Guidelines and Application Procedures
for API RP 578

PHMSA proposed criteria that would require material properties verification for higher-risk locations through a new § 192.607; specifically, by adding requirements for the verification of pipeline material properties for existing onshore, steel, gas transmission pipelines that are located in HCAs or Class 3 or Class 4 locations.

The PHMSA Rules & Reg. Mega Rule 49 CFR 191 $196 Hi-Lited for MVP 1-30-2020 can be found here. I have Hi-Lited the important parts out of the 78 pages, ( starts on page 11 & 13 for Material Verification ) for the reader to get informed.

“This instruction describes policies and procedures for implementing a National Emphasis Program (NEP) to reduce or eliminate the workplace hazards associated with the catastrophic release of highly hazardous chemicals at petroleum refineries”.

Don Mears gave a speech at the API Inspector Summit, held in Galveston (TX), January 27-30, 2009 (click here to download this API summit speech) .

Executive Summary Chem NEP-2017 CPL 03-00-021

This instruction provides guidance to the Occupational Safety and Health Administration’s (OSHA’s) national, regional, area, and State Plan offices for implementing and conducting an NEP to reduce or eliminate workplace hazards associated with the catastrophic release of highly hazardous chemicals at facilities, including petroleum refineries, covered by OSHA’s Process Safety Management of Highly Hazardous Chemicals (PSM) standard, 29 CFR 1910.119. Both programmed and un-programmed inspections associated with this NEP will begin immediately in all regions.

Significant Changes

This instruction describes an updated initiative by OSHA. Under the previous related instructions, OSHA conducted inspections of facilities covered by OSHA’s PSM standard either through an instruction specific to petroleum refineries or an instruction related to all other PSM-covered chemical facilities excluding petroleum refineries. This instruction is applicable to all facilities, including petroleum refineries, covered by the PSM standard. NEP inspections conducted at petroleum refineries will be conducted in the same manner as NEP inspections conducted at all other facilities covered by this instruction.

On July 28, 2005, 4 months after a devastating incident in the Isomerization (Isom) Unit that killed 15 workers and injured 180, the BP Texas City refinery experienced a major fire in the Resid Hydrotreater Unit (RHU) that caused a reported $30 million in property damage. One employee sustained a minor injury during the emergency unit shutdown and there were no fatalities.

Chlorine Transfer Hose Failure due to improper material braid construction (i.e., 316L and not the recommended braid of Hastelloy C-276). On August 14, 2002 a 1- inch transfer line ruptured during a railcar offloading operation at DPC Enterprises in Festus, Missouri and released 48,000 pounds of Chlorine into neighboring areas.

Many give examples of this or have witnessed this happening. Because of either Luck, Proper PMI / Inspection, Training, or Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) (i.e. API RP 578), we were able to apply these principles and stop the “Near Misses” from turning into catastrophe.