Chemical Process Safety (PSM/RMP)

It is rare; I can not recall ever disputing NFPA in any of their guides/standards/codes.  However, section 27.7 of NFPA 30 is worded incorrectly and needs to be called out as it poses significant risks if followed by the letter.  Section 27.7 covers the pressure and leak testing of “flammable liquid” piping circuits.  Although I…...

If you want a spirited process safety debate, simply mention the practice of having “intervening valve(s)” before or after a Pressure-Relieving Device (PRD).  There are some who swear that it is not allowed, but in fact, it is.  This is how I learned about the “Car-Seal” program early in my career.  ASME B31.12 is one…...

As I dig deeper into ASME B31.12, Hydrogen Piping, I continue to find nuggets of best practices for HAZMAT piping.  ASME B31.12 requires each operating company having industrial piping, pipeline, and commercial and residential systems to have Operational, Maintenance, and Emergency Plan(s) that include the following:… Membership Required You must be a member to access...

I have been working with several clients who are on a Hydrogen Fuel journey. It is fun to get deep into process safety protection schemes regarding NFPA 2 and ASME B31.12 and see the similarities and extra code requirements when dealing with large H2 gas systems. One of the interesting items regarding H2 piping is…...

Occasionally, we see some pipe labeling requirements that exceed those found in ASME A13.1.  NFPA 2, 2023 has a few: (emphasis by me)… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

It is good that we are finding fewer and fewer facilities without pressure testing and leak testing records on their process piping.  But now comes the difficult question: Is pressure and leak testing required after maintenance or alterations on piping systems? So, most companies will have their newly installed piping pressure tested and leak tested…...

Ammonia is held for sale by a retailer in a large storage tank.  The retailer sells ammonia as an agricultural fertilizer and a coolant for air conditioning systems.   Section 311(e)(5) of EPCRA exempts from the definition of a hazardous chemical “(a)ny substance to the extent it is used in routine agricultural operations or is…...

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…...

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…...