Chemical Process Safety (PSM/RMP)

CSB Update on Fatal H2S Release @ TX Refinery

Interesting facts about this event: On October 10, 2024, at 4:23 p.m., approximately 27,000 pounds of hydrogen sulfide gas were released during maintenance at the Refinery in Deer Park, Texas. The release fatally injured two (2) contract workers. Background Information The facility is a petroleum refinery located in Deer Park, Texas and is a Limited…...

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Does changing a chemical supplier require an MOC

Imagine the purchasing manager announcing at a staff meeting that the business is changing the supplier for one of your PSM/RMP-covered chemicals. There is nothing special about this chemical; it is a 100% pure solution/gas, so you think nothing is changing. But this chemical has come under a lot of questions by yours truly, and…...

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2 safety-critical devices in pressure testing our piping

It is great when I can convince an organization to pressure test and leak test its process piping. However, if this task is not done according to the book, we may have created a serious hazard. Two (2) safety-critical devices are often overlooked during pressure and leak testing, and missing either one or both can…...

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When Welding goes Wrong

This is why we MUST have a Quality Assurance process in our piping installations when welding joins the pipe. The same applies to the construction process vessels; however, most of those are “shop-built,” and we are outside the scope of those vessels. But a “field-erected” vessel would fall into our sphere of control…. Membership Required...

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“Leak Checking” new and modified piping

One of the top questions I get in my process safety circles is… Do we have to pressure test/leak test piping that has been opened/modified before we re-introduce the HHC/EHS to the piping? I turn to one of my favorite sources for RAGAGEPs, NFPA, and one of the best NFPA codes is NFPA 58, which…...

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CSB marks the 20th anniversary of the BP Texas City Refinery

The U.S. Chemical Safety and Hazard Investigation Board (CSB) marked the 20th anniversary of the fatal explosions and fires at BP America Texas City Refinery in Texas City, TX, that occurred on March 23, 2005. The tragic incident resulted in the deaths of 15 people and injuries to 180 others.  To remember this deadly event,…...

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3-Way Valve under Hydrostatic RV?

Processes that handle Liquified Pressurized Gases are required to have Hydrostatic Relief Valves on liquid piping where the liquid can be trapped. Much like vapor/gas phase Pressure Safety Valves, it is frowned upon when we have an intervening valve under the PSV. However, many codes today ALLOW us to install a 3-way valve below the…...

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Temporary SOP or a Car-Seal or Both?

The arrangement below is very common in processes/systems. This simple yet common arrangement causes havoc in hazard analyses. As the title states, is this arrangement managed with a Temporary SOP, a Car-Seal, or Both? The issue is that the motorized valve is tied to a Hi-Hi level alarm and interlock. When the vessel archives its…...

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How many locks do we need to Lockout a Double Block & Bleed arrangement

Several clients design Double Block and Bleed (DB&B) isolation into their process, especially when they know they will regularly enter certain Permit-Required Confined Spaces (PRCS). When these DB&B arrangements are part of the design, the isolation valves and the bleed valve are near one another. This allows us to use a single lock with some…...

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Did we learn from the Stapleton Air Port Tank Farm Fire (1990)

Contributing to the severity and duration of the fire was the lack of storage tank fail-safe control valves and internal fire valves and the location of the control building in the containment area where fuel leaks are likely to occur. The National Transportation Safety Board determined that the probable cause of the fire at the…...

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Secondary Containment and “Equalization” of tanks

I think most EHS professionals will agree that bulk tanks of hazardous materials need some means of “secondary containment”. This practice has been in place for my entire career and rarely gets challenged. However, in recent years I have come across several scenarios where either the facility/unit designed the process to function this way or…...

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CSB Releases Second Update into Fatal Hydrogen Sulfide (H2S) Release at PEMEX Refinery in Deer Park, Texas

Today, the CSB released a second update on its ongoing investigation into the fatal hydrogen sulfide (H2S) release that occurred on October 10, 2024, at the PEMEX Deer Park Refinery in Deer Park, Texas. Two contract workers died during the incident, and over 27,000 pounds of toxic hydrogen sulfide gas were released. Local authorities issued…...

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