This is a PERFECT EXAMPLE of how a “non-covered” chemical within a PSM Covered Process can impact that PSM/RMP covered process. This can happen to any type of covered process; just not in a refinery! I have personally experienced a single acid line (not covered in the PSM program) leak over another pipe in a pipe rack that was carrying a PSM/RMP covered chemical, corrode the pipe from the outside in and cause a significant release! Very hard to argue that the “uncovered process” can not impact your “covered process” after an event such as this! I am working on some material along these lines that I will publish later this summer, but this article was reported yesterday in Reuters…
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