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FATAL flashfire in gasoline storage tank (Flammable atm)
On May 2, 2023, an employee working for a gas station and convenience store arrived to talk to a coworker (the employer) about payment for the building he leases. The employee asked the coworker if he could help him apply a fuel tank liner. The employee climbed inside the tank and plugged in his own light into an extension cord. Membership Content
EPA RMP GDC citations @ seafood processing and cold storage facility (NH3 & $20K w/ $129K SEP)
Respondents owned and operated a seafood processing and cold storage warehouse facility. The Facility is one building that consists of two separate spaces on either side of a dividing wall. One side of the Facility is used for seafood processing and packaging. The other side of the Facility is a cold storage warehouse used to store the packaged seafood. The Facility is located alongside Gloucester's Inner Harbor in a large and densely populated residential area. It is within half of a mile of hundreds of homes, restaurants, and other businesses and within a quarter of a mile of an elementary school and at least two houses of worship. At the time relevant to the violations alleged herein, Respondents used anhydrous ammonia in two refrigeration systems at the Facility. The ammonia refrigeration system on the processing and packaging side of the Facility uses approximately 1,543 pounds of anhydrous ammonia, and the ammonia refrigeration system on the storage side of the Facility uses approximately 7,075 pounds of anhydrous ammonia. Accordingly, Respondents "stored" and "handled" anhydrous ammonia, subject to the General Duty Clause. On September 15, 2022, EPA conducted an inspection at the Facility. The purpose of the Inspection was to determine whether Respondents were complying with Section 112(r) of the CAA and the Emergency Planning and Community Right t o-Know Act. The EPA inspectors toured the Facility's perimeter, roof, the ammonia machinery room ("AMR") for each refrigeration system, cold storage spaces on the first and third floors, and the chemical storage area. The Inspection and EPA's review of information provided by Respondents revealed several potentially dangerous conditions relating to the refrigeration systems. Add ASME B31.12 to the list allowing "intervening valves" in the PRV path
If you want a spirited process safety debate, simply mention the practice of having "intervening valve(s)" before or after a Pressure-Relieving Device (PRD). There are some who swear that it is not allowed, but in fact, it is. This is how I learned about the "Car-Seal" program early in my career. ASME B31.12 is one of those RAGAGEPs that allows this practice WHEN it meets certain criteria, such as a Car-Seal Program. Essential Features of the Emergency Plan (ASME B31.12)
Each operating company shall establish written procedures to minimize the hazard of an emergency. The procedures shall provide instructions to operating and maintenance personnel. The procedures shall describe the following:
Writen Operational, Maintenance, and Emergency Plan(s) for Industrial Hydrogen Piping (ASME B31.12)
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: OSHA's Heat exposure standard
On April 24, 2024, the department's Occupational Safety and Health Administration presented the draft rule's initial regulatory framework at a meeting of the Advisory Committee on Construction Safety and Health. The committee, which advises the agency on safety and health standards and policy matters, unanimously recommended OSHA move forward expeditiously on the Notice of Proposed Rulemaking. As part of the rulemaking process, the agency will seek and consider input from a wide range of stakeholders and the public at-large as it works to propose and finalize its rule. ASME B31.12 - Leakage Survey
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 NFPA's 2 - Hydrogen Std and pipe labeling
Occasionally, we see some pipe labeling requirements that exceed those found in ASME A13.1. NFPA 2, 2023 has a few: (emphasis by me) Arc Flash During Conductor Checks Causes First and Second Degree Burns
An experienced electrician checking conductors at an industrial facility unknowingly accessed an energized breaker bucket inside a substation and shorted phase to phase on the line side of the energized breaker switch at 347/600V. This resulted in an electrical shock, creating an arc flash. The worker suffered first and second-degree burns to their wrist, hand, and face.
EPA RMP citations @ repackaging facility (Cl2, SO2, Flammables & $261K)
Respondent is the facility's owner and operator. The EPA inspected the Facility from July 27 to July 29, 2021, to determine the Respondent’s compliance with Section 112(r) of the CAAmand 40 C.F.R. Part 68 (“the Inspection”). Operations at Respondent’s Facility include, among others, repackaging chlorine for utilization in sodium hypochlorite bleach manufacturing. The Facility also uses or produces several regulated flammables. The Respondent’s processes meet the definition of “process” and “covered process,” as defined by 40 C.F.R. § 68.3. The Respondent’s RMP program level 3 covered processes store or otherwise use a regulated substance in an amount exceeding the applicable threshold. EPA Findings of Violation |
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