EPA finally answers the question: Are “tube” trailers considered a single process?

This has been a huge battle in the power generation and semi-conductor industries!  To me, it is very clear – as soon as the trailer is “dropped”, meaning the semi that was pulling the tube-trailer has been detached, then that trailer becomes a “stationary process”.  EPA has several documents making this point and for those who visit my PSM/RMP Case Page you have seen first hand that EPA issues citations against this practice.  But last month, EPA issued their official position regarding “tube-trailers”…

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