of milligrams per liter (mg/L). Is this equivalent to parts per million (ppm)?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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What measures qualify as “passive mitigation”? (EPA RMP FAQ)

Passive mitigation is defined in § 68.3 as “equipment, devices, or technologies that function without human, mechanical, or other energy input.”… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Determining thresholds for different chemicals in interconnected vessels (EPA RMP FAQ)

According to the definition of “process” in 40 CFR §68.3, any group of vessels that are interconnected is considered to be a single process. If a stationary source has two interconnected vessels and one contains 6,000 pounds of BUTANE while the other contains 6,000 pounds of PROPANE, is this a covered process under 40 CFR…...

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