How do the Clean Air Act (CAA) risk management program requirements differ from the hazardous chemical reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA)?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Differences between EPA’s RMP and EPCRA Read More »
This is safety satire on a Friday afternoon after a long week! I may not be a Certified Welding Inspector (CWI) or a Visual Level II inspector certified per ASME V Supplemental NDE Certification requirements. Still, I believe API 570, Section 8 Repairs, Alterations, and Rerating of Piping Systems allows only a dozen or fewer…...
May be a bit out of spec for API 570 Read More »
I have spent much time with clients doing “Engineering and Code Reviews.” These have been instrumental in avoiding many issues when it comes time for the INITIAL PHA. Depending on the process size and complexity, these can take 0.5 – 3 days, but that time is spent ensuring the primary containment systems and all the…...
Engineering & Code Review; What is it and Why do it? Read More »
It is rare; I can not recall ever disputing NFPA in any of their guides/standards/codes. However, section 27.7 of NFPA 30 is worded incorrectly and needs to be called out as it poses significant risks if followed by the letter. Section 27.7 covers the pressure and leak testing of “flammable liquid” piping circuits. Although I…...
NFPA 30, Section 27.7 Testing of Piping Systems Read More »
If you want a spirited process safety debate, simply mention the practice of having “intervening valve(s)” before or after a Pressure-Relieving Device (PRD). There are some who swear that it is not allowed, but in fact, it is. This is how I learned about the “Car-Seal” program early in my career. ASME B31.12 is one…...
Add ASME B31.12 to the list allowing “intervening valves” in the PRV path Read More »
I have written many articles relating to ASME B31.3 and the QA/QC requirements each weld/flange must meet. However, in B31.12, Table IP-10.4.2-1 Required Nondestructive Examinations, the code requires 100% VT (Visual examination). The code goes on to require a more extensive examination sampling of 5-10% joints using with Liquid Penetrant (PT) or Magnetic Particle (MT). …...
H2 industrial piping requires 100% VT on welded/brazed joints (ASME B31.12) Read More »
As I dig deeper into ASME B31.12, Hydrogen Piping, I continue to find nuggets of best practices for HAZMAT piping. ASME B31.12 requires each operating company having industrial piping, pipeline, and commercial and residential systems to have Operational, Maintenance, and Emergency Plan(s) that include the following:… Membership Required You must be a member to access...
I have been working with several clients who are on a Hydrogen Fuel journey. It is fun to get deep into process safety protection schemes regarding NFPA 2 and ASME B31.12 and see the similarities and extra code requirements when dealing with large H2 gas systems. One of the interesting items regarding H2 piping is…...
ASME B31.12 – Leakage Survey Read More »
Occasionally, we see some pipe labeling requirements that exceed those found in ASME A13.1. NFPA 2, 2023 has a few: (emphasis by me)… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
NFPA’s 2 – Hydrogen Std and pipe labeling Read More »
It is good that we are finding fewer and fewer facilities without pressure testing and leak testing records on their process piping. But now comes the difficult question: Is pressure and leak testing required after maintenance or alterations on piping systems? So, most companies will have their newly installed piping pressure tested and leak tested…...
Ammonia is held for sale by a retailer in a large storage tank. The retailer sells ammonia as an agricultural fertilizer and a coolant for air conditioning systems. Section 311(e)(5) of EPCRA exempts from the definition of a hazardous chemical “(a)ny substance to the extent it is used in routine agricultural operations or is…...
Tank used to store ammonia to be used as both agricultural fertilizer and coolant Read More »
The Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards (CFATS) impose comprehensive federal security regulations for high-risk chemical facilities. Do the CFATS alter the requirements that apply to a facility covered under both CFATS and either the Emergency Planning and Community Right-to-Know Act (EPCRA) or the Clean Air Act §112(r) (i.e., the Risk Management Program…...
CFAT Impacts on EPCRA and RMP Read More »
