Pursuant to the risk management program regulations, facilities must perform an offsite consequence analysis for the worst-case release scenario. Do the quantities of two separate vessels that are interconnected with a closed valve need to be aggregated for the worst-case release scenario analysis?
A flammable substance listed in 40 CFR §68.130 is excluded from the risk management program regulations when it is used as a fuel or held for sale as a fuel at a retail facility (§68.126). What is the definition of fuel for the purposes of this exclusion?
For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity (40 CFR §68.25(b)). Are mechanical
The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. Do all facilities subject to
What I am going to suggest in this article is NOT necessarily a code or standard requirement, but just some SOUND ADVICE on how to improve safety around expansion/seismic joints where hoses are utilized to allow for flexibility. As my clients know, I HATE hoses in a chemical process and I am OCD when it
I have been doing process safety my entire career and I have had some of the finest engineers teach me process safety. Now those that know me, know I am just some dumbass western KY edua-macated safety redneck, but even I know the importance of intenral inspections on my PVs. I know only two (2)
UPDATED on 8/21/2019 with the 2018 IFC Commentary… I am guessing that someone has published a technical paper or article stating that an “electrical shunt” is no longer a code requirement for ammonia refrigeration engine rooms. This has caused several of my clients and subscribers to ask me if this is true as this goes
This $50 device is priceless in validating that the ventilation system is functioning as designed Verifying that a mechanical exhaust system provides sufficient airflow is critical for preventing the accumulation of flammable vapors. The use of a Vaneometer™ is ideal for monitoring low-velocity air currents (typically 25 to 400 feet per minute) at the face
The 2019 edition of the National Board Inspection Code (NBIC) has been available for purchase since July 1st, 2019. Here is a summary of the major changes:
This is another picture that was shared with me and is making the rounds on social media. It certainly appears to be a liquid (hydrostatic) expansion event on a stainless steel pipe. The story goes and I can certainly see this happening… Valve installed when hot out. Valve didn’t fully seat and allows vapor to
I have many questions about this picture but was told this was the results of a failed hydrostatic pressure test after a non-certified repair was made. Has anyone seen this picture before? Got an incident report to go along with the image? My source is very trustworthy, but I just would like to have an
PLEASE NOTE this case is significant in that many facilities in the OSHA arena will EXEMPT their “methanol” from PSM coverage using the “Atmospheric Storage Tank” exemption (e.g. 1910.119(a)(1)(ii)(B) or called the “Meer Decision”). EPA couldn’t care less about this OSHA exemption, as is evident in this case! There is NO EPA RMP exemption for flammable liquids stored
