Chemical Process Safety (PSM/RMP)

Implosion of ISO container during transfer (Vent valve NOT opened)

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…...

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Line Break gone bad (Hydrate)

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…...

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Comparison of Tier II, TRI, and 112(r) Requirements (TCEQ)

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…...

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Its the little things that matter… open top or bung top container

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…...

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Nitrogen cylinder catastrophically failed during refilling/pressurization

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…...

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CUI leads to 1,100 gallon Naptha release

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…...

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The critical role a Hydrostatic RVs can play

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…...

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Line Break gone bad (Water Truck)

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…...

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Examination and Testing of NON-metalic piping systems (ASME B31)

How times have changed in 30 years regarding “materials of construction” in hazardous materials processes.  I grew up in process safety, seeing nothing but metallic piping systems; today, I bet I see piping systems made from non-metallic products upwards of 25% of the time.  This is becoming increasingly acceptable in one specific process I do…...

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What am I saying when I sign-off on the first line of my PSSR? (Piping)

Most PSSR forms we encounter simply regurgitate OSHA’s 1910.119(i)(2). If the user is thoroughly knowledgeable of what each of these four (4) line items entails, we may be able to execute the PSSR appropriately. Let’s look at these four line items, especially the first line. 1910.119(i)(2) The pre-startup safety review shall confirm that prior to…...

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ASME B31 Examination vs. Inspection

The two (2) terms sound similar and will conjure up similar images when we hear them, but they are used in the ASME B31 piping standards in very different ways and apply to different groups. To state it very simply, the EXAMINATION is what the owner/operator does to pass the INSPECTION, which is what the…...

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Corroded internal tube in Heat Exchanger leads to NH3 release

An internal failure of a heat exchanger caused ammonia gas to leak through and absorb into the circulating liquid brine for the underfloor loop. The ammonia within the liquid brine spilled out of the expansion tank, pooling within an open sump in the mechanical room. The heat exchanger needed to be replaced as it was…...

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