Chemical Process Safety (PSM/RMP)

EPA RMP… What are considered industrial buildings, commercial buildings, or recreational areas, and how can they be identified?

Pursuant to the hazard assessment requirements in 40 CFR Part 68, Subpart B, an owner or operator is required to conduct an offsite consequence analysis and analyze a worst-case release scenario and alternative release scenarios as part of a risk management plan (RMP). When completing these scenarios, public receptors need to be identified. A public…...

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EPA RMP… What are considered industrial buildings, commercial buildings, or recreational areas, and how can they be identified? Read More »

EPA RMP… For the five-year accident history, does the owner or operator need to include accidental releases that were only released onto the land or into water?

Pursuant to 40 CFR §68.42(a), the owner or operator of a stationary source subject to the risk management program regulations must document significant accidental releases of regulated substances from a covered process in the five years prior to the submission of an initial or updated risk management plan (RMP). For the five-year accident history, does…...

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EPA RMP… For the five-year accident history, does the owner or operator need to include accidental releases that were only released onto the land or into water? Read More »

EPA RMP… 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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EPA RMP… 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 »

EPA RMP… What is the definition of fuel for the purposes of exclusion?

A flammable substance listed in 40 CFR §68.130 is excluded from the risk management program regulations when it is used as a fuel or held for sale as a fuel at a retail facility (§68.126). What is the definition of fuel for the purposes of this exclusion?… Membership Required You must be a member to...

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

EPA RMP… Do all facilities subject to the risk management program regulations have to develop an emergency response program?

The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. Do all facilities subject to…...

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EPA RMP… Do all facilities subject to the risk management program regulations have to develop an emergency response program? Read More »

Expansion/Seismic hoses, excess flow valves, and check valves

What I am going to suggest in this article is NOT necessarily a code or standard requirement, but just some SOUND ADVICE on how to improve safety around expansion/seismic joints where hoses are utilized to allow for flexibility.  As my clients know, I HATE hoses in a chemical process and I am OCD when it…...

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Internal inspections… of my pressure vessel??? We don’t need no internal inspections

I have been doing process safety my entire career and I have had some of the finest engineers teach me process safety.  Now those that know me, know I am just some dumbass western KY edua-macated safety redneck, but even I know the importance of intenral inspections on my PVs.  I know only two (2)…...

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Internal inspections… of my pressure vessel??? We don’t need no internal inspections Read More »

What happens when the NH3 release inside the engine room exceeds 40,000 ppm?

UPDATED on 8/21/2019 with the 2018 IFC Commentary… I am guessing that someone has published a technical paper or article stating that an “electrical shunt” is no longer a code requirement for ammonia refrigeration engine rooms.  This has caused several of my clients and subscribers to ask me if this is true as this goes…...

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What happens when the NH3 release inside the engine room exceeds 40,000 ppm? Read More »

2019 edition of the National Board Inspection Code (NBIC) summary of major changes

The 2019 edition of the National Board Inspection Code (NBIC) has been available for purchase since July 1st, 2019.   Here is a summary of the major changes:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Anhydrous Ammonia hydrostatic expansion event?

This is another picture that was shared with me and is making the rounds on social media.  It certainly appears to be a liquid (hydrostatic) expansion event on a stainless steel pipe.  The story goes and I can certainly see this happening…  Valve installed when hot out. Valve didn’t fully seat and allows vapor to…...

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Hazards of Improper weld repair and failed hydrostatic pressure testing?

I have many questions about this picture but was told this was the results of a failed hydrostatic pressure test after a non-certified repair was made.  Has anyone seen this picture before?  Got an incident report to go along with the image?  My source is very trustworthy, but I just would like to have an…...

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