Chemical Process Safety (PSM/RMP)

Relief Valve Maintenance & Testing

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 […]

Illinois EPA refers Ellinor Trucking to Attorney General for enforcement

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

Replacement in Kind… is it really?

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

Pressure Test gone bad! (Tank Launched)

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

Comparison of Pressure Vessel Inspection Requirements in Refrigeration Industry

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 Piping Inspection Requirements in Refrigeration Industry

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)  

Corrosion Rates and Remaining Life/Fitness for Service

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

How does OSHA and EPA define “retail establishment” in regards to their “exemptions” from PSM/RMP

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

EPA’s RMP and Program 3 NAICS #’s

As we have discussed before, the EPA broke down its RMP rule into three (3) programs, and each program has criteria that will place the process in one of the three. However, the one criterion that confuses some businesses is how the EPA used the North American Industry Classification System (NAICS) to qualify a process

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