Materials Performance

OCT 2017

Materials Performance is the world's most widely circulated magazine dedicated to corrosion prevention and control. MP provides information about the latest corrosion control technologies and practical applications for every industry and environment.

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14 OCTOBER 2017 MATERIALS PERFORMANCE NACE INTERNATIONAL: VOL. 56, NO. 10 The August 2012 fire at Chevron's refinery in Richmond, California, was a driving factor behind a new refinery safety order in California. Photo courtesy of U.S. Chemical Safety Board. Corrosion Failure and Fire Spark New Refinery Safety Order in California T he process safety management (PSM) unit of the California Division of Occupational Safety and Health (Cal/OSHA) (San Francisco, California) recently f inalized a new ref inery safety order, 1 seeking to reduce the risk of major incidents at the state's oil ref ineries. The order, f inalized in May 2017, was f irst put into motion following a f ire on August 6, 2012, 2 at the Chevron ref inery in Richmond, California, where a hydro- carbon release and massive f ire occurred in one of the crude units. A technical eval- uation report 3 by Cal/OSH A and the U.S. Chemical Safety Board (CSB) (Washing- ton, DC) found evidence of sulf idation corrosion in tested pipe samples, and cur- rent CSB Chair Vanessa A llen Sutherland says the approval of new rules is a " large step forward " in promoting the safety of ref ineries across the state. "These new rules are ones that my agency, the CSB, strongly recommended in our 2013 investigation report of the August 2012 Chevron Richmond ref inery pipe rupture, vapor release, explosion, and f ire," Sutherland says. "Simply put, [this] action in California is an example of the CSB driving chemical safety change." The new order requires that a damage mechanism review (DMR) be conducted for each existing and new process for which a damage mechanism exists, and for any processes that result in equipment or material degradation. Employers are required to complete at least 50% of initial DMRs within three years and all remain- ing within five years, and each DMR must be revalidated at least once every five years. If a major change to a process unit may intro- duce a damage mecha- nism, a new DMR must be conducted prior to approval of the change. Moreover, if a damage mechanism is identi- fied as a contributing factor in an incident investigation, the employer must review the most recent DMRs relevant to the case. If a DMR has not been performed on those processes, incident investigators can rec- ommend that a DMR be conducted within a short timeframe. The DMRs are to be performed by a team with technical expertise in engi- neering, equipment and pipe inspection, damage and failure mechanisms, and the operation of the processes under review. The team must include one member knowledgeable in the specif ic DMR meth- odolog y being used, and employers must allow for employee participation. When investigating any situation that results in or could have reasonably resulted in a major incident, the team is required to utilize root cause analysis. According to the rule, damage mecha- nisms to be reviewed include mechanical loading failures, such as ductile fracture, brittle fracture, mechanical fatigue, and bucking; erosion, such as abrasive wear, adhesive wear, and fretting; corrosion, such as uniform corrosion, localized cor- rosion, and pitting; thermal-related fail- ures, such as creep, metallurgical trans- formation, and thermal fatigue; cracking, including stress corrosion cracking; and embrittlement, such as high-temperature hydrogen attack. Each DMR must include an assess- ment of previous experiences with the process, including the inspection history, all damage mechanism data, a review of industry-wide experience, and all appli- cable standards, codes, and practices. At the conclusion of the analysis, each team prepares a written DMR report, including the process unit and damage mechanisms analyzed; results of all analyses com- pleted; recommendations for temporarily mitigating damage; and recommenda- tions for preventing damage. The report is to be provided to and, upon request, reviewed with employees in each designated process unit. The employer is required to implement all rec- ommendations, and DMR reports are to be retained for the entire life of the pro- cess unit. The DMRs for each process unit must also be made available to the team MATERIAL MATTERS

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