Chemical Process Safety (PSM/RMP)

CSB updates H2S Line Break Double Fatality – Contractor(s) Opened WRONG flange

Today, the U.S. Chemical Safety and Hazard Investigation Board (CSB) released an update on the agency’s investigation of a fatal release of toxic hydrogen sulfide gas at the PEMEX Deer Park Refinery in Texas on October 10, 2024, which killed two workers and injured 13 others. During a maintenance activity at 4:23 p.m., approximately 27,000…...

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A look inside the Caramel Processing area

Last week, we saw the devastation of a catastrophic failure of a pressure vessel (PV) in Louisville, KY. We still do not know the cause of this failure, just that it was a “cook vessel #6. SAFTENG members can see my breakdown of the photographic evidence available from the Courrier Journal (local Louisville newspaper). But…...

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Line Break/Equipment Opening GONE BAD (185F water)

Another example shows us that serious hazards can be found OUTSIDE of chemical processes, and applying the Line Break/Equipment Opening Procedure and Permit to these hazards could go a long way in controlling these recognized hazards. DEFINING and QUANTIFYING “hazardous energy” sources is STEP 1 in ensuring the process/system can be safely opened. Step 2…...

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True Facility Siting – Louisville Explosion

This Louisville explosion has started the debate about the plant being in a residential area. What most of the media and local politicians fail to mention is that the plant has been there since 1948. The neighborhood was allowed to build up around it because of lax zoning and spineless politicians. So to blame the…...

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My take on Louisville Explosion

The Courier-Journal has released more photos. Below is my analysis of these photos, using their and Google Maps road images. The first image below is the PRE-EXPLOSION image. In it, we can see the two (2) standing cooling towers/condensers. The one in the blue box is the one that was destroyed and came to rest…...

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Catastrophic Failure of Pressure Vessel (Again?)

This week, we saw a fatal explosion in Louisville, KY. This same facility, albeit under a previous ownership, had a catastrophic failure of a PV in 2003. The photos coming out of the post-analysis of this week’s event look to be a similar type of explosion. CLICK HERE to see the pics. Here is my…...

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EPA RMP FY 2024 PARTIAL YEAR RESULTS

Inspections As of the 3rd quarter of the fiscal year (Q3), EPA completed 133 CAA Section 112(r) (Risk Management Program) inspections. Enforcement Cases As of the 3rd quarter of the fiscal year (Q3), EPA took action at 73 facilities to decrease the likelihood of chemical accidents.  Sasol Chemicals: In April 2024, EPA finalized a settlement…...

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EPA’s RMP Emergency Drills vs. International Fire Code Drill Requirements

The EPA’s revisions of its Risk Management Plan requirements regarding emergency drills have gotten much attention.  However, they were always a bit behind when it comes to the International Fire Code.  And need I remind those of you reading this that many states have adopted the IFC in some form. A Group H occupancy is…...

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Pressuring Electrical Enclosures in HAZLOCs (NFPA 496)

One of the acceptable “protection techniques” for electrical enclosures within a Hazardous Location is to “pressurize the enclosure.”  Here are the three (3) Types of Pressurized Enclosures and the HAZLOC they are permitted to be used, and their design basis: NFPA 70, 500.7, (D) Purged and Pressurized. This protection technique shall be permitted for equipment in…...

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Proof Testing of Secondary Containment Systems (diking)

In process safety, we spend a lot of time discussing the PRIMARY containment systems; however, our secondary containment systems play a vital role in our PROTECTION and MITIGATION layers of protection. Of course, we want to keep the tiger in its cage, but we also need to be prepared for the day it gets loose,…...

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Emergency Stops: Machinery Safety vs Process Safety

When we encounter a manufacturing facility that has been pulled into OSHA’s PSM or EPA’s RMP, we are almost certain to find the same design features for the emergency stop functions (i.e., E-Stops). Most of these facilities are shocked to learn there is a big difference between the location of an E-Stop on a machine…...

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Are you functionally testing your Excess Flow and Check Valves as part of your PSSR and PM Program?

I believe in Excess Flow Valves and Check Valves, even though I have seen them fail more often than work as hoped. However, these failures are “human failures” in the incorrect design (e.g., sizing and placement) of the process where these valves are utilized. The valves are highly reliable when they are DESIGNED, INSTALLED, and…...

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