Chemical Process Safety (PSM/RMP)

Ammonia Refrigeration, flange connections, gaskets, and torque (EPA Region VI)

Many years ago I had an open debate with a “grandfather of refrigeration” on his turf in front of about 30 other refrigeration professionals and the debate was about “flange connections”, ASME B16, and TORQUE and how it all applied to covered processes regardless of what the HHC/EHS was, including anhydrous ammonia in a refrigeration…...

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What does a “suitable telltale indicator” look like when we have a dual relief system (Part II)

It seems that my January article “What does a “suitable telltale indicator” look like when we have a dual relief system” was a hit as I received numerous requests for information on how to get these special gauges.  And as I promised each of you in the ammonia refrigeration industry, here is what I have…...

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Bypassing safety devices is a no-no! (BSEE Alert)

On December 30, 2019, the Bureau of Safety and Environmental Enforcement (BSEE) Inspectors working offshore discovered that a level safety high had been improperly deactivated with a zip tie, resulting in the issuance of a P-103 incident of noncompliance (INC). There have been multiple instances across the Gulf of Mexico in which operators have failed…...

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Pressure Relief Valve Testing on Pneumatic Systems (USCG Bulletin)

Although this Coast Gaurd Bulletin is specific to maritime vessels, it can and should be applied to relief valves on land as well.  There are some really good practices in this bulletin, such as when to perform the test in-situ vs. bench testing.  The incident happened when a relief valve on the associated compressor was…...

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Changes to a plant’s water system leads to a flash fire (MOC and State Plumbing Code)

A lot of older plants in the USA use their water piping as their main ground for a lot of purposes.  In one such plant, the grounding connections for the flammable liquid transfers were tied into the water piping.  One day a water pipe failed and caused quite a bit of damage; the price to…...

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No MOC for reduction of inventory to below PSM/RMP TQ leads to LPOC event (engineering out excess flow valves)

A number of years ago a former client decided that process safety was not worth the effort and wanted to get their process below the 10,000 pounds TQ for their LPG.  They hired a local architect/engineering firm that had no experience with the storage, handling, and processing of LPGs.  This “architect/engineering firm” advised the facility…...

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No MOC for reduction of inventory to below PSM/RMP TQ leads to LPOC event (engineering out excess flow valves) Read More »

When does a pressure vessel not require a pressure relief device? (ASME 6-inch exception)

Since I began consulting I learned of something I thought I would never see… an ASME pressure vessel without a pressure relief device (PRD).  Typically when I have come across one of these vessels I have gotten the “grandfather” or “its too small” justification.  So let’s discuss these two items and see if they are…...

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Contractor Safety training at petroleum refining or petrochemical manufacturing facilities (WA-OSHA)

The department is initiating rulemaking to implement the advanced safety training requirements for High Hazard Facilities. Chapter 49.80 RCW, enacted in 2019, requires owners of petroleum refining or petrochemical manufacturing facilities to use a skilled and trained workforce when contracting for construction, alteration, demolition, installation, repair, or maintenance work. By January 1, 2022, all workers…...

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Amine regeneration unit explosion (UK’s HSE Report)

  Shortly after 6 pm, on June 2, 2011, an atmospheric storage tank within the amine regeneration unit exploded. A fireball split the tank open and killed four (4) workers. The sole survivor sustained severe burns and suffered life-changing injuries. The force of the explosion ejected the five-ton steel tank roof over 180 feet through…...

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EPA Updates its National Compliance Initiative: Reducing Accidental Releases at Industrial and Chemical Facilities data

Last week EPA updated its National Compliance Initiative: Reducing Accidental Releases at Industrial and Chemical Facilities data and included an updated photo… Is this another “shot across the bow” to the ammonia refrigeration industry? They also updated their data with their 2019 Inspections:… Membership Required You must be a member to access this content.View Membership...

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Houston Explosion, Propylene, PSM, and RMP

So much media coverage of the explosion in Northwest Houston on January 24, 2020.  It is assumed that the explosion was caused by a propylene leak, a flammable gas that most people had never heard of before the explosion.  What is so sad is that some politicians are jumping on board this tragedy and calling…...

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Hazardous Locations: When, Where, and How

When most ordinary people hear the term “Hazardous Location” many conjure images of a dangerous location associated with typical hazards; however, when a safety engineer or engineer from the process industries hear the phrase we immediately elvate our antenna and sit up and pay close attention to what is being said.  But for those outside…...

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