This is a follow up to my July 2013 article “Making the case my PSM/RMP covered process complies with RAGAGEPs (Piping)”. With OSHA’s recent memo on “RAGAGEP in Process Safety Management Enforcement” I have received renewed request to explain how a facility can demonstrate their vessels/tanks comply with RAGAGEP(s). Here it goes:
You are sitting across the table from a CSHO and he/she ask you for documentation to show a particular vessel within your process “complies with RAGAGEP”.
1910.119(d)(3)(ii) The employer shall document that equipment complies with recognized and generally accepted good engineering practices.
What do you do?
I will use a flammable liquids storage tank as my working example, but this method of documenting compliance can be used for all types of tank/vessels.
First, if the vessel is a pressure vessel AND the vessel was built to ASME Section VIII, Division 1 or 2, provide the U1 form for said vessel. If the vessel is an atmospheric (atm) or low-pressure vessel then we should use one the following as an example of our chosen RAGAGEP(s):
- API Specification 12B, Bolted Tanks for Storage of Production Liquids
- API Specification 12D, Field Welded Tanks for Storage of Production Liquids
- API Specification 12F, Shop Welded Tanks for Storage of Production Liquids
- API Standard 650, Welded Steel Tanks for Oil Storage
- UL 58, Standard for Steel Underground Tanks for Flammable and Combustible Liquids
- ANSI/UL 80, Standard for Steel Tanks for Oil-Burner Fuels and Other Combustible Liquids
- ANSI/UL 142, Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids
- UL 1316, Standard for Glass-Fiber-Reinforced Plastic Underground Storage Tanks for Petroleum Products, Alcohols, and Alcohol-Gasoline Mixtures
- ANSI/UL 1746, Standard for External Corrosion Protection Systems for Steel Underground Storage Tanks
- UL 2080, Standard for Fire Resistant Tanks for Flammable and Combustible Liquids
- ANSI/UL 2085, Standard for Protected Aboveground Tanks for Flammable and Combustible Liquids
- API 620, Recommended Rules for the Design and Construction of Large, Welded, Low-Pressure Storage Tanks
All of these flammable liquid vessel RAGAGEP’s contain specific requirements for how the vessel is to be built and installed. Keep in mind OSHA will then use our chosen RAGAGEP as their inspection guide! We will need to have DOCUMENTATION that we followed our chosen RAGAGEP from conception to maintenance. From this point on, I will use NFPA 30 as my overall RAGAGEP for my flammable liquid storage tank (of which all of the above design/construction codes are listed).
Second, we need to be able to show that we had the vessel built for our process conditions. We need to be able to show the reason why this vessel is a pressure vessel vs. atm vessel and why the MAWP of our pressure is XXX psig @ XXXF and not some other abstract design basis. If the vessel received a special treatment such as Post-Weld Heat Treatment (PWHT) we need documentation of such treatment and an explanation as to why this special treatment was called for in its design. (NFPA 30, 21.4 Design and Construction of Storage Tanks.) Keep in mind that some of the large volume atm/low-pressure tanks are “built in place” and we do not get a U1 form once they are completed. So in regards to our documentation, we need the vessel as-built drawings with an engineer’s sign-off that the vessel was built to our chosen design. Some vessels may have a liner inside them for corrosion protection – this liner needs to be DOCUMENTED and a rationale for it made.
Third, we need to be able to show the materials of construction for the vessel are compatible with our process materials and conditions (inside and outside the vessel). (NFPA 30, 21.4.1 Materials of Construction.)
Lastly, we need to be able to demonstrate that the vessel was INSTALLED per the code. We need records for our tie-in welds, pressure/vacuum leak tests (NFPA 30, 21.5 Testing Requirements for Tanks), documentation that a final walk down was completed with the installer, etc. (NFPA 30, 22.16 Installation Instructions for Aboveground Storage Tanks)
Once we have convinced the CSHO that our vessel(s) was built and installed per our chosen RAGAGEP(s), the next logical progression is to move to the venting and/or relief system on the vessel and I will write about “relief systems” in detail next, but there are some items regarding normal “breathing” that are an absolute part of tank design and RAGAGEP that I will mention here.
These process vessels, pressure and atmospheric, will also require a separate foundation for which it will be built or sit upon. This foundation is CRITICAL to the life span of the vessel, thus, we need documentation and assurances from the engineer that designed the foundation and the builder who built the foundation that everything was done per our chosen RAGAGEP. The foundation could be as simple as a concrete pad or saddles, but they are VERY important to the vessel. (NFPA 30, 22.5.1 Tank Supports and 22.5.2 Foundations for and Anchoring of Aboveground Storage Tanks). SAFTENG Members should read my post Flammable Liquid Tanks on “Legs” as I discuss another aspect of RARAGEP – fireproofing the legs (i.e. foundation) of these tanks.
