Chemical Process Safety (PSM/RMP)

Deficiencies in Process Piping Cause Gas Release Incidents (QA and MI programs)

An increased number of gas release incidents have occurred in the Gulf of Mexico Region due to leaks from cracked welds, ring gaskets, flange gaskets, inlet nozzles, pipeline risers, suction headers, pressure safety valves (PSVs), and fuel gas lines. These gas release incidents involve deficiencies in Quality Assurance and Mechanical Integrity programs and are caused…...

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Sampling the PSM/RMP covered process can be a serious risk

Just because we intend to handle minimal quantities of the HHC/EHS, the task of “catching a sample” from a covered process can, in fact be one of the more hazardous tasks our operators perform.  Remember, Risk = Frequency X Severity, so operators catch many samples over their shift means this task is a high-frequency task. …...

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Do the quantities of two separate vessels that are interconnected with a closed valve need to be aggregated for the worst-case release scenario analysis?

Pursuant to the risk management program regulations, facilities must perform an offsite consequence analysis for the worst-case release scenario. Do the quantities of two separate vessels that are interconnected with a closed valve need to be aggregated for the worst-case release scenario analysis? … Membership Required You must be a member to access this content.View Membership...

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Do the quantities of two separate vessels that are interconnected with a closed valve need to be aggregated for the worst-case release scenario analysis? Read More »

Are mechanical controls such as alarms considered administrative controls and therefore limit the worst-case release quantity?

For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity (40 CFR §68.25(b)). Are mechanical…...

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Are mechanical controls such as alarms considered administrative controls and therefore limit the worst-case release quantity? Read More »

Worst-case release scenario “quantity released” reporting for a mixture

In section 2, element 2.5, of an RMP, facilities must report the quantity of toxic chemical that the facility used for the worst-case analysis. When reporting this data element in RMP*eSubmit for a mixture, should facilities report the entire weight of the toxic mixture potentially being released or only the amount of the regulated toxic…...

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FRESH AIR intakes for a ventilation system need to be from a source of FRESH AIR! (Part II)

I am not sure what it is about fresh air intake for exhaust ventilation systems, but we should call them “Rodney”, as in Rodney Dangerfield, because they get no respect.  As I said in 2016 and 2018 in my articles: The Ventilation Design Basis begins with our intakes FRESH AIR intakes for a ventilation system…...

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A food pantry, 50% Hydrogen Peroxide, and DHS’s CFATS

Today a longtime friend and SAFTENG member shared an article in our FaceBook group regarding a food pantry in TN that accidentally gave out fifty-four (54) 1-gallon containers of 50% Hydrogen Peroxide (H2O2) in their food packages.  Now I have no idea what a food pantry is doing with 50% Hydrogen Peroxide, much less that…...

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A PHA is not a JHA; a JHA is not a PHA

Both of these tools are necessary in the process safety arena; however, they have very different and distinct roles in process safety management.  In my career I found it best to perform the PHA first and based on the deviations identified in the PHA, we would write our SOPs to cover those deviations.  And of…...

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More on the limitations of Excess Flow Valves – 9 out 10 times they may let you down when you really need them

Yes… here we go again!  If we wish to claim an Excess Flow Valve as a “layer of protection” against a hose/pipe failure, we then MUST ensure the device is SIZED properly, INSTALLED properly, OPERATED properly, and MAINTAINED properly.  This is what is called process safety management and for the life of me, I just…...

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More on the limitations of Excess Flow Valves – 9 out 10 times they may let you down when you really need them Read More »

Flammable Liquids, Combustible materials, and Pressure Vessels

We have had many discussions on SAFTENG regarding pressure vessel safety, but it is the Year 2020 and we need to have a very direct talk about how we manage flammable liquids and combustible materials around our pressure vessels.  In this article, I am primarily speaking to those in the Anhydrous Ammonia fertilizer industry and…...

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Are you an Anhydrous Ammonia distributor using Nitrogen Stabilizers?

If you are an NH3 distributor and you’re using the Nitrogen Stabilizers some things have changed that you need to be aware of.  First and foremost, see my posting with the Safety Alert from Transport Canada regarding the issues they have found regarding storage and transport tanks and these Nitrogen stabilizers.  I have not heard…...

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Safety Advisory: Effects of additives in anhydrous ammonia nurse tanks or delivery tanks (Transport Canada)

In 2017 and 2019 I wrote about these Nitrogen Stabilizers and how their introduction into a PSM/RMP covered process would require a MOC and PSSR and I broke down the potential concerns and questions regarding these additives.  Now it seems there may be a Mechanical Integrity twist to the use of these additives, as Transport…...

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