Chemical Process Safety (PSM/RMP)
I have written many articles relating to ASME B31.3 and the QA/QC requirements each weld/flange must meet. However, in B31.12, Table IP-10.4.2-1 Required Nondestructive Examinations, the code requires 100% VT (Visual examination). The code goes on to require a more extensive examination sampling of 5-10% joints using with Liquid Penetrant (PT) or Magnetic Particle (MT). Even the VT requirements for Hydrogen piping are more specific... Membership Content
As I dig deeper into ASME B31.12, Hydrogen Piping, I continue to find nuggets of best practices for HAZMAT piping. ASME B31.12 requires each operating company having industrial piping, pipeline, and commercial and residential systems to have Operational, Maintenance, and Emergency Plan(s) that include the following:
I have been working with several clients who are on a Hydrogen Fuel journey. It is fun to get deep into process safety protection schemes regarding NFPA 2 and ASME B31.12 and see the similarities and extra code requirements when dealing with large H2 gas systems. One of the interesting items regarding H2 piping is a "Leakage Survey," which applies to "Industrial Plants." There is an ongoing debate about this "problem" with GH2 tubing and piping, and such the industry is attempting to make the argument that pressure and leak testing should be done with GH2. However, the AMSE B31.12 committee did not buy into this argument and still requires pressure and leak testing to be done with a NON-FLAMMABLE gas... IP-10.7.3 Test Fluid
Occasionally, we see some pipe labeling requirements that exceed those found in ASME A13.1. NFPA 2, 2023 has a few: (emphasis by me)
It is good that we are finding fewer and fewer facilities without pressure testing and leak testing records on their process piping. But now comes the difficult question: Is pressure and leak testing required after maintenance or alterations on piping systems? So, most companies will have their newly installed piping pressure tested and leak tested by the contractor who performed the installation. But two months into operating said piping, some maintenance work is necessary and this work will require us to OPEN the piping system, make repairs, and then return the piping to service. How many of you will include some type of integrity testing on this circuit of piping that has been opened/altered/repaired BEFORE we return it to service? Using my favorite Piping Maintenance RAGAGEP, API 570, we can see that...
Ammonia is held for sale by a retailer in a large storage tank. The retailer sells ammonia as an agricultural fertilizer and a coolant for air conditioning systems. Section 311(e)(5) of EPCRA exempts from the definition of a hazardous chemical "(a)ny substance to the extent it is used in routine agricultural operations or is a fertilizer held for sale by a retailer to the ultimate customer." For purposes of EPCRA sections 311/312 reporting, how would this combined usage of the ammonia tank be affected by the agricultural use exemption under EPCRA section 311(e)(5)? |
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