Chemical Process Safety (PSM/RMP)

The CSB explains the non-typical BLEVE at the PES Refinery

  The rupture of the V-1 vessel appears to have caused a boiling liquid expanding vapor explosion (BLEVE, pronounced ‘blev-ē). A BLEVE is the “sudden loss of containment of a pressure-liquefied gas existing above its normal atmospheric boiling point at the moment of its failure, which results in rapidly expanding vapor and flashing liquid. The…...

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Rule Implementation Update: Chapter 296-71 WAC Refinery worker training and certification in high hazard facilities

Updated on 11/1/22   Effective Date: October 22, 2022 This rule created a new chapter, refinery worker training and certification in high-hazard facilities, implementing the advanced safety training requirements under chapter 49.80 RCW, adopted by the Washington State legislature in 2019. Chapter 49.80 RCW, requires owners of petroleum refining or petrochemical manufacturing facilities to use…...

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New York City DEP requires an RMP and some very specific additional requirements from U.S. EPA’s

New York City’s Community Right-to-Know Law (Local Law 92) requires facilities where extremely hazardous substances or regulated toxic substances are present at or above federally determined levels (Threshold Planning Quantity), to prepare and submit a Risk Management Plan to the Department of Environmental Protection on or before March first of every year. In situations where…...

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What are inherently safer practices?

We have recently heard the phrase “inherent safety” used by OSHA and EPA as both agencies work at revising/updating their process safety standards.  But what exactly is “inherent safety,” and why is it at the top of the Hierarchy of Controls for process safety? Inherently safer practices are an approach to designing safer chemical plants,…...

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CSB Releases Final Report into 2019 PES Fire and Explosion in Philadelphia

Pay close attention to the break in the smoke plumes on the right hand side of the screen… Today, the U.S. Chemical Safety and Hazard Investigation Board (CSB) released its final investigative report into a massive fire and explosions at the Philadelphia Energy Solutions (PES) Refinery in Philadelphia, Pennsylvania, that occurred in June 2019. The…...

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Example of LATENT failures – Auditing

Many organizations have become very good at identifying the ACTIVE failures associated with an accident; however, in almost all of the accident investigations I have been involved with, I find LATENT failures to play a bigger role than active failures.  But that is a really hard pill for most organizations to swallow.  But there is…...

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Butane Railcar(s) stored on a siding in NC found to be a stationary source under RMP

A North Carolina Administrative Law Judge found that railcars on a “siding” are a “stationary source,” as such, if they contain an EHS over the RMP threshold, they fall under EPA’s Risk Management Plan. This is in line with EPA’s recently proposed changes wanting to apply a 48-hour time frame to the term “storage, not…...

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EPA Region 1 Chemical Warehouses and Distribution Facilities

EPA Region 1 RMP presentation. It has a lot about Ammonia refrigeration and some other EPA rules.   The presentation has a lot of actual pictures of violations.        … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Hot Work strikes again! (CSB report)

On August 12, 2016, hot work was being conducted by a contractor at a crude oil terminal on a section of pipe that contained residual crude oil. Using an isolation device, the pipe segment was plugged on both ends by a sub-contractor (hired by the primary contractor). During the welding operation on the inside surface…...

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Poor Preparation Prior to Hot Work Leads to Fires (BSEE Safety Alert No. 447)

Recently, several fires occurring during hot work have been reported to BSEE. Hot work is any job with the potential to create an ignition source, such as an open flame, sparks, or high temperatures. Examples of hot work include welding, using acetylene torches, and grinding and cutting metal…. Membership Required You must be a member...

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Temporary Equipment as a Potential Source of Ignition on Offshore Facilities (BSEE Safety Alert 449)

Bureau of Safety and Environmental Enforcement field personnel have indicated a need for increased operator awareness when using temporary equipment (TE). Some TE may be a potential ignition source and can range from small items such as portable welding sets to large skid-mounted packages (e.g., temporary generators, air compressors, hydraulic power packs, well-testing equipment, process…...

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EPA’s RMP Emergency Response requirements explained for “Non-Responding Facilities”

In my discussions with SAFTENG members who are Process Safety clients, the question is always asked:  “Where do you get the terms “responding facilities” and “Non-Responding facilities” from?  These are terms used in EPA’s Risk Management Plan rule, and I have said many times in my writings that not every facility is required to have…...

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