Liquid chlorine has a very high coefficient of thermal expansion. Relatively small increases in liquid chlorine temperature can create enough pressure to cause a blocked-in section of piping to rupture or leak at the connections. A temperature rise from 14°F (-10°C) to 32°F (0°C), will expand liquid chlorine by 2%. However, in a contained volume, the same temperature rise will increase the hydraulic...

Leak testing should be done once the piping system is completely assembled. The purpose of a leak test is to ensure all connections and components will not leak chlorine when pressurized. Leak testing is not a substitute for pressure testing. If the system was not disassembled and reassembled as part of the pressure testing and drying process, the nitrogen/dry air test (i.e. Step 1) may be omitted. Step...

The Chlorine Institute has revised its piping RAGAGEP and it is FREE for anyone who wants it.   Pamphlet 6 – Piping Systems for Dry Chlorine, Edition 17 contains major revisions to the following sections, in addition to minor clarifying changes throughout the pamphlet: … HomeRead More »

PHMSA provides written clarification regarding the pipeline safety regulations found at 49 CFR parts 190–199 in the form of FAQs and other guidance materials. PHMSA is requesting public comment on a set of DRAFT FAQs that were developed by the Working Group that was established by the Gas Pipeline Advisory Committee (GPAC) and the Technical Hazardous Liquid Pipeline Safety Standards Committee, also...

The short and simple answer is YES. It is, without a doubt, a PRCS.  This debate is much like the “Is an Evaporative Condenser a PRCS” discussion.  This week, I was presenting at the 2020 Refrigerating Engineers & Technicians Association (RETA) virtual conference, and my presentation was “Evaluating Your Ammonia Refrigeration System to determine if certain equipment...

EPA has reached an agreement with a Nitrogen manufacturer to resolve federal civil environmental violations of the Clean Air Act’s chemical accident prevention measures and of federal laws requiring timely notification of chemical accidents. EPA identified these violations following an anhydrous ammonia release that led to thirteen workers being injured at the facility in Arizona. The facility, which...

This is SIGNIFICANT for those who truly believe in the purpose and function of OSHA’s LOTO standard.  I was never more disappointed in an ALJ than after they decided to vacate such a clear violation of LOTO.  I may have even said, “Why do lawyers/judges make for bad safety professionals.”  This fatality involved an apprentice for an electrical contractor working at...

After a boiler exploded at a refinery, OSHA cited the refinery’s owner for violating 29 C.F.R. § 1910.119, which sets forth requirements for the management of highly hazardous chemicals. The Occupational Safety and Health Review Commission (the Commission) upheld the violations. In doing so, it noted that the refinery had previously violated § 1910.119. But it determined that these prior violations...

Have you ever been told… “it moves too slow to be a hazard”?  If you stay in the safety profession long enough, you will be presented with this viewpoint.  But LOTO is NEVER about how slow something moves; there is no exemption in the standard for such a thing.  Here is a case we can use to demonstrate that the speed at which a hazardous form of energy moves does NOT...

The RMP Amendments finalized on January 13, 2017, included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93).  The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018.  Because the RMP Amendments were not effective until September 21, 2018, are...

Program 1 eligibility under 40 CFR §68.10(b) is contingent upon the process NOT having had an accidental release of a regulated substance that led to offsite death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk management plan submission. Additionally, as part of the hazard assessment required under 40 CFR §68.42(a), sources are required...

As one of its core research focuses, the U.S. Environmental Protection Agency’s (EPA’s) Homeland Security Research Program (HSRP) is interested in refining its tools and methodologies to better characterize the fate and transport of hazardous contaminants during all phases of an emergency response. Atmospheric dispersion modeling is one tool that can be used for effective emergency preparation or response...