Bryan Haywood

EPA RMP… Do the quantities of two separate vessels that are interconnected with a closed valve need to be aggregated for the worst-case release scenario analysis? 

Pursuant to the risk management program regulations, facilities must perform an offsite consequence analysis for the worst-case release scenario. Do the quantities of two separate vessels that are interconnected with a closed valve need to be aggregated for the worst-case release scenario analysis? … Membership Required You must be a member to access this content.View Membership...

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EPA RMP… What is the definition of fuel for the purposes of exclusion?

A flammable substance listed in 40 CFR §68.130 is excluded from the risk management program regulations when it is used as a fuel or held for sale as a fuel at a retail facility (§68.126). What is the definition of fuel for the purposes of this exclusion?… Membership Required You must be a member to...

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EPA RMP… Are mechanical controls such as alarms considered administrative controls and therefore limit the worst-case release quantity?

For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity (40 CFR §68.25(b)). Are mechanical…...

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EPA RMP… Do all facilities subject to the risk management program regulations have to develop an emergency response program?

The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. Do all facilities subject to…...

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Expansion/Seismic hoses, excess flow valves, and check valves

What I am going to suggest in this article is NOT necessarily a code or standard requirement, but just some SOUND ADVICE on how to improve safety around expansion/seismic joints where hoses are utilized to allow for flexibility.  As my clients know, I HATE hoses in a chemical process and I am OCD when it…...

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Does an PRCS attendant need respiratory protection?

I am sure the thought has crossed everyone’s mind who has issued an entry permit for a HAZ ATM entry… “should the attendant be in breathing air as well?”.  Is there an exposure potential for the attendant to the HAZ ATM from within the PRCS?  Most attendants are stationed right outside the entry portal, add…...

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Is a palletizer a Permit-Required Confined Space?

One of the biggest mistakes I see in my auditing and the biggest frustration I have when facilities state they treat all of their confined spaces as PRCS is that most have not recognized the fact that a roll-off trash compactor and/or large palletizers are actually Permit-Required Confined Spaces.  For example, we have a large…...

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Falls, Permit-Required Confined Spaces, and Reclassifying the space

Our behind the scenes debate continues and now a number of clients have joined in with their take on the matter. The fundamental part of our debate has come down to two (2) positions: does a fall inside or into a Confined Space make that CS a Permit-Required Confined Space? if you said yes to…...

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EPA RMP GDC @ food facility (NH3 & $90K)

Respondent operates an ammonia refrigerant system which contains approximately 8,487 pounds of ammonia which is processed, handled, and stored in the ammonia refrigerant systems, and ammonia is a regulated extremely hazardous substance listed under Section 112(r)(3) at 40 C.F.R. § 68.130. EPA inspected the Facility on June 7, 2018. Prior to the June 7, 2018…...

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Internal inspections… of my pressure vessel??? We don’t need no internal inspections

I have been doing process safety my entire career and I have had some of the finest engineers teach me process safety.  Now those that know me, know I am just some dumbass western KY edua-macated safety redneck, but even I know the importance of intenral inspections on my PVs.  I know only two (2)…...

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Did OSHA mean to define a non-PRCS differently in the Construction Standard?

Several years ago I wrote an article about how a space goes through its transitions to become a non-permit required confined space.  A space is not identified as a non-permit required confined space during its first evaluation; it becomes one after it has been “reclassified” using either (c)(7) or 1926.1203(g).  That article caused quite a…...

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What happens when the NH3 release inside the engine room exceeds 40,000 ppm?

UPDATED on 8/21/2019 with the 2018 IFC Commentary… I am guessing that someone has published a technical paper or article stating that an “electrical shunt” is no longer a code requirement for ammonia refrigeration engine rooms.  This has caused several of my clients and subscribers to ask me if this is true as this goes…...

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