Chemical Process Safety (PSM/RMP)

UPDATE on NH3 Fatality… Coroner’s Jury Rules on Anhydrous Ammonia Incident

A coroner’s jury has ruled the death of a man, who inhaled anhydrous ammonia last year, accidental. The jury ruled the man died of a brain injury caused by a lack of oxygen due to chemical burns from inhaling anhydrous ammonia from a ruptured tank. He also had bacterial pneumonia and acute chronic respiratory failure…....

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Flammable Liquids process, PSM, MOC and simultaneous flows

A number of years ago the SAFTENG team was asked to aid in an investigation involving a flash fire that injured a worker. The State Fire Marshall was able to establish the flash fire was ignited OUTSIDE of the atmospheric vessel. We were challenged with finding out how and why. This incident was traced back…...

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EPA’s “cheatsheet” for complying with CGA 2.1 (NH3)

The following are key safety measures the EPA will use in its inspection of facilities storing/processing Anhydrous Ammonia (NH3). These are measures that EPA has determined should be in place, regardless of a facility’s age or size. This is not intended to be a comprehensive list of essential safety measures, but rather a subset of…...

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API Releases three (3) New Standards

The American Petroleum Institute (API) issued three new first edition standards to enhance refinery safety and inspection programs as part of its core commitments to improving workplace safety and protecting the environment. RP 583, Corrosion Under Insulation and Fireproofing: This standard will assist with industry inspection, and allow maintenance personnel to fully understand the complexity…...

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Your RMP “Emergency Contact”

Provide the name of the person designated as the emergency contact. If your facility has a regulated toxic substance, you may already have designated a facility emergency coordinator in your notification to your Local Emergency Planning Committee (LEPC) under EPCRA Section 312. If your facility has more than one emergency contact, provide just one name…...

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U.S. EPA Risk Management Plan (RMP) Webinars and Training – RMP*eSubmit Webinars

Registration is now open for EPA’s Web-based software, RMP*eSubmit. The software is used for online Risk Management Plan (RMP) reporting. RMP*eSubmit allows facilities to submit, correct, resubmit, and access their RMPs online, 24 hours a day, 7 days a week. EPA asks that all facilities use this method to submit RMPs: it’s easy to use…...

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Boiler and Pressure Vessel Report of Violation Findings for First Quarter 2014

The National Board of Boiler and Pressure Vessel Inspectors has released its First Quarter Report of Violation Findings for 2014.  The data captures problem areas and trends related to boiler and pressure vessel operation, installation, maintenance, and repair; and also identifies problems before unsafe conditions occur.  This report serves as an important source of documentation…...

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Hazards of Hot Work on Vessels/Containers

This is an amazing summary from OSHA that shows us the number and severity of Hot Work Accidents involved with doing hot work on improperly prepared vessels.  There are other hot work fatalities mixed in, but the vast majority of these incidents involved welding/cutting on vessels/containers that were NOT properly prepared. Check out 1910.252(a)(2)(vi)(C) and 1910.252(a)(3)(i) for…...

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Just some random thoughts about “Detectors in my header”

Over the last decade or so it has become popular to utilize a “relief header” in the ammonia refrigeration process.  And in more recent years, the practice of installing an ammonia detector in this relief header has become very popular.  Here are some random thoughts about these detectors that employers need to think through when…...

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Catastrophic Failure of a Liquid N2 Storage Tank – BLOCKED IN scenario (Japan, 8/28/1992)

On 28th August 1992, in a food factory, a liquefied nitrogen storage tank catastrophically failed, causing the destruction of the upper half of the factory as well as damaging other factories and structures partially, including the outer walls, window glass, and shutters of 25 buildings, 39 parked vehicles consisting of busses, trucks and cars, and…...

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UK’s HSE guidance on failure modes in Refrigeration Processes

UK’s HSE provides some EXCELLENT guidance on how ammonia refrigeration process safety can be managed.  We have always taught our process safety courses with the underlying philosophy of process safety as PREVENT, PROTECT, MITIGATE, and in this HSE material they follow the same philosophy.  This information is particularly helpful as they have matched up the…...

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SOP annual certifications and 40 CFR Part 68.200 Recordkeeping (RMP)

Today I learned of yet another SIGNIFICANT difference in complying with EPA’s RMP vs. OSHA’s PSM.  Yes old dogs can learn new tricks and I am betting that I may not be the only old dog “out of compliance” with 68.200!  We have been assisting a company with a US EPA RMP inspection and in…...

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