Chemical Process Safety (PSM/RMP)

Working in the area of a PRD discharge

I talk a lot about “safe locations” when we discuss Pressure Relief Device (PRD) discharge. The phrase “safe location” is used in just about every PRD RAGAGEP; however, none of them DEFINE or QUANTIFY the phrase, leaving it open to some poor designs. Here is a case where two workers were doing work 30′ under…...

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OSHA cites employer for doing pneumatic pressure testing rather than hydrostatic pressure testing (5A1 – Fatality)

On July 14, 2009, Employees #1 and #2 were performing a pneumatic test to verify leak tightness of a new pipeline meter station. The test medium was nitrogen gas, and the system being tested included piping and two (2) pressure vessels. Numerous leaks were found in the system during the test. The system reached the…...

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What am I seeing… Isolation of PRDs

I have these debates on a regular basis: ” We can not put an isolation valve before or after a Pressure Relief Device (PRD).” And that would be an incorrect statement. Yes, placing an “intervening valve” in a PRD path (before or after the PRD) can be risky; however, in some situations, these valves are…...

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LINE BREAK GONE BAD (R-22 & Compressor Oil Flash Fire)

At 11:00 a.m. on April 10, 2023, Employee #1, 55, was performing maintenance on the refrigerant lines of a Liquid Chiller used for air conditioning at an airport terminal. Employee #1 was removing the Electronic Expansion Valve (EEV) from the hot gas bypass line. The line contained R-22 refrigerant and compressor lubricating oil at a…...

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The power of decomposing Chlorine Dioxide (ClO2)

Chlorine dioxide (ClO2) gas is unstable and decomposes, sometimes violently, into Cl2 and O2 (with a 50% increase in gas volume). When storing chlorine dioxide (ClO2), it is commonly kept in CHILLED WATER because its solubility in water significantly increases at lower temperatures, making it more stable and allowing for higher concentrations to be safely…...

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When your local responders throw you “under the bus”

“Police told media outlets that the leak happened late Saturday night at Vanguard Culinary Group. Crews had a hard time reaching valves that were attached to three tanks, each of which holds up to 500 gallons of ammonia. Officials say the leak was caused by a failure in the plant mechanical system. No evacuations were…...

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Wisconsin updates its Mechanical Refrigeration State Code

Not everyone seemed comfortable turning over NH3 Refrigeration Codes and Standards to the IIAR. In November, Wisconsin updated its State Code on Mechanical Refrigeration. One of the requirements that caught my eye is the INSTALLATION INSPECTION documentation the state will require before issuing the operating permit: (2) INSTALLATION INSPECTION. … the following documents shall be…...

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UPDATE on CFATS

The Chemical Facility Anti-Terrorism Standards (CFATS) Program identified and regulated the security of high-risk chemical facilities using a risk-based approach. Pursuant to section 5 of the Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2014. Authorization had been granted for CFATS until July 27, 2023. Congress did not act to reauthorize the program…...

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OSHA cites API 510, 6.2 Inspection During Installation

I first wrote about this API 510 requirement in July 2019, and now OSHA seems to have caught on to this requirement; this year, they issued their first Citation against this requirement. Of course, the citation was related to a PSM-covered process. Here is the API 510 requirement for newly installed pressure vessels and the…...

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Pressure Test gone BAD (Fire Hose #2)

Employee #1, a firefighter, was performing a pressurized hose test on a 4-inch fire hose. The employee was standing at the pump panel of the fire truck next to the discharge point where the hose was connected by a 2.5-inch double female adapter to the 3.5-inch fitting on the truck. The hose was being brought…...

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Pressure Test gone BAD (Fire Hose)

On November 3, 2006, Employee #1, a firefighter/paramedic, was the designated pump operator during the performance of an annual hose test. The pump on the fire department apparatus was utilized to perform the test. Near the conclusion of the 5-minute 400 psi test, while Employee #1 was reducing the pressure in a hose being tested,…...

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Pressure Test gone BAD (Fatality)

On September 20, 2018, an employee was performing a pressure test of a residential sewer line when he was struck in the eye by a small piece of a pneumatic quick connection of a pressure test kit…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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