Chemical Process Safety (PSM/RMP)

Liquid Penetrant Examination (NBBI)

by Jim Worman, Senior Staff Engineer with The National Board of Boiler and Pressure Vessel Inspectors If you have contractors or on-site engineers doing pressure vessel inspections, this is one method they may choose. This article is VERY WELL written and is a MUST READ for those not formally trained in this method of inspection…....

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Guidance for Conducting Risk Management Program Inspections under Clean Air Act Section 112(r)

EPA is announcing the release of “Guidance for Conducting Risk Management Program Inspections under Clean Air Act Section 112(r)” (EPA 550-K-11-001, January 2011).  This document updates and supersedes the “Guidance for Auditing Risk Management Plans/Programs under Clean Air Act Section 112(r)” of August 1999.  The new document includes updated EPA policy on involvement of facility…...

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LOPA and SIS/SIL

LOPA is a Layer of Protection Analysis and is a type of PHA that looks at the actual layers of protection a particular scenario would have. As you know, process safety is built upon the fundamental concepts of prevention, threat, and mitigation. Hence, we want to prevent the scenario from even starting, but if we…...

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Valves installed backwards?

After some good debate in a LinkedIn forum, I came to the conclusion that this practice should not be called an “industry practice” as there were a lot of people in the industry that did not do it and had never heard of it…. Membership Required You must be a member to access this content.View...

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2010 SECTION VIII — DIVISION 1 NONMANDATORY APPENDIX M – INSTALLATION AND OPERATION

M-1 INTRODUCTION M-2 CORROSION M-3 MARKING ON THE VESSEL M-4 PRESSURE RELIEVING DEVICES M-5 STOP VALVES LOCATED IN THE RELIEF PATH M-6 INLET PRESSURE DROP FOR HIGH LIFT, TOP GUIDED SAFETY, SAFETY RELIEF, AND PILOT OPERATED PRESSURE RELIEFVALVES IN COMPRESSIBLE FLUID SERVICE M-7 DISCHARGE LINES FROM PRESSURE RELIEF DEVICES M-8 PRESSURE DROP, NONRECLOSING PRESSURE RELIEF…...

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What is the difference between an update and a correction to a risk management plan? (EPA)

Updates and resubmissions require the owner or operator to review and revise all sections of the RMP as needed to bring the RMP up to date and the submission must be accompanied by a letter certifying that the entire RMP is true, accurate, and complete. The five-year anniversary date for resubmitting the RMP is reset…...

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OR-OSHA changes their PSM applicability to NH3 Fertilizer and the impact it will have on RMP

UPDATE 08/12/12 – Region 10 EPA has now publicly stated they are now aware of how this OR-OSHA change has impacted “ammonia retail businesses” (in the state of Oregon) RMP submittals!  If you are an “anhydrous ammonia retail business” in the state of Oregon and had submitted an RMP, beware EPA may be paying you a…...

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Techniques for assigning a Target Safety Integrity Level (SIL)

If your company is planning an expansion, retro-fit, grass roots facilities, or simply modifying a process unit, and the process hazard analysis (PHA) indicates you need a safety instrumented system (SIS) as a protective layer, then you need to comply with ANSI/ISA S84.01. Why? Because in February 1996, the “Application of Safety Instrumented Systems for…...

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Post Weld Heat Treating (PWHT) failure

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…...

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ASME and Hot Bolting and Half Bolting Procedures

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…...

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Re-Submitting your RMP

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’…...

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RMP Facilities in the United States as of December 2009

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…...

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