Flammable liquid Presure vessel and piping inspection 1

[LAMAN75]

Are there any mandatory inspection intervals on piping pressure vessels and equipment containing flammable liquids by OSHA Standards? If so what is the publication reference? I have looked through OSHA 1910 but I can`t seem to find a mandatory time limit on inspection intervals or the documentation requirements.

 

[Rich2001]

Mandatory inspection intervals - none in the direct standard however there are some in the standards that rae incorporated by reference.
I have listed a few below.

Standards that include inspection information are incorporated by reference as specified in Sec. 1910.6:


National Fire Protection Association Standard for Drycleaning Plants, NFPA No. 32-1970;


National Fire Protection Association Standard for the Manufacture of Organic Coatings, NFPA No. 35-1970;


National Fire Protection Association Standard for Solvent Extraction Plants, NFPA No. 36-1967;

National Fire Protection Association Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines, NFPA No. 37-1970;

ASME Boiler & Pressure Vessel Code

___________________________________________________________

Obtain a copy of "National Board Inspection Code -- 2001 Edition --- NB-23"

http://www.nationalboard.org/catalog.html

This American National Standard is a required code in many jurisdictions of the United States and Canada. Provides rules and guidelines for inservice inspection of boilers, pressure vessels, piping and pressure relief valves. Also provides rules for the repair, alteration, and rerating of pressure-retaining items and repair of pressure relief valves. Serves as a manual for inspectors to help maintain uniform administration of boiler and pressure vessel rules. Now also includes "VR" requirements. (Technical) Required for all "R", "NR", "VR" and O/U certificate holders.

___________________________________________________________

You might want to contact your juridision's chief boiiler & pressure vessel inspector or your insurance company to find out what their requirements are.

http://www.nationalboard.org/members/mb_index.html

 

[RPG]

Refer to the Mechanical Integrity section of 1910.119 PSM Standard for a good model of a system for inspection. Time intervals for inspections are what ever you choose, BUT be ready to defend the interval you selected should a failure occur. Typically you would select a very conservative frequency of inspection and based on data/experience/amount of safety factor in the material of construction/etc. the frequency can then be adjusted. In this way you have a solid justification for making the decision. In many cases the interval can be increased initially and then will shorten as the life of the equipment increases and wear/corrosion takes hold.

 

[MJCronin]

LAMAN75,

Each owner of a facility containing piping/equipment transporting, processing and or storing flamable liquids must develop a plan for inspection. OSHA has regulations about "Process Safety Management" planning, regulations and guidelines. Your state may also require developed and implemented plans....

The plan must take into consideration the specific liquids processed or stored and the unique aspects of your facility.

Having said that, be aware that PSM plans for most piping systems and tanks/pressure vessels involves (as a minimum)annual visual inspections for external corrosion and leakage. Tanks must also be periodically emptied, cleaned and internally inpected. Typical intervals for internal inspection (after the original commisioning inspection) are two to five years.

The American Petroleum Institute has published guidlines (API-579)on system inspection and "fitness for service".

You may want to consider having an outside contractor perform this service....

Try these websites

http://www.fitness4service.com/news/2002/api579course.htm

http://www.becht.com/index.htm

http://www.hghouston.com/services_4.html

http://www.thielsch.com/ppiffs.htm

Good Luck..........


Let us know how you make out.....

MJC

 

[LAMAN75]

MJ, thank you for your response, as you stated: Each owner of a facility containing piping/equipment transporting, processing and or storing flamable liquids must develop a plan for inspection. OSHA has regulations about "Process Safety Management" planning, regulations and guidelines. Your state may also require developed and implemented plans....In your statement " must develope a plan for inspection" Where in the osha regulation publication can I find a difinitive statement that requires inspection, it just kind of seems like the plants have a loop hole because there are no time limits on inspection as far as I`ve seen. It seems also that they are able to set there own intervals of inspection because there are no laws giving time limits on inspection.

High pressure steam vessels running at 2000 psig and 500f are typical in many plants, are there any inspection intervals set by osha or any goverment agency. If a pinhole leak would develope it would be able to cut a man in half........ Thanks for your help

 

[MJCronin]

LAMAN75,

According to my best understanding of the convoluted OSHA PSM situation......

To directly respond to your question, OSHA does not directly specify inspection intervals.....and, yes the owner is able to determine his own intervals "based on the characteristics of his specific system"

Several organizations offer thier services to plant owners in development of a PSM plan.......and, yes this does seem like a loophole to me too.....

Based on the description of your "high-energy" systems, you should know that some engineering firms offer software to help in the determination of PSM inspection intervals.

