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…...
Many facilities believe putting a flange together is far easier than paying for a “certified weld” joinment. They see this as a low-risk, cost-saving solution, believing any “maintenance mechanic” can put a flange together. Hence, most LOPC events I have had in my time were due to a flange that was NOT assembled per ASME…...
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…...
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…...
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’…...
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…...
Verifying that grounding and bonding systems meet a specific resistance threshold—such as the common 10 ohms target for flammable liquid processes—requires a systematic approach to ensure both accuracy and technician safety. The following procedure outlines the steps for performing a static ground-resistance test using a dedicated ground-resistance tester (Ohmmeter). This procedure applies to the periodic…...
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”…...
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…...
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…...
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…...
