Are there any recordkeeping requirements specified in the risk management program (RMP) regulations in 40 CFR Part 68? The owner or operator of a stationary source that is subject to the RMP regulations must maintain records supporting the implementation of Part 68 for five years (§68.200)…. Membership Required You must be a member to access...
Are there any RMP recordkeeping requirements? Read More »
In many processes, the use of a rupture disc (RD) between the vessel being protected and the Relief Valve (RV) is a fairly common practice. This is ALWAYS done for design necessities and not just “because”. Some processes could be corrosive to the RV internals, at least this is the most common reason for this…...
Rupture Disc between Pressure Vessel and Relief Valve (and after the RV) Read More »
Some specialized literature regarding the maintenance of safety relief valves (SRVs) is available, but it is best to always consult the manufacturer’s detailed installation and maintenance manuals on the subject, as some type of valves might require special attention. It is highly recommended to always use genuine manufacturer’s spare parts. In some parts of the…...
Relief Valve Maintenance & Testing Read More »
Illinois Environmental Protection Agency Director has asked the Illinois Attorney General’s office to proceed with enforcement action against Ellinor Trucking and River Rock Logistics, operated out of Lanark. The Illinois EPA alleges an inadequate transfer hose was used when an Ellinor employee prepared to offload anhydrous ammonia to an above-ground storage tank, which resulted in…...
Illinois EPA refers Ellinor Trucking to Attorney General for enforcement Read More »
Following the guidance of OSHA and EPA, the industry has attempted to simplify what type of change requires the initiation of the Management of Change system and which type of change is a “replacement in kind” (RIK). Oddly enough, both OSHA and EPA chose not to define the meaning of “change”; instead, they have officially…...
Replacement in Kind… is it really? Read More »
On January 26, 2006, a factory in Brazil witnessed a significant accident during a pneumatic pressure test involving a tank and pipework. The incident occurred because blind flanges were not used to isolate the pipework connected to the tank. Instead, only the valves were closed. This oversight led to the possibility that one or more…...
Pressure Test gone bad! (Tank Launched) Read More »
Comparison of Pressure Vessel Inspection Requirements in the Refrigeration Industry Code Type of Inspection Component Description Inspection Remediation Inspection Frequency IIAR 109 (1997) All pressure vessels If signs of more than mild corrosion should inspect further by a professional engineer or ASME inspector (4.3.5) None listed – Annual ammonia safety check (5.2) – Thorough inspection every 5 years (5.3) IIAR 110 (1993) Including…...
Comparison of Pressure Vessel Inspection Requirements in Refrigeration Industry Read More »
Comparison of Piping Inspection Requirements in Refrigeration Industry Code Component Description Inspection Remediation Inspection Frequency IIAR 109 (1997) Uninsulated Pipe (4.7.4) Examine for corrosion Clean pipe down to bare metal and paint with rust preventative paint. “Badly corroded pipe should be replaced.” (4.7.4) – Annual ammonia safety check (5.2) – Thorough inspection every 5 years (5.3) …...
Comparison of Piping Inspection Requirements in Refrigeration Industry Read More »
Source Corrosion Rate or Degree of Corrosion Remaining Life or Fitness for Service Application API 570 Long-term (between last and initial inspections): (use corrosion rate resulting in shortest remaining life) Piping Short-term (between last and previous inspections): Piping and Vessels NBIC – 23 a) calculated from data collected by owner or user on vessels in the same…...
Corrosion Rates and Remaining Life/Fitness for Service Read More »
The following are all the “exemptions” permitted in EPA’s Risk Management Plan rule (40 CFR PART 68—Chemical Accident Prevention Provisions)… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Summary of the RMP Chemical Exemptions Read More »
Below is OSHA’s official position on the need for hydrostatic relief valves in an Ammonia Refrigeration process. This is a bold move on OSHA’s part as the Ammonia Refrigeration industry and their trade groups have consistently stated that a “trained operator” is better than a hydrostatic RV. (emphasis added by me)… Membership Required You must...
OSHA’s position on Hydrostatic Relief Valves and Ammonia Refrigeration Processes Read More »
Retail facilities are exempted from PSM requirements. At first glance, it appears this is a pretty broad exemption, as the standard just states. This section does not apply to:1910.119(a)(2)(i) Retail facilities; But as I wrote about last month, not all retail facilities selling a PSM Highly Hazardous Chemical (HHC) in the USA are exempt. In…...