See this link:

http://www.misolution.com/Newsletters1/NL11.pdf

The Canadians are more straightforward......this TSSA guidline is interesting.....

http://www.tssa.org/boilers/advisories/sb00_18_rev2.pdf

These people are still developing guidelines....

http://www.forengineers.org/mpc/HEPP.html

The APTECH people have been involved in this field for a long time...

http://www.aptecheng.com/AES100.PDF

Hope that this helps

MJC

 

[LAMAN75]

MJ ,thanks again for our response, the issue at hand is the lack of inspections performed on equipment that has potential for harm to human life if there is a faillure. The reason plants are guilty of inproper inspection intervals is a matter of dollars and cents, it simply cost them money to inspect, the down time and the cost of the repairs inspections will reveal. I find it hard to believe that OSHA or some other government agency does not get involved in a mandatory inspection interval. The plants are required to have an inspection program but it`s like their on the honor system or something. I`m here to tell you from what I`ve seen they aren`t very honorable. I can tell you for a fact, the above mentioned equipment ( steam vessel operating at 2000 psig/ 600f )has not been shut down to perform the proper inspections for 37 years, now how can some one tell me that there isn`t` a law against such neglegents. This is only one example ,I know of many more.These plants are choosing cost control over safety every time if they "think" they can get away with it. When OSHA drives into these plants, all they see is safety posters, billboards,and strick policies inforced upon the workers at these plants. But the real hazards are overlooked (not properly maintaining their hazardous equipment). Many of these plants were built in the 60`s and 70`s and they are in a deteriated condition and it`s only a matter of time before they experience catastrofic failure. My question is, are OSHA and other governmental agencies aware of the neglect in these plants? My answer is yes they are aware but are not willing or don`t care enough to do anything about it. I also beleive that these plants have soo much money, they roll right over OSHA and anyone else that gets in there way. I see it happen every day.

 

[MJCronin]

LAMAN75,

Are you asking if lies, bullshit, corruption and MBAs will always trump honesty, virtue, common sense, and personal reponsibility ?

OF COURSE !!!!!!!!!!!!!!

I am guessing that you are either a young engineer or someone who is new to the site........ Do you think that your reasonable observations of conditions that have existed for many years and compliance with national and state law is new to the owners and operators of the facility ?

OF COURSE NOT !!!!!!!!!!!!

These people are probably aware of dangers that you haven't even discovered yet !!!! They are graduates of some state school somewhere and are hoping that they can get to "bonus time" or retirement before the big explosion/fire !!!

Think I am a little crazy or bitter ?

Go to

http://www.csb.gov

and start reading the reports......Read about systems that were run beyond thier design capacity or by "contract employees" (read "poor mexican&quot who get burned or killed in the process......

Read about the MOTIVA sulfuric acid tank disaster and tell me how many pieces that the welder was blown into when he struck an arc near a tank vent. You can also read about the state govenor who was so "outraged" that she wrote a two page letter to the plant manager because of the accident.

There is plenty of money to hire slimeball attorneys after the chemical plant accident......but no money to prevent it

Want more ? Purchase and read "What went wrong ? by Trevor Kletz......... a fine accident anthology

Watch your back, LAMAN.......most MBA management has a tendency to try to blame those that identify a systematic problem after it has been uncovered and punishment is immenent....

My thoughts only....

MJC

 

[LAMAN75]

MJ, I agree with what you say , no doubt. The point I`m trying to make is that the government should be involved in all safety aspects of plant operation. Leaving it up to the plant management is gross neglect on the governments part. Making sure that employees wear safty glasses and ear plugs is not enough, the plants equipment is the real danger that is of the utmost concern. The government/OSHA needs to step in and (at the plants expence)monitor the inspection activities to insure the equipment is inspected and repaired properly. It`s the only way I can see that will insure proper maitainance of the piping, tanks and pressure vessels that can and "has" flatten a city block in a matter of seconds. THE HONOR SYSTEM DOES NOT WORK!!!!

 

[JOM]

What exactly is the "philosophy" in the US re government regulation and inspection?

Here in Australia, the philosophy is definitely a "hands-off" approach to safety in the petrochem industry. Our governments do not want prescriptive regulation, but go for a performance-judged regime.

Inspection still occurs, but operators are free to design and run plants in their own way. The governments will not tell them how.

Cheers,
John.

 

[RPG]

If you look at the budget that OSHA has versus EPA, you will learn why EPA has more teeth than OSHA. The money /manpower does not exist for OSHA to be in every plant telling them how to do things. Even if they could, history shows us that a small facility can cause fatalities just like a big facility. Ultimately it comes down to doing the right thing. And if your facility doesn't, the consequences are fatalities and a Plant Manager going to jail. If you are in the loop and let things go unnoticed then the authorities may need another set of handcuffs if something happens in your facility. I think enough has been said about this topic. YOU need to do the right thing. My motto to live by is: go home each night knowing that you have done all that you can do and you did not turn a blind eye to a problem.

