Chemical Process Safety (PSM/RMP)

NFPA 497 has its Table 4.4.2 updated with new chemical-physical property data

NFPA 497, Table 4.4.2. has become my “go-to” source for chemical-physical property data for my flammables (along with the SDS).  Although they use Celsius rather than Fahrenheit, and this drives me crazy just because I am “old school”, this table is instrumental for understanding the “Group” your flammable gas/vapors belong to!  In the 2021 edition…...

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The Chlorine Institute recognizes three (3) piping pressure testing techniques

All new or modified chlorine piping systems must undergo pressure testing to verify the integrity of the piping (see section 11.4 for leak testing). ASME B31.3 (13.2.8 ), Process Piping testing requirements, should be applied as a minimum standard. There are three (3) types of acceptable testing methods: hydrostatic testing, pneumatic testing, and the alternate…...

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The Chlorine Institute has revised its hydraulic thermal expansion design considerations

Liquid chlorine has a very high coefficient of thermal expansion. Relatively small increases in liquid chlorine temperature can create enough pressure to cause a blocked-in section of piping to rupture or leak at the connections. A temperature rise from 14°F (-10°C) to 32°F (0°C), will expand liquid chlorine by 2%. However, in a contained volume,…...

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The Chlorine Institute revises its piping leak testing protocols

Leak testing should be done once the piping system is completely assembled. The purpose of a leak test is to ensure all connections and components will not leak chlorine when pressurized. Leak testing is not a substitute for pressure testing. If the system was not disassembled and reassembled as part of the pressure testing and…...

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The Chlorine Institute has revised its piping RAGAGEP

The Chlorine Institute has revised its piping RAGAGEP and it is FREE for anyone who wants it.   Pamphlet 6 – Piping Systems for Dry Chlorine, Edition 17 contains major revisions to the following sections, in addition to minor clarifying changes throughout the pamphlet:… Membership Required You must be a member to access this content.View Membership...

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PHMSA issues DRAFT FAQ for Midstream facilities and OSHA’s PSM

PHMSA provides written clarification regarding the pipeline safety regulations found at 49 CFR parts 190–199 in the form of FAQs and other guidance materials. PHMSA is requesting public comment on a set of DRAFT FAQs that were developed by the Working Group that was established by the Gas Pipeline Advisory Committee (GPAC) and the Technical…...

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Tenth Circuit Appeals court rules a boiler connected to a PSM/RMP covered process is part of the “covered process”

After a boiler exploded at a refinery, OSHA cited the refinery’s owner for violating 29 C.F.R. § 1910.119, which sets forth requirements for the management of highly hazardous chemicals. The Occupational Safety and Health Review Commission (the Commission) upheld the violations. In doing so, it noted that the refinery had previously violated § 1910.119. But…...

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Tenth Circuit Appeals court rules a boiler connected to a PSM/RMP covered process is part of the “covered process” Read More »

Emergency Response Coordination Activities Effective Date(s)

The RMP Amendments finalized on January 13, 2017, included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93).  The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018.  Because the RMP Amendments were not…...

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Differences in accident history between Program 1 eligibility and the hazard assessment

Program 1 eligibility under 40 CFR §68.10(b) is contingent upon the process NOT having had an accidental release of a regulated substance that led to offsite death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk management plan submission. Additionally, as part of the hazard assessment required…...

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Dispersion Modeling Systems Relevant to Homeland Security Preparedness and Response

As one of its core research focuses, the U.S. Environmental Protection Agency’s (EPA’s) Homeland Security Research Program (HSRP) is interested in refining its tools and methodologies to better characterize the fate and transport of hazardous contaminants during all phases of an emergency response. Atmospheric dispersion modeling is one tool that can be used for effective…...

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Pipe Welding and Welder Qualifications (ASME B31.1 and 31.5)

If you’re installing/repairing/modifying your chemical process piping using ASME B31.3 and 31.5, these standards have some strict QA/QA requirements for who can make the welds to join the piping.  These welders MUST be qualified in accordance with ASME Code, Section IX, “Welding Qualifications.”  ASME Code, Section IX, Part QW-103.1, states that: “Each manufacturer or contractor…...

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COVID safety changes may need an MOC when they impact a PSM/RMP process

We have seen hundreds of changes to our businesses since March and many of these changes were needed for worker protection, but recently we came across one such change that had serious potential to cause a bad event!  Maybe you have seen the latest and greatest devices for aiding in our “social distancing” efforts.  These…...

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