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...
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…...
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…...
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…...
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”…...