 

[LAMAN75]

In my opinion OSHA should step in , regulate and monitor inspection and repair activities in these plants. The expence incured for this should be paid by way of a required permit to operate by the government ( NOT THE TAX PAYERS)By the way "RPG" I am definately not in the loop and would never condone accepting substandard inspection practices. Something has to be done about this situation and I am not in the position to administer the remedy but any OSHA representative reading this can at least look in to it.

 

[LAMAN75]

Del. wins oversight of Motiva refinery
Agreement settles government lawsuit

By JEFF MONTGOMERY
Staff reporter
12/16/2003

State regulators on Monday won unprecedented oversight of safety and maintenance management at Motiva Enterprises' Delaware City Refinery, settling a government lawsuit over repeated accidents at the complex.

Under the pact, Motiva Enterprises agreed to a three-year, state-supervised overhaul of programs at the Delaware City Refinery. Motiva will pay for independent audits of the company's progress, with reports delivered to the state by an engineering and safety contractor.

Gov. Ruth Ann Minner demanded the concessions in 2001, after a deadly explosion and fire in a sulfuric acid tank at the refinery. Subsequent investigations led to the consent order filed Monday in Chancery Court that gives Motiva from six months to three years to complete 15 tasks recommended by the same engineering consultant who will audit the work.

Early priorities include completing overdue inspections and repairs, with provisions for automatic daily fines of as much as $2,500 if Motiva misses deadlines.

Delaware officials said they were unaware of any other state where government safety oversight had reached as deeply into refinery operations.

"Having it filed with the court sets a precedent, as far as I know. This is the first time I know of that a state has entered into an agreement for plantwide inspection and maintenance," Minner said Monday.

Motiva officials said the company already has completed a number of the recommendations.

"We remain committed to improving the plant's safety and environmental performance and are doing so" through an industry certification process and other programs, refinery manager Frank Wheeler said. He said the company has made some progress but there is still more to do.

State regulators based the order on a sweeping "mechanical integrity" review commissioned by the state and completed earlier this year by Houston-based ABSG Consulting. ABSG found the Delaware City Refinery was "below the industry norm" for proper upkeep and operation of its equipment.

Motiva has faced a string of lawsuits and regulatory sanctions since the July 17, 2001, explosion that killed a Pennsylvania man and injured eight other workers. More than 1.1 million gallons of gasoline-laced acid spilled during the accident, later blamed on neglected maintenance and overlooked warnings.

A civil case seeking more than $50 million in penalties for federal and state air and water pollution violations is pending in U.S. District Court. Motiva, the state Department of Natural Resources and Environmental Control and the Environmental Protection

Agency are in settlement talks in that case.

Problems persist at the plant, however, with Motiva reporting the failure of a major pollution control system and excess emissions of hydrogen sulfide, ammonia, carbonyl sulfide, hydrogen cyanide and sulfur dioxide as recently as Sunday.

"They've been trying. They've had some problems but they continue to try," Minner said. "We need to make sure that we stay on top of it."

Provisions in the latest settlement include:

* A six- to 18-month deadline for completing higher-priority tasks, such as safety training for workers and development of new procedures for temporary repairs and reporting on inspections of equipment that operates under pressure.

* A three-year deadline for other changes, including development of safety-related record-keeping and monitoring programs.

* Automatic penalties ranging from $300 to $2,500 per day for missed deadlines.

* A $30,000 payment to the DNREC for oversight costs.

State officials said in 2001 that the acid tank explosion was a symptom of misplaced corporate priorities - "too much emphasis on productivity and not enough emphasis on the safety of that refinery," Minner said. Weeks after the explosion, she said Delaware would consider a shutdown if company officials balked at reforms.

"The baseline here was industry standards," said David Small, deputy DNREC secretary. "This is really about the oversight and administrative and management system that the refinery has in place."

 

[MJCronin]

LAMAN75,

Thank you for the update to this thread.....

I believe that the dates tell the true story....

The MOTIVA disaster occured in July 2001, a man was killed, the acid tanks were in terible shape for a long time "Governor Ruth Ann's" statement is dated December 2003.

The state of Delaware turns a blind eye to all operations until there, of course, there is a vote threatening disaster....

Until a politician might not get re-elected.....

Then the slimeball/lawyer/politicos get "outraged at the situation and demand change !!!!!"

The politico's wrath, of course is directed ONLY AT A PARTICULAR COMPANY and ONLY FOR A SHORT TIME

The obvious, common sense solution,......third party (or state)review of safety is never selected. More civilized countries than the United States (like Spain/Germany/England) implement a third party review

There have been other accidents at other refineries/process chemical plants involving explosive vents....workers have been killed/dismembered in the past......this will continue in the future

same as it ever was....same as it ever was.......

MJC

"There comes a time in the affairs of man when he must take the bull by the tail and face the situation." W.C. Fields