I recently received a question from a client about “piping inspection methods for newly installed piping”. It seems that a general contractor was advising the facility that they were “required” to do some “thickness testing” on newly installed piping as part of the installation QA/QC. The PSE asked me “So are we required to take […]
This is an EXCELLENT LOI from OSHA that covers three (3) IMPORTANT aspect of PSM applicability: Co-Location of smaller containers of flammables that could be impacted by a single event (i.e. fire) Once a process is PSM covered it remains such UNTIL such time the employer puts in place a means to LIMIT the quantity of the
The car manufacturers have begun using a new refrigerant for our cars and trucks air conditioning systems. This new refrigerant, HFO-1234yf, is received by truck, stored as a liquified (pressurized) gas, and dispensed into the vehicles A/C unit. The piping associated with this storage and transfer of this refrigerant must meet…
We see a lot about Corrosion Under Insulation (CUI) as it relates to piping, but we can not forget that the same failure mode can occur on vessels as well. API 510 spells out some ranges as to when we MUST consider the need for a CUI inspection on our vessel(s).
Sorry for a lack of posts these last couple of weeks, they have been crazy with travel and work. But I wanted to follow-up on a lot of questions and comments I got regarding my “Internal inspections… of my pressure vessel??? We don’t need no internal inspections” post a few weeks back. If your engineers/management
One way EPA selects facilities to be inspected is by “Vulnerable Zones”. These are areas that could be affected by a release from a chemical accident at a facility subject to the risk management program requirements in 40 CFR Part 68. So how can a facility determine if they are one of the many facilities that impact a “vulnerable zone” and
The Ontario Recreation Facilities Association Inc. (ORFA) has reviewed the Fernie, BC Ammonia Triple Fatality investigation report produced by Technical Safety British Columbia (the safety authority and governing body for pressure vessels and operating engineers in BC), and offers the following comparative as it relates to Ontario related legislation, regulations, and registered refrigeration plant operational
Catastrophic rupture of dead-leg pipe-work Issue Date: 20.08.2019 Target Audience: Operators of Process Plant (and associated inspection bodies) which may have pipe-work dead-legs on toxic, flammable, dangerous to the environment or other critical services. Oil and gas (onshore / offshore) Chemical processing and production Nuclear Pharmaceutical Power production Key Issues: This safety alert highlights the
Pursuant to the risk management program regulations under 40 CFR §68.10(b), Program 1 eligibility requires that the process has not had an accidental release of a regulated substance that led to off-site death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk management plan submission. Additionally, as
In section 2, element 2.5, of an RMP, facilities must report the quantity of toxic chemical that the facility used for the worst-case analysis. When reporting this data element in RMP*eSubmit for a mixture, should facilities report the entire weight of the toxic mixture potentially being released or only the amount of the regulated toxic
UPDATED 9/26/22 Pursuant to the Risk Management Program regulations, the owner or operator shall identify and analyze at least one alternative release scenario for each regulated toxic substance held in a Program 2 or Program 3 process above its threshold (40 CFR §68.28). If a facility has both ammonia and ammonia (anhydrous) on-site above their
