Monika Chrzaszcz, U.S. EPA, Region 5, presented at this years MI Safety Conference on the matters of Anhydrous Ammonia and how the chemical impacts EPCRA and RMP. Her presentation points out some of the RMP amendments that are in place now and those coming, as well as EPCRA Tier II reporting and release reporting…. Membership...
GREAT UPDATE from EPA on RMP, EPCRA and Ammonia’s impact Read More »
NFPA 499, Recommended Practice for the Classification of Combustible Dusts and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas was updated for 2021 and this update involves a very peculiar reference that has me scratching my head. This reference is also another example of why Safety and Process Safety professionals have come…...
NFPA 499 (2021) updated with a peculiar reference Read More »
We have discussed this numerous times over the years, but we rarely have a first-hand account of a “bleed” within a DB&B causing an LOPC event. But because CALARP now has a Program 4 Incident Reporting trigger, we get to see firsthand how a 3/4″ bleeder on a 14″ pipe handling a HHC/EHS can cause…...
Way back in 2017, the state of California (CA) revised it’s Accidental Release Prevention program by adding a Program Level 4 for the state’s refineries. In addition to the expanded prevention program requirements, the refineries are required to submit investigation reports, including root cause analysis after any major incident. But the one aspect of the Program…...
Cal ARP Program 4 and reporting on Process Safety Performance Indicators Read More »
You may have seen this latest and greatest “detection method” in your junk mail, pop-up ads, or in a search of the internet. These tapes work and they work well in my experiences, but as with any product, there are some serious drawbacks that one must understand before using these products. Before I get into…...
Chemical detection tape – the pro’s and con’s? Read More »
Many of you that handle anhydrous ammonia are familiar with The Compressed Gas Association’s (CGA) 2.1, Requirements for the Storage and Handling of Anhydrous Ammonia, which is the baseline RAGAGEP for ammonia fertilizer distributor facilities. But the organization has another ammonia standard, G-2, Ammonia that is an EXCELLENT compliment to CGA 2.1. The G-2 standard…...
The CGA updated their G-2 Ammonia standard Read More »
I have written many articles on “scrubbing NH3” in preparation for line breaks/equipment openings or emergency removal from a compromised container and with NH3 the scrubbing media is simply water (H2O). I learned these “scrubbing” methods while working one summer in an internship and the safety pro who hired me was also an MSU graduate…...
Chlorine and a “KY Scrubber” Read More »
Chlorine (Cl2) has a great warning property in that most people can smell Cl2 at around 0.002 ppm in the air (the official odor threshold per Agency for Toxic Substances and Disease Registry) and 0.31 ppm in water; although most data says its odor threshold is 0.2 – 0.4 ppm. In other words, even the…...
Finding chlorine leaks – approved methods and PSM/RMP requirements Read More »
This is a common question we get regarding pressure testing and leak testing of process piping. I have written quite a few posts regarding the ASME B31.3 and 31.5 requirements for pressure and leak testing over the years, but this question about holding pressure for 24-hours is one that just will not die. I am…...
Most of my clients who are users of Chlorine (Cl2) use it in vacuum systems where the Cl2 is being injected or inducted into a water flow. In these smaller “processes” it is not unusual to find “tubing” being used vs. hard pipe. It took me years to accept the tubing design model as I…...
Chlorine and tubing used in vacuum systems Read More »
I have asked for an official interpretation on this question, but until that arrives I will answer this question as I did for a client this week. Here is the scenario: There is a significant fire in the RMP covered. The fire does NOT cause a release of the EHS, much less get off-site. However,…...
The Chlorine Institute has updated its instruction booklet for applying an A Kit to 100-LB. & 150-LB. Chlorine Cylinders. Remember, these Instruction Booklets can be downloaded for FREE from their bookstore and if your facility is using 100 or 150 pound Cl2 cylinders, the A Kit is a MUST HAVE and training on the proper…...
