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
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
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
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
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).
This series is intended to bring attention to failures in the “coded welding” practices. From not using certified welders, to failures in visual and NDE, and failures in Pressure/Leak testing. This first incident was caused by a decision NOT to perform Post-Weld Heat Treatment on a repaired pressure vessel.
While virtually any liquid trapped in a “blocked-in” section of pipe can cause a rupture due to thermal expansion, specific chemicals are strictly regulated by OSHA 1910.119 (PSM) and NFPA 30 because of their volatility or toxicity. The requirement for a hydrostatic relief valve (HRV) is generally triggered by the chemical’s physical state (liquefied under
Immediate Lethal Zone — Fireball Radius Typical range: 160–820 ft Hazards: Used for: absolute exclusion zone. Severe Burn Zone — High Thermal Radiation Typical range: 820–1,300 ft Thermal radiation: ~12.5–37.5 kW/m² Effects: Used for: firefighter withdrawal line unless cooling operations are effective. Moderate Burn Zone — Pain/Blistering Typical range: 1,300–2,600 ft Thermal radiation: ~5–12.5 kW/m²
To understand what certification is needed for the visual examination of welds under ASME B31.3, it is critical to distinguish between the two (2) distinct roles defined by the Code:1) the Examiner and2) the Inspector While in fact, B31.3 requires 100% visual examination of fabrication (341.4.1), the “certification” depends on which of these two roles
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
