This was a new pressure vessel that failed during its hydro test following its fabrication. The vessel’s Post Weld Heat Treatment was not properly conducted, when some parts of it did not reach the required temperature. Coupled with a small hydrogen crack, the failed post weld heat treatment was sufficient to cause catastrophic failure while…...
Post Weld Heat Treating (PWHT) failure Read More »
First, let’s define what this article is all about. Has your facility ever had a leaking flange? Just a tiny drip of liquid or a small release of gas? What is the most common response to this leaky flange? Someone goes out and tightens the flange bolts to stop the leak. This practice is done…...
ASME and Hot Bolting and Half Bolting Procedures Read More »
RMPs MUST be updated at least once EVERY five (5) years. Owners and operators responsible for RMP implementation should review the factsheet A Checklist for Submitting your Risk Management Plan (pdf). This factsheet provides a checklist to consider in updating and resubmitting RMPs. Use EPA’s RMP*eSubmit for your resubmissions. For additional information see the RMP*eSubmit Users’…...
Re-Submitting your RMP Read More »
Under the Clean Air Act, Section 112(r), the EPA established a program requiring facilities possessing greater than certain threshold quantities of 140 chemicals to provide risk management plans to the EPA.1 As part of this reporting requirement, facilities are required to determine the worst-case scenario release from a single chemical process, using EPA criteria and guidelines.2 Facilities…...
RMP Facilities in the United States as of December 2009 Read More »
An older post, with updates…Ever since the 2005 BP Texas City tragedy, refineries and chemical plants have been working diligently to review “facility siting” risks for their facilities. As with all of the PSM elements, many of us took this new focus as a learning opportunity. We had all done something we called “facility siting”…...
A reverse look at Facility Siting and Change Management Read More »
As we have discussed here many times, our piping is our “primary containment” that seems to be where the vast majority of Loss of Primary Containment (LOPC) events occur. Many reasons for this, which we have spelled out in other postings, but none the less the vast majority of “leaks” occur in our piping. One…...
PSM and RMP (e.g HAZMAT) Pipe Supports… how many and how far? Read More »
March 31, 2009 MEMORANDUM FOR: REGIONAL ADMINISTRATORS THROUGH: DONALD G. SHALHOUB DEPUTY ASSISTANT SECRETARY FROM: RICHARD E. FAIRFAX, DIRECTOR DIRECTORATE OF ENFORCEMENT PROGRAMS SUBJECT: Management of Organizational Change This memorandum addresses the application of 29 CFR 1910.119 (l), Process Safety Management (PSM) – Management of Change (MOC), to…...
Management of Organizational Change (OSHA Letter to RAs) Read More »
EPA can improve its program management and oversight to better assure that facilities covered by the Clean Air Act’s Risk Management Program submit or re-submit an RMP. EPA had not established national procedures for identifying covered facilities that had not submitted RMPs. For the 5 States reviewed, we identified 48 facilities in 3 States that…...
This article is for ANYONE with anhydrous ammonia, regardless if you have 100 pounds or 100,000 pounds of ammonia and your primary means of containment is Carbon Steel. I have written numerous times about the Stress Corrosion Cracking (SCC) failure mode and shared numerous accidents and alerts regarding this failure mode. In this article, I…...
MAJOR CHEMICAL DISASTERS IN INDIA Origin of accident Year Date Location Products involved Number of Deaths Injured Evacuated Explosion (warehouse) 1992 29.04 New Delhi Chemicals 43 20 Fire at a chemical store 1994 13.11 New Delhi Toxiccloud (chemicals) 500 Leakage 1984 03.12 Bhopal* Methyl isocyanate 2800 50,000 200,000 Leakage 1989 05.05…...
MAJOR CHEMICAL DISASTERS IN INDIA Read More »
This article discusses how a facility would need to get one of its coded pressure vessels repaired, altered, or re-rated. The article will cover pertinent code and jurisdiction requirements and the differences among the American Society of Mechanical Engineers (ASME) Code, the National Board Inspection Code (NBC), and American Petroleum Institute (API) requirements, as well…...
National Board Inspection Code vs. API 510 Read More »
A Process Hazard(s) Analysis is a thorough, orderly, and systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. The facility shall perform a process hazard analysis on all processes covered by EPA’s RMP rule and/or OSHA’s PSM standard. The process hazard analysis methodology selected must be appropriate to the…...
Process Hazards Analysis Techniques (Methodolgies, Resources, and Time) Read More »
