Chemical Process Safety (PSM/RMP)

EPA fines the US Olympic Park for RMP violations related to their Anhydrous Ammonia refrigeration process

The Utah Olympic Park agreed to pay a $7,000 fine this month after an EPA inspection found violations with the nonprofit’s documentation for handling anhydrous ammonia, a regulated, toxic chemical used to refrigerate the bobsled track over the winter months.  PLEASE NOTE there appears to be some inaccuracies in this news paper article.  CLICK HERE…...

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EPA Region X RMP/EPCRA Actions April 1-June 30, 2012

The U.S. Environmental Protection Agency (EPA) completed 38 enforcement actions from April 1 through June 30, 2012 to ensure individuals, businesses, and governments comply with the nation’s laws that protect public health and the environment.  Of the 38 actions: – 2 were RMP related to Anhydrous Ammonia refrigeration processes for a total of $47,633 –…...

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Process Safety and “Critical Utilities”

What is meant by the term “critical utilities” when used in context with process safety?  I like to define the term as any utility that plays a safety role within the covered process.  Probably the most common “critical utility” is the use of nitrogen within a flammable liquid process, where nitrogen is used for blanketing…...

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Has EPA established a new selection criteria for RMP inspections?

This week EPA put out a news release regarding an RMP inspection at an Ethanol plant in CO.  But this news release had something in it that I had never seen before in the hundreds of RMP news releases I have read since 1999.  The news release contained a breakdown of the demographics within the…...

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MI Inspection of Anhydrous Ammonia Vessel (No PWHT)

Ask a group of experienced engineers in ammonia refrigeration, ammonia fertilizer, and eletrical utilities if Post Weld Heat Treating (PWHT) is needed for vessels used in Anyhydrous Ammonia service and you will get a varying degree of answers.  I am certainly not one to ask, but we do recommend PWHT for any new vessels put…...

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Now this is Process Safety Information!!

I think someone has awakened the giant within the USA Government Safety Agencies!  Below is a SUMMARY of the document request from the Federal Energy Regulatory Commission (FERC) to a business wanting to build a Gas Liquefaction Plant in Corpus Christi, TX.  For those involved in Process Safety, the list will be recognizable; but ask yourself… Would…...

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Flammable vapour cloud risks from tank overfilling incidents

This report documents research undertaken in 2007 and 2008 to examine the important factors affecting the production of flammable vapour in incidents where large storage tanks of volatile liquids are overfilled. This is an important output from the Buncefield response programme that was not published on completion due to constraints on HSL staff involved in…...

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Excellent depiction of PSM/RMP Process Arrangements

From OSHA’s PSM Preamble… The term “process” when used in conjunction with the application statement of the standard establishes the intent of the standard. The intent of the standard is to cover a “process” where the use, storage, manufacturing, handling or the on-site movement of a highly hazardous chemical exceeds the threshold quantity at any…...

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Pressure Testing vs. Leak Testing for Mechanical Refrigeration Processes

This article is meant to provide some guidance to mechanical refrigeration operators (e.g. ammonia refrigeration processes) as to when a “pressure test” is required and when a “leak test” is required and what are the specifics that have to be met in order to comply.  Not having performed a “pressure test” on field erected piping…...

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Inherently Safer Design (CSB Video)

The video discusses the four main components of inherently safer design as identified by the NAS study. They are substitute, minimize, moderate and simplify and are described as: 1) Substitute: replacing one material with another that is less hazardous; 2) Minimize: reducing the amount of hazardous material in the process; 3) Moderate: using less hazardous process conditions such…...

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Process Safety, Staffing, and responding to alarms

Earlier this year, the US EPA cited a company for not having trained staff on-site at all times the Extremely Hazardous Substance (EHS) or Highly Hazardous Chemical (HHC) is on-site in quantities that exceed the Risk Management Plan threshold.  The case (Click Here for my summary of the case) involved an ammonia distributor.  The only…...

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