If you can tell, I was at a flammable liquids processing facility last week for an introductory visit. It did not go well as we could not agree on basic compliance measures and RAGAGEP practices associated with PSM-covered and non-covered processes. One of the major pushbacks I got was their use of some ancient, non-nameplated cast iron vessels. There is NO history on these vessels, no U-1 forms, no welding records, no fitness for service records, etc. They are atmospheric vessels ranging from 500 to 3,500 gallons, and they process CAT 1, 2, and 3 flammable liquids. Minus the documentation issues, we have a severe RAGAGEP issue with Cast Iron being the material of construction…
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UCI-2 SERVICE RESTRICTIONS Cast iron vessels SHALL NOT be used for services as follows: (a) to CONTAIN LETHAL OR FLAMMABLE SUBSTANCES, EITHER LIQUID OR GASEOUS (b) for unfired steam boilers [see U-1(g)(1)] (c) for direct firing [see UW-2(d)] |