Bonding and grounding are items that can sometimes get lumped into vessel design. I personally put bonding and grounding systems into my “safety systems”, but either way, if the OSHA CSHO begins to ask questions about the grounding of the vessel, we need to have the design of the grounding system available. For example, how is the vessel grounded? Does it have its own ground rod, is it tied into the grounding grid in the concrete foundation, etc? What was the grounding system designed to (e.g. how much/little resistance)? And since we are talking about grounding the vessel, I should mention “dip-legs” on flammable liquid tanks. These dip-legs will be a requirement for any vessel BUILT for flammable liquid(s) service. So it is easy for us to find a vessel in a flammable liquids process that does not have a dip-leg, and at that moment, we know we may have an issue. These dip-legs are designed so that we are not splash filling vessels (huge static generator). Of course, if a facility chooses to use an inert gas to purge the vessel head space below the flammable atmospheres limiting oxygen concentration (LOC) then maybe they have a defense for not having a dip-leg in the tank(s). I have taken issue with this approach – not that it is unsafe, but that questions arise about the intended design of the vessel. Any engineer who builds/orders a vessel for a flammable atmosphere will do so with a dip-leg; having a process vessel without one opens a can of worms for the CSHO or auditor. (NFPA 30, 21.4.4 Tank Fill Pipes)
Another aspect of the atmospheric tank that we need to document is the venting system, both normal breathing and fire venting. NFPA 30 establishes some minimums for both normal venting (NFPA 30, 21.4.3 Normal Venting for Storage Tanks) and fire/emergency venting (NFPA 30, 22.7 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks).
So now we are starting to get an idea of specific documentation we would need to demonstrate our tank/vessel complied with our chosen RAGAGEP, but we are not quite finished.
Not to sound like a consultant, but we need to have every aspect of our vessels documented. Even their location and spacing between the tanks can become an issue, their arrangement within a tank farm can become an issue, etc. OSHA/EPA can use this RAGAGEP requirement to cite or they may use the PHA “Facility Siting” requirement if the PHA did not address the location/position/arrangement of these tanks. But it is easy to look to almost all the Flammable Liquids RAGAGEP and see the location, spacing, the arrangement can all be traced back to an RAGAGEP. Here are some “siting” specifics from NFPA 30:
22.4.1 Location with Respect to Property Lines, Public Ways, and Important Buildings.
22.4.2 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks.
So there we have a look at the documentation we would need to demonstrate that our flammable liquid vessel meets our chosen RAGAGEP(s): the chosen construction RAGAGEP for the tank/vessel and NFPA 30. I used NFPA 30 as my chosen RAGAGEP, but there are others that can be used. I would like to end with answering a question we get asked often…
“Can I just comply with 1910.106(b) and be in compliance with 1910.119(d)?”
That is a question for an attorney – not a safety engineer, but our position is that 1910.106 is a darn good start in managing your flammable liquid hazards. However, we believe that if OSHA meant for 1910.106 to be the sole requirement of a flammable liquids process that exceeded 10,000 pounds they would have said so. We believe that although .106 contains some great baseline requirements, a PSM-covered process that has over 10,000 pounds of flammable liquids needs to step up its game in reference to the degree of hazards that process presents. So NO, merely complying with 1910.106 would NOT, in our professional opinion, demonstrate compliance with 1910.119. Remember, 1910.106 was taken from NFPA 30-1960’s version so it is badly out-dated. PSM is a “performance-oriented” standard and has higher expectations. I have written dozens of articles about 1910.106 requirements and made mention of how these requirements could/would play out in a PSM-covered process, but be warned, NFPA 30 has these same requirements and OSHA would be referencing NFPA 30 (or your chosen RAGAGEP) in their PSM citations if we failed to meet our chosen RAGAGEP. If a facility is really behind in the game and they have not yet documented their chosen RAGAGEP, I can assure you OSHA will choose NFPA 30 for them and reference NFPA 30 in all their PSM citations.
I will end with a PSM Tip… PSM allows us to CHOOSE our RAGAGEP(s)! This gives us tremendous flexibility in how we CHOOSE to manage our hazards. But if we fail to CHOOSE our RAGAGEP(s), rest assured OSHA will “suggest” some for our process in the citations they will be issuing!
PLEASE see my other articles where I talk about the activities that are used to show our process was built to an RAGAGEP:
A Process Hazards Analysis is NOT an “engineering review” – Part II
A Process Hazards Analysis is NOT an “engineering review”