Chemical Process Safety (PSM/RMP)

The Jack Rabbit Test Program Trial Summary – NH3 and CL2 Release Studies

The releases were 1 ton releases (at least the videos in the presentation were the 1-ton releases).  The presentation does an EXCELLENT job showing how these two chemicals differ when released.  Along with the Seward, IL Ammonia video footage, this footage confirms that NH3 will act as a “heavier-than-air” gas when it is released in…...

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PSM Battery Limits – it may not be as simple as “Interconnected”

OSHA’s most recent PSM Letter of Interpretation (LOI) confirms their position on covered process battery limits. I struggle with this, as their position states, and I quote, “Neither the application paragraph nor the definition of “process,” states or implies that controls can limit the extent or boundaries of a PSM-covered process.” With this position, OSHA…...

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More OSHA PSM Citations on a NH3 Refrigeration Process (includes NO MOC on personnel changes!)

No mention if this inspection was an NEP, scheduled, or complaint; but 9 of 12 citations were PSM.  They include: 1) The employer did not develop P&IDs which accurately represent current equipment for the ammonia refrigerationsystem. 2) No periodic inspections of the energy control procedures at least annually. 3) The employer did not train affected…...

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Explosion of MDEA Storage Tank

In August 1999, an explosion in an MDEA storage tank at a Nitrogen Products plant in Alaska propelled the tank off its base and into the air.  The tank landed on an adjacent air-cooled heat exchanger filled with synthesis gas.  The impact of the tank on air-cooled heat exchangers initiated a second explosion and fire…....

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How did EPA select the list of regulated substances?

How did EPA select the substances to be included in their RMP rule? The chemical accident prevention provisions promulgated pursuant to Section 112(r) of the Clean Air Act (CAA) are designed to focus on chemicals that pose a significant hazard to the community in the event of an accidental release and to prevent and minimize…...

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Another valve that needs to be Car-Sealed OPEN

There is a “personnel safety” practice that is very common in the design of process plants, but it is not the best design for “process safety,” and I forgot to mention this in my earlier Car-Seal article. Here is the setup. Do you see anything wrong with the pressure gauge arrangement?… Membership Required You must...

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Vulnerability of oil contaminated fire retardant coveralls

Coveralls become oil-contaminated very rapidly in many work situations, particularly offshore, in some cases within one day. From time to time, there are significant hydrocarbon fires offshore (eg on the Rough Platform). There is evidence that frequent washing reduces the fire retardant properties of some materials, thereby increasing personal risk to persons and compromising their…...

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Contractors and chemical process safety?

In the chemical industry, we had things a bit easier when it came to defining our process battery limits and this made it easy for us to define who was a PSM/RMP contractor.  But things are not so easy in facilities where the PSM process is a small and not core to the business.  We…...

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Features of successful Safety Management System (SMS)

The following factors are critical to any SMS’s sucess. The SMS:• must be comprehensive and integrated with respect to the adopted control measures• must be implemented in practice and used as the primary means of ensuring safe operation• should be consistent with the understanding of risk gained from the Safety Assessment• should have sufficient focus…...

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Electrical Classification for Hazardous Locations

My line of work brings me into contact with a lot of hazardous locations.  Some weeks I feel I should just sleep in my FR coveralls!  But each month we find errors in hazardous location classifications that could have disastrous results.  This article is an attempt to bring to light some of the common errors…...

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How secure are your safety systems?

A large metropolitan zoo maintenance employee may have disabled a warning light on a small train that derailed in 2009, sending 22 people to the hospital.  The records are part of the evidence to be used in a February 2012 trial in which plaintiffs claim the zoo was negligent in its maintenance and operation of…...

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