Chemical Process Safety (PSM/RMP)

Setting the record straight on NH3 detectors, the IMC, IFC and ASHRAE 15

With today’s announcement of the OSHRC decision that the IMC was the facilities RAGAGEP and that the IMC does not require detectors, I thought this record needs to be CORRECTED and CLARIFIED, as the ALJ’s understanding of how the IMC and its requirements apply to an ammonia refrigeration process/system.  In the decision, the facility successfully…...

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Why lawyers/judges make poor safety engineers (OSHRC NH3 PSM decision)

This 2019 OSHRC decision is without a doubt the worst excuse for process safety I have seen since I have been involved with process safety (27 years).  This case fails to meet the most fundamental basis of how OSHA’s wrote the standard.  Employers get to pick their RAGAGEPs, but when they state the “codes and…...

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Was the massive explosion at PES this past week a BLEVE or a HIT

UPDATED on 7/1/2019 – Pics of the tank that “exploded” being recovered from the river Well, only time will tell, but my best guess from viewing the video footage from several angles is that it appears that a vertical atmospheric storage tank did go airborne and this resulted in a large fireball.  I have no…...

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NTSB issues PRELIMINARY findings on Beach Park, IL NH3 release

The information in this report is preliminary and will be either supplemented or corrected during the course of the investigation. On April 25, 2019, about 4:33 a.m. central daylight time, about 750 gallons (3,800 pounds) of anhydrous ammonia liquefied compressed gas (UN1005, Division 2.2) were accidentally released from two 1,000-gallon nurse tanks mounted on a…...

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What you do with your “Ammonia bleed water” matters!

This week we saw two Canadian businesses be fined over $1.2 M (CAD) for discharging their “Ammonia bleed water” to a storm drain which discharged into a river killing around 70 fish. The business, a University in British Columbia, hired a refrigeration contractor to make repairs to the refrigeration system, at which time the contractor…...

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Controlling access to your process battery limits is CRITICAL… for almost everyone

One of my pet-peeves is CONTROLLING ACCESS to process battery limits.  Even OSHA and EPA felt this was so critical that they actually mention it TWICE in their process safety standard/rule.  They cover it in Operating Procedures for all company personnel and again in Contractors for those visiting the facility.  But there is one group…...

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Vehicle Impact Protection Alternative to Bollards – Curb Barrier Protection Model

Anyone who works with SAFTENG knows we are serious about facility siting and more specifically VEHICLE IMPACT PROTECTION.  This stems from my horrible luck I had with vehicles around my covered processes.  I can not even remember how many incidents I suffered while a safety engineer in the petrochemical and semiconductor industries with everything from cranes…...

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Anhydrous Ammonia Pipe Welding per ANSI K61.1/CGA 2.1 (ASME B31.3)

2019 has been a year of coal-fired power plants or me so far!  It’s only June and I have spent more than four weeks in these facilities.  With that said, I wanted to provide my friends in that industry who operate an SCR some factual information on their Anhydrous Ammonia (NH3) piping and what ANSI K61.1/CGA…...

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North Dakota’s Anhydrous Ammonia Code – well done ND!

The state of North Dakota has an excellent state code for Anhydrous Ammonia.  They have done so much more than just adopted ANSI K61.1/CGA 2.1.  They have written a code for a process safety novice, using the RAGAGEPs as their foundation…. Membership Required You must be a member to access this content.View Membership LevelsAlready a...

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Accidents associated with ammonia (ARIA)

This study essentially concerns refrigeration installations using ammonia as a refrigerant.  However, in order to better understand and to place the risks associated with these installations in perspective, quantified information has also been collected on numerous accidents, both French or foreign, in other industrial or agricultural activities and in the field of transport. The processing of these data allows…...

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Explosion of an alcohol tank inside a vinegar plant

Inside a vinegar plant, a 150-m³ tank containing 38.5 m³ of an alcohol vinegar mixture exploded around 9:40 am. The 3,000-m² site had been in activity start-up mode, but engineering works were still underway. The tank bottom became detached from the shell. It’s upper part, measuring 13 m high, 4 m in diameter and weighing some 3.5 tonnes, was…...

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Hydrogen chloride release following a maintenance operation

Ten kilos (22 pounds) of hydrogen chloride gas was released from a flange that had been fitted by a contractor just a few weeks earlier, triggering alarms and resulting in an internal emergency intervention. The incident had no significant consequences.  A contractor performing maintenance was instructed to remove the pressure sensor from a device and replace it with…...

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