Recently, I had the opportunity to help a client gain the full picture of what has to be done regarding the BULK TRANSFER hoses to unload their HHC/EHS from Tanker Trucks/ISO Containers and Railcars. Now, before we get into the specifics, I know a number of folks will fall back on the compliance position that unloading/loading our HHCs/EHSs are DOT-regulated functions. Through my career, I have learned the hard way that the risks associated with these unloading/loading activities are among the highest in my processes (even across the entire facility!). Such that my first Node in any PHA I facilitate is to cover Unloading of the HHC/EHS. A client who does not want to include this function in the PHA is no longer a client – that is how seriously I take these matters. Do as you wish, but I do hope your facility will embrace this risk and attack it head-on using the information provided in this article.
I understand there are some questions about the decision to pressure-test and leak-test the NEW XXXXXXX unloading hose, given the events earlier this week with the previous unloading hose. I thought it might be helpful to explain Bulk Transfer Hoses through the lens of Process Safety Management (PSM). Please feel free to share this with others you feel could benefit from the content of this email.
As I have discussed with many of you, the bulk transfer of a hazardous material through a hose and the hose’s two (2) temporary connections pose a significant risk of a catastrophic event in [the process] and are among the top 10 risks in XXXXXXXX with unloading XXXXXXXXX. [SAFTENG note: both HAZMATs referred to in this are Flammable Liquids]
As a PSM-covered process, the business MUST adopt Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) related to the design, operation/use, and maintenance of bulk transfer hoses within the Battery Limits of the covered process. I have been using the Association for Rubber Products Manufacturers (ARPM) RAGAGEPs for most of my 30+ year career. This trade group was formed specifically to write these standards for chemical hoses; some are specific to certain chemicals, but their main standard was for ALL Chemical Hoses (ARPM IP-11-7, MANUAL FOR MAINTENANCE, TESTING, AND INSPECTION OF CHEMICAL HOSE).
NOTE: this RAGAGEP should be applied to ALL hazardous materials bulk transfers, including the Nitrogen unloading done by our supplier.
The business can adopt a different bulk transfer hose RAGAGEP if it chooses to; ARPM/IP-11-7 is simply the most widely used RAGAGEP in the chemical/PSM arena.
The RAGAGEP makes several KEY points regarding bulk chemical transfer hoses that drove the decision to RETIRE the leaking hose from service and to have the new hose pressure- and leak-tested. Below are quotes from RPM/IP-11-7 that are related to our CESS unloading hose(s):
Never allow chemicals to drip on the exterior of a hose or allow hose to lie in a pool of chemical since the hose cover may not have the corrosion resistance of the tube. Should a corrosive material come in contact with the reinforcing material, early failure will result. (ARPM/IP-11-7/2015, Page 4 of 8)
Our XXXXXXXXX is not only flammable, but it is also highly corrosive with a pH of 2-3; about the same pH as Nitric Acid.
Bulk Transfer Service – When chemical hose is used in normal bulk transfer service, it shall be visually inspected daily and hydrostatically tested every 90 days. The details of the examination and testing are listed below. An inspection card and recording system must be adopted for chemical hose used in bulk transfer service applications. The inspection card shall contain the following information: the hose, manufacturer, date received, purchase order number, and date of installation for each hose. The inspection card must be used to record the test results and condition of the hose. (ARPM/IP-11-7/2015, Page 5 of 8)
Our service meets the definition of “normal” service. Our Truck Unloading SOPs require the hose to be inspected for the issues noted above. But we need to place our bulk unloading hoses used in Hazardous Materials service into a Preventive Maintenance program to ensure we are testing our hose(s) every 90-days. Here is the challenge: as we learned on Friday and in the past PSM courses at XXXXXX, the preferred means to pressure test hoses and piping is HYDROSTATICALLY using water. Unless we can show that using water or another fluid creates a greater hazard, the code(s) require the test to be performed hydrostatically. This is simply due to the significant risks of performing the test pneumatically. The hose testing done on Friday, even though we requested pneumatically, was performed hydrostatically using water and the test solution. We need to work through this in the coming weeks as we build out the Work Order for this quarterly test.
