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A Pressure Vessel subject to Internal Corrosion shall be defined as any metal Pressure Vessel using a process product that can cause Corrosion, Erosion, Pitting, Cracking, or Deterioration, as defined in Part 2, 3.3 of the National Board Inspection Code. The intent is to verify the vessel is safe to operate.  Pressure Vessels subject to internal corrosion shall receive a Certificate Inspection every three (3) years. Owner-Users qualified in accordance with Section 15 of the Illinois Boiler & Pressure Vessel Safety Act (430 ILCS 75) shall have the option of using API-510 or the NBIC for inspection intervals.  This inspection shall be external and internal where conditions permit,* however, small air receivers and domestic hot water supply storage vessels, or vessels without man-way openings, may substitute thickness readings compared to original material thickness values when internal inspection is impractical.  CLICK HERE (pdf) to see this DRAFT Document.

The Department of Homeland Security (DHS) continues to strengthen security at the Nation’s high-risk chemical facilities through the Chemical Facility Anti-Terrorism Standards (CFATS) program.  Chemical Security Program Statistics as of March 2, 2015:

  • More than 48,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest
  • 3,471 facilities are currently covered by CFATS
  • More than 3,000 facilities voluntarily removed, reduced, or
  • modified their holdings of chemicals of interest
  • 1,790 visits to assist facilities with compliance
  • 2,779 Security Plans authorized
  • 2,061 Authorization Inspections conducted
  • 1,600 Security Plans approved following an on-site inspection

CLICK HERE (pdf) for the DHS press release

There are over 75 billion pounds of hazardous chemicals regulated under the RMP rule.

Top Five (5) RMP Chemical Quantities

As I posted back in August 2014, CAL EPA was looking to make changes to the CALARP rule.  The proposed petition process was rejected but the rest of the package was accepted and were approved by the Office of Administrative Law and took effect on January 1, 2015.. The Governor’s Interagency Task Force on Refineries has suggested additional amendments that are being considered for the next update.  Persons interested in reading the rulemaking file, including the final statement of reasons may do so by appointment at Cal OES headquarters, 3650 Schriever Avenue, Mather, California 95655. For questions please contact Jack Harrah, phone: (916) 845-8759 or email: This email address is being protected from spambots. You need JavaScript enabled to view it..   

Here’s a look at the Amendments, as well as the NEW CalARP Regulations (2015)…

Regulation Amendments for 2015 (pdf)

CalARP Regulations 2015 (pdf)

A look at what changed can be seen in my August 2014 Post Some interesting changes coming to CalARP.  It appears all the proposed amendments were adopted as proposed.

This is an interesting turn of events!  The ALJ upholds most of the citations and then OSHRC vacates them all. This after a 750 pound relase of butylene oxide that occured during a line break activity and was caused by an IMPROPER energy control plan.  One worker was was diagnosed with “chemical pneumonia” due to his exposure to the cloud and the two workers directly involved had to decon in a safety shower to stop the burning of thier skin.  The contractor fired their employee involved for not following SWPs and the facility fired the operator for the improper energy isolation.  Yet the OSHRC vacated the citations on what I can only call "technicalities".  But wow... if lawyering up can get you to NO citations after an incident like this...just wow!  Here's the facts as presented in the OSHRC decision..

A contractor was engaged to perform maintenance at a chemical production plant in May 2010. Both the plant and the contractor were engaged in a process known as a “Test and Inspect turnaround” (“T&I”), which required the shutdown of certain equipment for maintenance purposes. As part of the T&I, a contractor crew was assigned to remove eight emergency shutdown devices (“ESDs”) on some chemical lines and replace them with new ESDs. This required that the ESDs first be isolated pursuant to the plant’s energy control procedures. During the isolation process, a gate valve on a butylene oxide line was found to be leaking and had to be replaced before the ESD work could continue. The plant did not assign this particular work to the contractor and indicated that plant personnel would perform the work. Nevertheless, after an operator mentioned the job task over the radio, a contractor employee offered to assist. 

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I am Speaking

Stop by session 721 on

Wednesday 6/10 @ 7:45 a.m.

Process Safety Management

Enforcement Trends and Best Practices

I am also teaching a

1-Day PSM Course

"Implementing a World-Class PSM Program"

Course # 910

as a POST CONF Seminar

on Friday 6/12/15