Category Archives: Good Engineering Practices

Relief Systems – Understanding Design and Design Basis

In compliance audits all over the country, we’re finding that the requirements for documenting the relief systems are not being met in many PSM programs. How bad is the situation? About 1/3rd of the relief documentation we see shows that … Continue reading

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What’s the deal with Valve torque?

A common question I get is whether or not flanged and bonneted valves need to be torqued when they are installed. Unfortunately, many of these questions are due to OSHA citations – Ideally you want to answer this question BEFORE the … Continue reading

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IIAR 2 and IIAR 4 up for public review

IIAR Standard 2 (Safety Standard for Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems) and IIAR Standard 4 (Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems) are available for public review on the IIAR website. While being an IIAR member … Continue reading

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CSB Releases Safety Video on 2009 Fatal Blast at NDK Crystal – Animation Depicts Stress Corrosion Cracking; Vessels Were Not Inspected or Tested

Today the CSB issued a report on a 2009 vessel failure that it blamed on Stress Corrosion Cracking. There are some interesting lessons to be learned about incident investigation in this report since the mechanism that led to the vessel’s … Continue reading

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Do your Emergency Shut-down and Ventilation switches comply with IIAR2-2008b/IIAR5-2013, Appendix B?

IIAR5 was released just recently and a surprising number of people think that it introduces new requirements for emergency switches. The requirements themselves don’t differ from IIAR2-2008b – they are just laid out a little clearer in IIAR5, Appendix B: … Continue reading

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OSHA to revise Palmer guidance on Hydrostatic Trapping

OSHA and the IIAR have not seen eye to eye on the issue of Hydrostatic trapping since 2006 when OSHA issued the Palmer interpretation letter which said the following: If a liquid expansion hazard exists and the only safeguard to protect … Continue reading

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Five Year Independent Full Inspection

IIAR Bulletin 110, Section 6.4.4 calls for something called an “Independent Full Inspection”: At least every five years, the annual inspection of the vessels and heat exchangers shall be carried out by a competent person independent of immediate commercial and … Continue reading

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Maximum Intended Inventory (1910.119(d)(2)(i)(C))

Lately we’ve been seeing quite a few misunderstandings of the inventory calculations required by a PSM program so I thought I would try and explain it as simply as I can. Both the EPA’s RMP and OSHA’s PSM require you … Continue reading

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Ammonia citations under the General Duty clause

Most of us in the Ammonia Refrigeration industry are dealing with a PSM covered process, but there are some of us who are not required to implement PSM because we don’t have a threshold quantity. The real worry for those … Continue reading

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Pressure Relief Valves – The Five Year Replacement Interval

There has been a lot of discussion recently about the five year inspection interval for Pressure Relief valves. I believe that a lot of this discussion comes from this quote out of the National Emphasis Program for Refineries CPL 03-00-010: … Continue reading

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