Most of my clients who are users of Chlorine (Cl2) use it in vacuum systems where the Cl2 is being injected or inducted into a water flow. In these smaller “processes” it is not unusual to find “tubing” being used vs. hard pipe. It took me years to accept the tubing design model as I was always raised that Cl2 is a Category M Hazardous Material per AMSE B31 and thus the piping had to meet additional installation parameters above and beyond say what Anhydrous Ammonia piping would have to meet. So to say I was taken back when I walked into the first Cl2 Cylinder room/building as a consultant and saw a lot of “tubing” being used is a bit of a stretch – luckily I was with an old friend who hired me to help with his Cl2 process.
As both OSHA and EPA requirements, when it comes to the Mechanical Integrity of our containment systems, we start with the manufacturer’s requirements…
1910.119(j)(4)(iii) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.
or
ยง68.73 Mechanical integrity
…
(3) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.
And with this tubing, we have some STRICT manufacturer’s replacement frequencies…