Chemical Process Safety (PSM/RMP)

U.S. Court of Appeals for the Fifth Circuit finds that OSHA can’t cite for violations that were over 6 months old (PSM)

Delek purchased an oil refinery located in Tyler, Texas from Crown Central and took possession on April 29, 2005. Beginning in February 2008, OSHA conducted a four-month inspection of the refinery and issued a citation on August 18, 2008, finding violations of 29 C.F.R. § 1910.119 and other regulations that are not at issue here…....

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Safeguarding our piping (ASME B31.3, Appendix F)

Safeguarding is the provision of protective measures to minimize the risk of accidental damage to the piping or the harmful consequences of possible piping failure.  In most instances, the safeguarding inherent in the facility (the piping, the plant layout, and its operating practices) is sufficient without the need for additional safeguarding.  In some instances, however,…...

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Flanges and their joinment integrity

Three distinct elements of a flanged joint must act together to provide a leak-free joint: the flanges, the gasket, and the bolting Factors that affect performance include the following:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Changes to the 2015 IFC impact “Mechanical Refrigeration” requirements in a BIG WAY

The revisions to 2015 IFC, Section 606.12 clarify the code requirements and add references to two (2) International Institute of Ammonia Refrigeration (IIAR) standards and one American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc. (ASHRAE) standard for design and operation of ammonia refrigeration systems.  This edition of the IFC also pulls in a lot…...

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EPA’s Amended Risk Management Plan Rule (December 2016)

In an effort to provide you with the new language I have presented this material, cut from EPA’s early release document which was several hundred pages.  Here is what is actually changing in the rule:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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A breakdown of EPA’s amendments to their Risk Management Plan rule (2016)

My good friend and Ammonia Refrigeration PSM extraordinaire, Brian Chapin with RCE, has allowed me to share his work here.  I figured I could not have done any better on this breakdown so I asked if he minded I share this at SAFTENG, we lucked out and he said yes!  This is an excellent breakdown,…...

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Breaking down EPA’s new Emergency Response requirements for RMP facilities

EPA recently updated their Risk Management Plan (RMP) rule in several key areas:  1) accident prevention program requirements, 2) emergency response requirements, and 3) improvements to the public availability of chemical hazard information.  In this article, I will break down the NEW Emergency Response requirements and some serious barriers to fully complying with these new requirements…....

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Breaking down EPA’s revisions to the Risk Management Plan (RMP) rule

EPA in response to Executive Order 13650, is amending its Risk Management Program regulations. The revisions contain several changes to the accident prevention program requirements including an additional analysis of safer technology and alternatives as part of the process hazard analysis for some Program 3 processes, third-party audits and incident investigation root cause analysis for…...

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EPA finalized it’s Risk Management Plan Amendments

Today, the U.S. Environmental Protection Agency (EPA) finalized a rule amending its Risk Management Program (RMP) regulations to reduce the likelihood of accidental releases at chemical facilities and improve emergency response activities when those releases occur. This rule is the latest in a series of actions the federal government has taken in consultation with industry,…...

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2015 International Fire Code (IFC) and Hotwork Requirements

The 2015 edition of the International Fire Code (IFC) introduces how hot work on flammable and combustible liquid storage tanks shall be carried out and the requirements are quite specific.  And for those of you working in states that have adopted the 2015 IFC as your state fire code, I have posted ALL of the HW requirements from…...

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AWS updates Specification for AWS Certification of Welding Inspectors

The purpose of welding inspection is to determine if a weldment meets the acceptance criteria of a specific code, standard, or other document. The welding inspector must be thoroughly familiar with welding processes, welding procedures, welder qualifications, materials, the limitation of weld testing, be able to read drawings, prepare and keep records, prepare and make…...

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EPA issues new RMP FAQ – NFPA 4 Criteria

A stationary source has a mixture above the threshold. At standard temperature and pressure, the mixture does not meet the criteria for a National Fire Protection Association flammability rating of 4 (NFPA 4). At elevated temperatures and pressures, however, the mixture meets the NFPA 4 criteria. Is this process covered under the risk management program…...

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