The 316 stainless steel pressure vessel involved had been moved into the Commonwealth of Kentucky approximately ten years prior to the accident. The vessel had originally been used as an atmospheric vessel in the manufacture of ammonium bisulfite, a raw material for caramel color, and later converted to be used as a pressurized unit.  The tanks were operated at atmospheric pressure and were equipped with pressure relief devices at the time.  

A few months ago I wrote about this new refrigerant as having the catastrophic risk of a BLEVE event. Now I wish to offer some guidance on how a business utilizing this refrigerant can reduce the likelihood of this type of event.  First, there is NO engineering standards that guide a manufacturer of an ASME pressure vessel in how to construct a pressure vessel so that it will not fail in a BLEVE event. So we can not assume that our vessel is so well designed or constructed that it will with withstand either a hot or cold BLEVE.  Our FIRST LINE of defense in managing BLEVE risk(s) is the placement of our pressure vessel(s). If our facility is in a state with an adopted fire/HAZMAT code(s) we will find some base line “facility siting” instructions in these state-adopted codes. But this new refrigerant has no specific code(s) to aid a business in how they should manage their “facility siting”. However, there are some codes and RAGAGEPs designed for other Category 1 Flammable Gases (which HFO-1234yf is) and it is these codes and RAGAGEPs I turn to when asked about tank location.

On Jan. 19, 2016, the Hartford Area Office cited a chemical manufacturer for 15 serious violations of workplace safety standards. Inspectors found that a manufacturer of swimming pool chemicals and acetone preparations used in nail polish were exposed employees to chemical, fire and exit access hazards. The company’s manufacturing processes use large amounts of the flammable chemicals acetone and isopropyl alcohol 99 percent. OSHA standards require a workplace to have a program for safely managing processes involving large amounts of these chemicals. The plant lacked a process safety management program. Deficiencies included:

At the site of an inactive gas well, two workers were flowing the high-pressure gas from the well to determine production potential. They were inside an operator's shack when a pipe ruptured, and the escaping flammable gas exploded in a fireball. Although the two workers were wearing fire-retardant clothing, they suffered burns. The smaller piping downstream from a pressure relief valve (PRV) was one of the factors that caused the piping system to fail.

We continue to see the “check the box” engineering when it comes to “ventilation” requirements for processes that fall under PSM/RMP. I have written about the design basis and the many flaws we come across regarding the actual design, but this one is becoming more and more prevalent. I am thinking “space” is becoming less available so facilities are installing their FRESH AIR INTAKES in the darnedest places.  In this article I home to educate those interested in the most basic need for a FRESH AIR INTAKE and that is…. FRESH AIR.

 
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