Imagine having a pressure vessel that has a MAWP of 300 psi and yet there is no high-pressure alarm before 300 psi is reached. How would an operator know he/she is approaching their consequence limit? As I wrote about earlier this year, a well-designed process will have both alarms – BEFORE the safe upper/lower operating…...
Any individual or facility that possesses 10,000 lb. or more or more of ammonia (anhydrous)—expected to be less than 10% water—must report their chemical holdings to DHS. DHS regulates security at high-risk chemical facilities under the Chemical Facility Anti-Terrorism Standards (CFATS) program (6 CFR Part 27). CFATS ensures high-risk facilities have security measures in place to…...
Incident summary A worker was completing a pressure test on the coil tube connector. The worker was positioned over the well head and was inadvertently contacted in the face by the test pipe, sustaining fatal injuries. Sequence of events… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log...
All too often, when we ask for the “ventilation design basis” (1910.119(d)(3)(i)(E)) we are given some calculations from a 3rd party engineering group. These calculations demonstrate the fan sizing for the necessary air exchanges and flows; however, what these calculations do NOT provide us is the full design basis for the ventilation system. For me,…...
The United States Court of Appeals, FOR THE DISTRICT OF COLUMBIA CIRCUIT has reversed EPA’s delay of the RMP Amendments. In its decision the courts states:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Are you tired of paying a consultant to prepare and submit your Risk Management Plan (RMP)? How about learning how to perform your Off-Site Consequence Analysis using FREE software? This course will teach you how to use RMP Comp software to determine your WCS and ARS distances, abiding by all the EPA requirements, and then…...
This week we saw an MC-331Tanker carrying Propane (i.e., LPG) rear-ended another truck on an interstate. The accident caused an immediate breach of the container and fire, which led to a BLEVE minutes later. This video contains the best footage I could find showing the actual BLEVE from two different directions of view and the…...
Pursuant to the risk management program regulations, the owner or operator of a regulated stationary source is required to submit a correction within one month of any change in the emergency contact information (40 CFR §68.195(b)). What should the owner or operator do for the required correction if they do not have a replacement contact…...
WARNING! NEVER, in your wildest dreams, EVER EVER do this!!!! But this video does show us the flammable properties of ammonia gas. Crazy I tell ya, just crazy – not to mention this is just NOT the way Hot Work was intended to be carried. SO MANY concerns – but I just wanted to demonstrate…...
This is a telling video, showing us the consequences of “slugging a compressor” with liquid anhydrous ammonia. I do not have the details of the event, but one would have to consider the cause being a “High Level” in the vessel the compressor is intending to pull vapor from. These vessels should have level control…...
At 4:45 p.m. on December 27, 2017, an employee was adding piping from a man-lift to a chemical tank when he struck a transducer on a nearby chemical tank containing tetra-methyl ammonium hydroxide. The employee was drenched and was able to lower the man-lift and get into the emergency wash station. Several co-workers assisted the…...
When I was growing up in the profession, PSM was the king standard we lived by. Everything we did revolved around our Process Safety Management System. One thing that I continue to find is facility personnel not assigned to the process and contractors working within the covered process “battery limits” and never knowing what they…...
