Chemical Process Safety (PSM/RMP)

“Leak Checking” new and modified piping

One of the top questions I get in my process safety circles is… Do we have to pressure test/leak test piping that has been opened/modified before we re-introduce the HHC/EHS to the piping? I turn to one of my favorite sources for RAGAGEPs, NFPA, and one of the best NFPA codes is NFPA 58, which…...

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CSB marks the 20th anniversary of the BP Texas City Refinery

The U.S. Chemical Safety and Hazard Investigation Board (CSB) marked the 20th anniversary of the fatal explosions and fires at BP America Texas City Refinery in Texas City, TX, that occurred on March 23, 2005. The tragic incident resulted in the deaths of 15 people and injuries to 180 others.  To remember this deadly event,…...

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3-Way Valve under Hydrostatic RV?

Processes that handle Liquified Pressurized Gases are required to have Hydrostatic Relief Valves on liquid piping where the liquid can be trapped. Much like vapor/gas phase Pressure Safety Valves, it is frowned upon when we have an intervening valve under the PSV. However, many codes today ALLOW us to install a 3-way valve below the…...

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Temporary SOP or a Car-Seal or Both?

The arrangement below is very common in processes/systems. This simple yet common arrangement causes havoc in hazard analyses. As the title states, is this arrangement managed with a Temporary SOP, a Car-Seal, or Both? The issue is that the motorized valve is tied to a Hi-Hi level alarm and interlock. When the vessel archives its…...

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How many locks do we need to Lockout a Double Block & Bleed arrangement

Several clients design Double Block and Bleed (DB&B) isolation into their process, especially when they know they will regularly enter certain Permit-Required Confined Spaces (PRCS). When these DB&B arrangements are part of the design, the isolation valves and the bleed valve are near one another. This allows us to use a single lock with some…...

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Did we learn from the Stapleton Air Port Tank Farm Fire (1990)

Contributing to the severity and duration of the fire was the lack of storage tank fail-safe control valves and internal fire valves and the location of the control building in the containment area where fuel leaks are likely to occur. The National Transportation Safety Board determined that the probable cause of the fire at the…...

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Secondary Containment and “Equalization” of tanks

I think most EHS professionals will agree that bulk tanks of hazardous materials need some means of “secondary containment”. This practice has been in place for my entire career and rarely gets challenged. However, in recent years I have come across several scenarios where either the facility/unit designed the process to function this way or…...

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CSB Releases Second Update into Fatal Hydrogen Sulfide (H2S) Release at PEMEX Refinery in Deer Park, Texas

Today, the CSB released a second update on its ongoing investigation into the fatal hydrogen sulfide (H2S) release that occurred on October 10, 2024, at the PEMEX Deer Park Refinery in Deer Park, Texas. Two contract workers died during the incident, and over 27,000 pounds of toxic hydrogen sulfide gas were released. Local authorities issued…...

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If we are not trending the findings from our 3-year PSM/RMP audits, WTH are we doing?

We see this far too often… a management system failure related to 3-year PSM/RMP audits. A company with multiple facilities should be “trending” its 3-year audit findings to IDENTIFY opportunities for improvement across the company. I did this years ago when I was a member of the Corporate EHS Team for a semi-conductor. And was…...

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Failing to control flammable vapor results in severe injuries for by-stander (video)

A video I posted over two years ago has come full circle. A citizen (some may call him homeless) was allowed to sit (and smoke) within 20′ of a gasoline tanker unloading operation at a gas station. His actions may not have been his sole demise, as we can see in the video evidence that…...

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CSB Issues Final Report into 2023 Fire at a Renewables Facility in Martinez, CA

Fire Severely Burned an Employee and Resulted in $350 Million in Damages The CSB released its final investigation report into the November 19, 2023, fire at the renewable diesel facility in Martinez, CA.  The incident seriously injured one employee, who suffered third-degree burns over most of his face and body and resulted in approximately $350 million in…...

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The CSB releases Volume 2 of its Incident Reports

Volume 2 covers 25 serious chemical incidents in 14 states: Arkansas, Alabama, California, Colorado, Connecticut, Illinois,  Louisiana, Mississippi, Nebraska,  Nevada, New Mexico, Ohio, Oklahoma and Texas.  These serious incidents resulted in 7 fatalities, 23 serious injuries, and approximately $1 billion in property damage. Link to Volume 2: http://www.idevmail.net/link.aspx?l=1&d=86&mid=421120&m=2672 The reports give the public important information about…...

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