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May 14, 2020
INCIDENT OVERVIEW
A hairline crack formed in a suction header pressure gauge line resulting in a minor leakage of ammonia.
INVESTIGATION CONCLUSIONS
The suction header pressure gauge line in question was ¼ inch steel tubing which connected the ammonia suction header to the pressure gauge installed in front of the engineer’s control room so that engineer on watch can visually monitor the pressure in...
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May 14, 2020
Have you ever wondered where all the “separation distances” we see in OSHA Standards, NFPA Codes, Fire Codes, etc. come from? Who came up with them, what are they based on, etc.? All legitimate questions and you are NOT alone!! Many of these requirements have historical undocumented origins. Guidance, which may inform a sound technical basis for adjusting these distances,...
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May 14, 2020
Anyone who has attended one of my Process Safety training courses has heard me use the phrase “circuitizing your piping” when we discuss the mechanical integrity aspect for piping. API 570 is our baseline RAGAGEP for our Piping Inspection Program, but API 574 is how these inspections will actually be conducted and this standard is chock full of great information and is a MUST READ...
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May 13, 2020
Respondent is a municipality in the Commonwealth of Virginia. According to information provided to EPA, a release of chlorine gas, (CAS # 7782-50-5), occurred at the Facility on October 19, 2017, at approximately 11:40 a.m. due to a rupture of tubing connected to a chlorine tank in the chlorine room. On December 12, 2018, EPA representatives conducted an inspection of the Facility following the Release...
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May 13, 2020
Respondent owns and operates an agricultural feed, fertilizer, chemical, and grain storage and supply business with two different facilities in Iowa. On March 7, 2016, an accidental release of anhydrous ammonia occurred at one Facility while an employee was replacing a pump near a supply vessel and resulted in injuries to the employee. On or about May 22, 2019, EPA conducted an inspection of both Facilities...
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May 13, 2020
It seems it does not matter if you have land under your feet or water – process safety challenges seem to be very similar! In accordance with 30CFR250.1920(b)(5), lessees on the Outer Continental Shelf (OCS) are required to have their SEMS programs audited by an accredited Audit Service Provider (ASP) within 2 years of starting operations and every 3 years thereafter. BSEE Gulf of Mexico...
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May 13, 2020
OSHA has cited a manufacturer of steel storage tanks for exposing employees to amputation, confined spaces, and other safety hazards. The company faces $234,528 in penalties. OSHA issued 10 repeated and 12 serious safety and health violations, including failing to implement lockout/tagout procedures to prevent machines from unintentional startup, provide required machine guarding, and control permit-required...
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May 12, 2020
A few weeks back one of my good friends and a hell of a process safety professional contacted me about OSHA’s Hot Work (HW) referenced RAGAGEP, NFPA 51B. He wanted to be sure he was not missing something, as OSHA still references the Year 1962 Edition of NFPA 51B. Just to show how broken OSHA rulemaking is, NFPA 51B has been revised/updated eleven (11) times since!!! And each...
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May 8, 2020
During our process safety audits and engineering reviews for existing processes, the #1 deficiency that we still come across is the lack of piping MI inspections. However, there seems to be a major effort in getting these types of inspections completed as most auditors will now take issue if there are no “official” inspections by a “qualified person” on the process piping. So...
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May 7, 2020
So have the measures that the USA (Federal, State, and Local governments) caused more harm than good? That seems to be the debate at this stage in this pandemic. So as a profession we have been conditioned (hopefully this is changing) that the OSHA rates are a measure of safety performance. I think anyone working at a factory with 100+ people has heard of the OSHA rate – heck...
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May 7, 2020
I said it and I am proud to have said it. Back in the earliest of days when they were discussing all of the extraordinaire measures that we would need to take to “flatten the curve”, I stated that after the measures work, we will then be faced with the idea that “this was all overkill and it was not necessary” based on the success of those very measures.
We see it...
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May 7, 2020
We have tons to still learn from this event, but under the current economic conditions due to the virus, India has been in “lockdown” for five (5) weeks. This incident, happened last night, lends itself to being a “polymerization event” based on the video and photographic evidence I have seen from my India members. The ONLY way to Styrene to vent like that is during...
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