NOTE: I have been referring to Annual testing, but since 2015, the RARAGEP has been requiring quarterly testing. This frequency was changed back in 2015 based on data and unloading/loading events over the years.
Daily Inspection Procedure – Each day prior to the day’s use a visual inspection shall be made. If any unusual appearances are noted the hose shall be subjected to the Pressure Test as described below. (ARPM/IP-11-7/2015, Page 5 of 8)
This requirement means we need an inventory of unloading hoses so that, when one fails its pre-use inspection, we have a spare hose ready to go. With XXXXXX handling both XXXXXX and XXXXXXXX, inventory will be very tight. Missing a truck unload will push the business’s ability to maintain production to the limit. We will have plenty of other supply chain and weather-related challenges; we don’t need to add a “failed hose” to the list of causes for a missed unload. We do NOT want to get into the business of pressure testing our own hoses, so we will need a budget item for XXXXXXXX and XXXXXXXX to rotate our hoses through testing. And since we are using our hoses in Flammable Liquid Service, these 90-day tests will include conductivity of the hose(s); although, by code, conductivity testing is annually if we choose to go with that frequency. (see more on conductivity testing below)
New Assemblies and Hose Taken from Storage – All new hose assemblies and hose taken from storage shall be tested prior to use to determine if they have been damaged in storage or shipment. Follow the method described in the section titled Pressure Test shown below. (ARPM/IP-11-7/2015, Page 6 of 8)
Normal Use – When chemical hose is subjected to ordinary use in bulk transfer applications, the frequency of testing shall be every 90 days. (ARPM/IP-11-7/2015, Page 6 of 8)
Abnormal Use – Hose assemblies used in bulk transfer or dock service shall also be tested immediately after the hose is subjected to abnormal abuse such as: severe end pull, flattening or crushing by vehicles, or sharp kinking. Any hose that has been recoupled shall be proof tested and inspected before being placed in service. (ARPM/IP-11-7/2015, Page 6 of 8)
The first and last sections above are why we wanted to pressure – and leak-test the new hose (given that the first hose was clearly not assembled properly or pressure- or leak-tested!). Soulbrain is buying a hose from a hose manufacturer and then adding special couplings. These modifications render the OEM pressure/leak test VOID, and thus the hose must be pressure and leak tested BEFORE being put into Bulk Transfer Service. We tried to have Soulbrain provide this service for us, but I am convinced this is not something Soulbrain should be doing. They pressure-tested a hose rated at 10.5 bar at a test pressure of 1.21 bar. Why they chose this test pressure could not be explained, but it is way off from being acceptable.
4. For new hose, raise the pressure to twice the rated working pressure and hold for 5 minutes. During this hold period, the hose shall be examined for leaks at the couplings, fitting slippage, or for any indication of weakness in the hose structure. The hose shall be retired from service if any sign of leaks, fitting slippage or weakness in the hose structure are found. (ARPM/IP-11-7/2015, Page 8 of 8)
5. For used hose, test with pressure of 1-1/2 times the rated working pressure and hold for 5 minutes. During this hold period, the hose shall be examined for leaks at the couplings, fitting slippage, or for any indication of weakness in the hose structure. The hose shall be retired from service if any sign of leaks, fitting slippage or weakness in the hose structure are found. (ARPM/IP-11-7/2015, Page 8 of 8)
CAUTION! Hose at 150% OR 200% of working pressure is hazardous if damage has occurred. Take all necessary safety precautions during examination. (ARPM/IP-11-7/2015, Page 8 of 8)
Please keep in mind that this hose testing is being done Hydrostatically, which permits a much smaller testing CAZ. However, a SAFE DISTANCE must still be maintained. The company we used on Friday most likely has a testing booth with cameras so they can visually inspect from afar. So even if we had wanted the original hose that leaked used again, it would have needed to be pressure/leak tested before being placed back into service.
Electrical Continuity
When required by the user, electrical continuity between the fittings shall be tested using a low voltage system. The hose must be clean and dry for this test. The procedures outlined in Chapter 6 of the ARPM Hose Handbook, “Hose Test Methods”, can be used as a guide. (ARPM/IP-11-7/2015, Page 8 of 8)
As always, if anyone has questions or concerns, please reach out anytime to discuss.
Bryan