Respondent operates a meat processing facility that uses 24,300 pounds of ammonia as its refrigerant. Respondent has one RMProgram level 3 covered process, an ammonia refrigeration process, which stores or otherwise uses a toxic chemical in an amount exceeding its applicable threshold of 10,000. During calendar year 2014, EPA opened an RMProgram compliance monitoring investigation…...
On October 29, 2009, Employee #1 was performing pressures tests on 30-pound fire extinguisher bodies, using a test machine run in automatic mode. Employee #1 loaded four bodies/cylinders into the machine and started the test cycle by activating the two-hand control. The machine submerged the fire extinguishers into a water bath, and the bodies were…...
On September 24, 2010, Employee #1 was standing five feet away from a pressure test being conducted with nitrogen. Inside the test, the cylinder was a downhole tool used in oil and gas production. For unknown reasons, the tool inside the test cylinder exploded knocking the threaded end cap off the test cylinder. The explosion caused the straps…...
The new T/O program formalizes the “Test Only” process by providing National Board certification to organizations conducting in-service testing of pressure relief valves. The program includes an adjustment for restoring nameplate set pressure and provides customer and inspector confidence in testing capabilities. T/O Certificates of Authorization will be extended to current VR certificate holders. New applicants can obtain a T/O Certificate of Authorization by…...
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As a result of a 2012 inspection, Respondent was cited for five repeat violations, which were issued on March 27, 2013. The citations upon which the repeat violations were based were issued to Wynnewood Refining while owned and operated by Gary Williams Energy (GWE), most of which became final orders of the Commission in April…...
Last week I posted a June 2016 OSHRC decision in which an Administrative Law Judge (ALJ) sided with OSHA on a number of PSM citations regarding a fatal boiler explosion that occurred within a PSM-covered process. Since that posting, I have received dozens of e-mails asking for more explanation and how I suggest managing this…...
This case is not final orders of the Review Commission as it is pending Commission Review! This decision can have HUGE impacts throughout the PSM/RMP community, as many covered processes are “interconnected” to a boiler and many may also be “co-located” such that a boiler explosion could impact the covered process. This case involved a boiler…...
This week I was privileged to be able to present as ASSE’s Safety 2016 on a topic near and dear to me… Line Break/Process Opening. In our presentation, we mentioned “Routine vs. Non-Routine Openings” and how we manage these different openings. One of the requests we received afterward was for “routine openings” that resulted in…...
This is the latest version of the Chemical Reactivity Worksheet (CRW) 4.0.0, which was posted on March 3rd, 2016 . Follow these instructions for downloading, installing, and running the CRW. NOTE: With the release of CRW 4.0 in March 2016, the ongoing management and distribution of the CRW have been transitioned to The Center for…...
Respondent owns and operates a chemical manufacturing facility that has an Acrylonitrile Manufacturing process. On or about December 1-3, 2015, an EPA inspector conducted an inspection of Respondent’s facility. A contractor was removing a six-inch blind and installing four-inch and three quarters inch blinds to prepare the Heads Column in the Acrylonitrile Unit for caustic cleaning. The…...
