Tried to summarize some of the key differences between EPA’s Risk Management Plan and OSHA’s PSM requirements and even threw in some CFATS info. Let’s start with EPA’s most recent numbers for a breakdown of the RMP Sites as of 2018 …… Membership Required You must be a member to access this content.View Membership LevelsAlready...
Respondent is the owner and operator of a Facility that utilizes approximately 32,000 pounds of anhydrous ammonia in its refrigeration system at the Facility. Respondent uses anhydrous ammonia in a series of interconnected pipes and vessels in a refrigeration system at the Facility (the “Process”). On June 26, 2017, EPA conducted an inspection of the…...
Respondent is the owner and operator of a food storage and distribution facility which includes refrigerated process areas and storage areas with a refrigeration system that uses anhydrous ammonia with a capacity of 14,722 pounds. Respondent uses anhydrous ammonia in a refrigeration “process,” as defined by 40 C.F.R. § 68 .3. in a typical vapor…...
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Respondent is food company which owns and operates buildings, structures, installations, equipment, pipes or pipelines, and storage containers, located on a single site or on contiguous or adjacent sites, where it deposited, stored, disposed of, or placed, Ammonia CAS# 7664-41-7. Between June 21 and July 19, 2013, Respondent spilled, leaked, emitted, discharged, or allowed to…...
Respondent operates a specialty chemical manufacturing facility that includes an aboveground storage tank, tanker truck, tanker car, tote and drum chemical storage areas. At its stationary source, the Respondent has 500,000 pounds of carbon disulfide in onsite storage and Respondent has one RMProgram level 3 covered process, which stores or otherwise uses carbon disulfide in…...
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Starting this month (September) I will be conducting four (4) training sessions on Permit-Required Confined Spaces. These are FREE, with lunch provided, and will cover all aspects of implementing a PRCS Program, with each month covering a different element. The four elements are: Evaluating Spaces – What makes a space a CS and what makes…...
It only takes one spark and a trashcan with a flammable waste residue (e.g. vapor). Now you understand why there is a 35′ fire safe area requirement… watch the spark travel and land in the trash can. WARNING! Turn down your volume – NSFW language…. Membership Required You must be a member to access this...
Violation Code Violation Description # of Inspections # of Violations % of Total Violations # of OOS Violations OOS Percent 1 177.834A Package not secure in vehicle 3,154 3,277 9.71% 3,138 95.76% 2 107.620B No Copy Of US Dot Hazardous Materials Registration Number 2,269 2,269 6.73% 3 0.13% 3 177.817E Shipping paper accessibility 2,150…...
Imagine having a pressure vessel that has a MAWP of 300 psi and yet there is no high-pressure alarm before 300 psi is reached. How would an operator know he/she is approaching their consequence limit? As I wrote about earlier this year, a well-designed process will have both alarms – BEFORE the safe upper/lower operating…...
