2017 Video of the Week #1 (CO2 Release)
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EPA explains the changes to the FINAL RMP Amendments local emergency response coordination requirements
This week EPA issued two letters explaining the changes to the local coordination requirements and they will advance local preparedness and assist local response officials, as well as the Local Coordination requirements that are included in the final rule. Here’s what EPA said:… Membership Required You must be a member to access this content.View Membership LevelsAlready a...
EPA clarifies the new “public information” requirements for their FINAL amendments of their RMP Rule
EPA issued several letters this week clarifying the NEW “public information” requirements in their FINAL AMENDMENTS of their RMP rule. Here are the questions that EPA answered in their letters: What is the process for responding to information requests from the public? How does EPA’s final rule preserve security while enhancing the ability to local…...
EPA explains the new Incident Investigation provisions in their Final RMP Amendments
EPA issued a letter explaining what incident investigations and root cause Analysis requirement changed from the proposed to final rule and what the final rule requires with regards to incident investigations. Here’s what EPA said:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
EPA explains Safer Technology and Alternatives Analysis (STAA)
“Safer Technology And Alternatives” (STAA) refer to risk reduction strategies developed using a hierarchy of controls that are considered inherent, passive, active, and procedural. This strategy can be applied initially to all design phases and then continuously throughout a process’s life cycle. STAA includes concepts known as inherently safer technologies (IST) or inherently safer design…...
EPA explains the new RMP rule Third Party Audit requirements
EPA has issued two letters that better clarify what the “Third Party Audit” requirements changed from the proposed to final rule and what the third-party audit requirements actually are. Here’s what EPA said:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
EPA explains the new RMP rule provisions COMPLIANCE DATES
EPA has established the following dates for facility owners and operators to comply with the revised rule requirements:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
EPA issues two (2) letters regarding Ammonium Nitrate
EPA issues “letters” on their website that helps clarify many of their rule requirements, much like OSHA’s Letters of Interpretation. This week OSHA issued twenty-one (21) such letters following their FINAL amendments to their Risk Management Plan rule. These two (2) letters address what EPA has done to further the safe storage and handling of Ammonium…...
U.S. Court of Appeals for the Fifth Circuit agrees that a control room’s positive pressurization unit (PPU) is part of a “covered process” (PSM)
OSHA cited a refinery in 2008 for failing to inspect a piece of equipment known as the positive pressurization unit (PPU). The refinery contends that this citation is unlawful because the PPU is not encompassed by the relevant regulations. Because this dispute involves the interpretation of a binding regulation promulgated by the agency, we defer…...
U.S. Court of Appeals for the Fifth Circuit finds that OSHA can’t cite for violations that were over 6 months old (PSM)
Delek purchased an oil refinery located in Tyler, Texas from Crown Central and took possession on April 29, 2005. Beginning in February 2008, OSHA conducted a four-month inspection of the refinery and issued a citation on August 18, 2008, finding violations of 29 C.F.R. § 1910.119 and other regulations that are not at issue here…....
Safeguarding our piping (ASME B31.3, Appendix F)
Safeguarding is the provision of protective measures to minimize the risk of accidental damage to the piping or the harmful consequences of possible piping failure. In most instances, the safeguarding inherent in the facility (the piping, the plant layout, and its operating practices) is sufficient without the need for additional safeguarding. In some instances, however,…...
Flanges and their joinment integrity
Three distinct elements of a flanged joint must act together to provide a leak-free joint: the flanges, the gasket, and the bolting Factors that affect performance include the following:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...