The Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards (CFATS) impose comprehensive federal security regulations for high-risk chemical facilities. Do the CFATS alter the requirements that apply to a facility covered under both CFATS and either the Emergency Planning and Community Right-to-Know Act (EPCRA) or the Clean Air Act §112(r) (i.e., the Risk Management Program…...
CFAT Impacts on EPCRA and RMP Read More »
The current list of delegated states and counties is: NOTE: Kentucky, Puerto Rico, and the Virgin Islands no longer implement the program, and the regional office has taken over the implementation of those areas…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
During a recent design review, we encountered some questionable “normal breathing” designs. I have always used the simplest of tests to ensure the tank has ADEQUATE venting during filling and emptying. Although OSHA allows the designer to use API 2000 (1968) or “other accepted standards,” the simplest test is that the VENTING capability MUST be…...
“Normal venting” for aboveground tanks Read More »
“We were doing some cleaning at the end of yesterday. I boiled some water in the HLT to pump through the heat exchanger. At the end of the day, there were 40-50 gal left in our 3bbl HLT. I turned off the heat and went home for the night. The next morning, I came into…...
Condensing water vapor creates a vacuum, destroys tank Read More »
An ISO container, partly filled with Monoethylene Glycol (MEG), imploded on the back deck of a ship, spilling around two cubic meters (528 gallons) of MEG onto the deck and to sea and causing unrepairable damage to the tank itself. There were no injuries. The tank was a 26-cubic-meter tank containing ten cubic meters (6600…...
Implosion of ISO container during transfer (Vent valve NOT opened) Read More »
The following incident is a precautionary example of the potential hazards of improperly depressurizing piping to remove a hydrate. During production operations, a control room operator observed a decrease in gas lift pressure supplied through a pipeline to a remote well location. The control room operator notified the onboard platform operators of the pressure drop…...
Line Break gone bad (Hydrate) Read More »
The Emergency Planning and Community Right-to-Know Act (EPCRA) requires businesses that store and/or manufacture, process, or use certain chemicals to complete the Tier II (EPCRA 311 and 312) Report and/or the Toxics Release Inventory (EPCRA 313) Report, also called the Form R. Section 112(r) of the Clean Air Act focuses on risk management for accident…...
Comparison of Tier II, TRI, and 112(r) Requirements (TCEQ) Read More »
I have written many articles discussing evacuating hazardous materials from a piping system. Over my career, I learned that using an open-top container can have disastrous results. It may sound silly or petty, but when something fails in the tasks and the hazardous material erupts from the open-top container, making contact with the worker(s), you…...
Its the little things that matter… open top or bung top container Read More »
Two people were severely injured after a Nitrogen cylinder catastrophically failed during refilling/pressurization. Person 1 shut off the air and nitrogen gas supplies before yelling to the workshop to call the HSE leader (nurse). Person 2, who was holding the cylinder, suffered severe injuries to his legs and one hand. Person 3 was injured when…...
Nitrogen cylinder catastrophically failed during refilling/pressurization Read More »
The investigation has found that the direct cause of the leak was corrosion under the insulation in a 4″ pipe for heavy naphtha from the distillation tower. The lack of inspection and repair meant that the corrosion had continued long enough for a hole to form in the pipe. Piping and equipment in a refinery…...
CUI leads to 1,100 gallon Naptha release Read More »
A Y-shaped strainer (filter) in a three-inch pipe ruptured. The failure occurred after pressure cycles induced by thermal expansion. The released isobutylene resulted in a gas cloud explosion and the company’s bankruptcy. Aspects: When a closed system filled with a liquid hydrocarbon raises the temperature, the pressure can rise above the design. Here, a brittle…...
The critical role a Hydrostatic RVs can play Read More »
Line Break is commonly associated with OSHA’s Highly Hazardous Chemicals in its PSM standard and EPA’s Extremely Hazardous Substances in its RMP rule. But SAFTENG members know I use Line Break Safe Work Practice (SWP) outside the PSM/RMP process battery limits. I apply this SWP to energy sources such as steam and even water when…...
Line Break gone bad (Water Truck) Read More »
