Much like The National Board did, ASME is now splitting out its relief systems into a new section. The NB created Part 4 – Pressure Relief Devices in 2017 and now ASME is following suit and has created Section XIII, Rules for Overpressure Protection (available 7/31/21). This new section in the 2021 edition of the…...
NEW to 2021 ASME BPVC: Section: XIII – Rules for Overpressure Protection Read More »
For 20 years now, when teaching any of my process safety courses I make the student repeat this three times: UPWARDS and UNOBSTRUCTED, UPWARDS and UNOBSTRUCTED, UPWARDS and UNOBSTRUCTED. We do this when we get to the Relief System design basis. The vents to the atmosphere almost will always be required to be UPWARDS and…...
Upwards and unobstructed, two simple words that cause way too much debate! Read More »
I love the Line Break and Equipment Opening (LEO) SWP because it is one of the most hazardous tasks a worker will perform within a covered process AND the fact that there is no OSHA standard dictating how a business manages these risks. This lack of “OSHA Control” spoon-feeding us safety requirements causes most management…...
Should we allow line break/equipment opening behind a single valve isolation? Read More »
Please note this citation was issued as a General Duty Clause (GDC) citation by a State OSHA Plan and the incident was not a PSM/RMP incident (at least OSHA did not cite .119). The practice at issue is one that is done routinely in just about all companies and on just about every type of…...
OSHA (State Plan) issues GDC citation regarding “Hot Bolting” Read More »
A few years ago we were asked to participate in an engineering review/facility siting for a proposed facility. The business was in a $ crunch so one way they decided to save some $ was to utilize DOT-306 tankers as “temporary storage tanks”, thus reducing the number of above-ground storage tanks AND a reduction in…...
DOT tankers without their motive power may be PSM covered processes Read More »
Back in January 2019, I posted an article titled “Is API 570 your Piping Inspection/Repair RAGAGEP… Repair Requirements are now crystal clear” and this posting caused quite the stir with many of you. Most of you followed the code(s) and went and verified what I shared in the article, but as usual, I got a…...
Pressure testing after breaking the boundry of previously tested piping circuit (Part 1) Read More »
Over the years I have been told time and time again that there are two absolutes in ammonia refrigeration. #1 – we do not have “temporary operational conditions” so we have no need for “temporary operating procedures” and #2 – there is no “process chemistry” in ammonia refrigeration. But it dawned on me this week…...
Ammonia refrigeration and process chemistry Read More »
RMPs must be updated at least once every five years. EPA offers a Checklist for Submitting your Risk Management Plan (RMP). We must fully update your RMP for resubmission sooner than the five-year anniversary date if any of these changes occur:… Membership Required You must be a member to access this content.View Membership LevelsAlready a...
The Ammonia Safety Awareness Program was developed due to the rise of ammonia-related incidents and hazards over the past few years, including the tragedy at Fernie Memorial Arena. Developed in collaboration with industry professionals, this program provides training and downloadable tools to fill in knowledge gaps and share best practices for maintaining ammonia refrigeration equipment and…...
Technical BC launches Ammonia Safety Awareness Program Read More »
This topic has always been one that seemed to be controversial in the ammonia refrigeration sector, with decades of denial that Stress Corrosion Cracking could occur in an ammonia refrigeration process due to the water content in the ammonia. But last month, Technical BC (British Columbia) discussing their SCC concerns related to pressure vessels in…...
Did Technical BC just say pressure vessels in NH3 refrigeration need to be PWHT? Read More »
One of the biggest and longest debates in process safety circles is the responsibility of businesses to upgrade their process design(s) based on an updated RAGAGEP. OSHA attempted to address this in a 2016 LOI. Now EPA has stated their “official position”… (emphasis by me)… Membership Required You must be a member to access this...
At least every five (5) years a Risk Management Plan must be updated. We are seeing a lot of RMP that have been updated in the past 12-16 months that failed to include this in their update. I wrote about this new requirement this past weekend, but now I want to demonstrate the “fall-out” from…...
On your next RMP 5-year Update, be sure to include this Read More »
