Chemical Process Safety (PSM/RMP)
How times have changed in 30 years regarding "materials of construction" in hazardous materials processes. I grew up in process safety, seeing nothing but metallic piping systems; today, I bet I see piping systems made from non-metallic products upwards of 25% of the time. This is becoming increasingly acceptable in one specific process I do a lot of work with, so I can not provide specifics as it could create a trail back to some of my clients. Just know that many of the processes are PSM/RMP-covered processes. ASME B31.3 addresses non-metallic piping systems in Chapter VII, Nonmetallic Piping and Piping Lined With Nonmetals. In this article, I want to discuss Part 10, Inspection, Examination, and Testing of Nonmetallic Piping Systems Used in a PSM/RMP-covered process. For those who are not SAFTENG members, just know that ASME B31.3 requires many of the same examination and testing requirements for nonmetallic piping systems as it does for metallic piping systems. Two (2) very CRTICIAL PROHIBITIONS for non-metallic piping are the SAME as metallic piping:
Here are the other examination and testing requirements for NON-metallic piping systems: Membership Content
Most PSSR forms we encounter simply regurgitate OSHA's 1910.119(i)(2). If the user is thoroughly knowledgeable of what each of these four (4) line items entails, we may be able to execute the PSSR appropriately. Let's look at these four line items, especially the first line.
This single line item, (i)(2)(i), INCLUDES a ton of responsibility, as well as documents/data, to embrace what it is attempting to achieve fully. This line item covers EVERYTHING (physical object) the HHC/EHS touches; however, I will discuss only how it impacts PSM/RMP piping in this article. We see a lot of PSSR in our travels, and almost all of them will have this line item signed off as completed; however, when we ask for piping installation records, we get the "deer in the headlights" look. Here is what a facility should have to sign off on this single PSSR line item properly:
The two (2) terms sound similar and will conjure up similar images when we hear them, but they are used in the ASME B31 piping standards in very different ways and apply to different groups. To state it very simply, the EXAMINATION is what the owner/operator does to pass the INSPECTION, which is what the Authority Having Jurisdiction (AHJ) does. In summary
Examination applies to quality control functions performed by the manufacturer (for components only), fabricator, or erector. Reference in this Code to an examiner It is the owner’s responsibility, exercised through the owner’s Inspector, to verify that all required EXAMINATIONS and TESTING have been completed and to inspect the piping to the extent necessary to be satisfied that it conforms to all applicable EXAMINATION requirements of the Code and of the engineering design. For many of you managing a PSM/RMP covered process, the actual work/requirements of B31.3 are inside the "examination bubble," which is where the heart and soul of the Quality Assurance measures come to life, such as:
An internal failure of a heat exchanger caused ammonia gas to leak through and absorb into the circulating liquid brine for the underfloor loop. The ammonia within the liquid brine spilled out of the expansion tank, pooling within an open sump in the mechanical room. The heat exchanger needed to be replaced as it was not repairable. The failure of the exchanger was internal between the ammonia hot gas side and the calcium chloride liquid brine side. This caused ammonia gas to escape, be absorbed by the brine side, and escape out of an open-to-atmosphere expansion tank. The heat exchanger was isolated and stopped the flow of ammonia gas over to the brine side, and as a result, there was no underfloor brine heating available to the ice rinks affected as the pump was locked out and isolated. The heat exchanger failure was caused by an internal tube failure due to corrosion caused by a failure to maintain brine chemical and system levels, which allowed oxygen to attack metal internal surfaces. Internal corrosion caused by the lack of brine system maintenance is the most likely cause of the failure.
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Facilitating Process Hazard(s) Analysis (PHA) is one of my favorite process safety skills. From having the honor to be the author of Part II in the CCPS's Hazard Evaluation Techniques (3rd Edition) to working with several software companies on the development of their PHA products, there is nothing better than facilitating an actual PHA with a talented team of Engineers, EHS professionals, Operators, and Maintenance personnel. In every one of my PHAs, I explain the process using this simple PREVENT-PROTECT-MITIGATE model. I then challenge the team to identify the safeguards they have in place that fit into these three (3) layers of protection for each scenario studied. Last week I shared a fun exercise we can do with management to gauge their knowledge of the safety barriers/controls/safeguards within their business. This PREVENT-PROTECT-MITIGATE model works in both OSH and Process Safety matters and provides a visual structure within which the team can work. Members can download the clean image without the watermark.
This is me doing a Process Hazards Analysis (PHA) with my non-American clients who use the metric system!
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