Bryan Haywood

The National Board of Boiler and Pressure Vessel Inspectors Report of Violation Findings for First Quarter 2013

The National Board of Boiler and Pressure Vessel Inspectors has released its First Quarter Report of Violation Findings for 2013.  The modified violation tracking system launched in July 2012 and captures a clearer picture of problem areas and trends related to boiler and pressure vessel operation, installation, maintenance, and repair. The data also identifies problems…...

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Looking for some technical data for one of your pressure vessels?

The National Board has announced 1,530,716 registrations of boilers, pressure vessels, attachments, and nuclear equipment for the fiscal year 2013 (July 1, 2012–June 30, 2013).  The National Board maintains manufacturers’ data reports on all boilers and pressure vessels registered with the National Board. Each data report includes the name of the manufacturer, the item’s National…...

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OSHRC on Permit Required Confined Spaces

This case is one for the record books!  Reading this decision is like reading a mystery novel like “Clue.”  The ALJ literally eats up some of the witnesses and calls them liars.  The official case files have names redacted because of the back-and-forth between the company and ex-employees.  BOTTOM LINE… a company can not claim…...

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EPA RMP citations @ Winery (NH3 & $7.5K)

Process Safety Information (Pipe Labeling & Tagging) Document that equipment complies with recognized and generally accepted good engineering practices as required by Section 112(r)(7) of the Act, and 40 C.F.R. §68.65(d)(2).During the facility walkthrough, it was apparent that ammonia system piping and component labeling and tagging was not in conformance with IIAR Bulletin 114. Operating…...

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EPA RMP citations @ gas liquid extraction facility (Flammables & $89K)

Respondent owns and operates a natural gas liquid extraction facility which consists of buildings, equipment, structures, and other stationary items which are located on a single site or on contiguous or adjacent sites, and which are owned or operated by the same person (the natural gas liquid extraction facility). On March 18, 2009, under Section…...

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Federal Railroad Administration Issues Emergency Order to Prevent Unintended Hazardous Materials Train Movement

The U.S. Department of Transportation’s Federal Railroad Administration (FRA) has issued an Emergency Order and Safety Advisory to help prevent trains operating on mainline tracks or sidings from moving unintentionally. The FRA’s announcement was made in response to the July 6, 2013 derailment in Lac-Mégantic, Quebec, Canada, as it awaits additional data once the investigation…...

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CFATs Program Statistics as of August 1, 2013

More than 44,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest 4,298 facilities are currently covered by CFATS More than 3,000 facilities voluntarily removed, reduced, or modified their holdings of chemicals of interest 1276 visits to assist facilities with compliance 589 Security Plans authorized 182 Security Plans approved following an onsite inspection…...

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How can I determine if my facility’s wastewater treatment operation meets the Chemical Facility Anti- Terrorism Standards (CFATS) exemption under 6 CFR 27.110(b) for the Federal Water Pollution Control Act?

Section 27.110(b) of 6 CFR exempts from CFATS “Treatment Works,” as defined in section 212 of the Federal Water Pollution Control Act, Pub. L. 92-500, as amended. If an industrial facility treats its wastewater and that water is directly discharged into a body of water without further treatment, then the facility must be registered with…...

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“It’s just Ammonia” – yep it sure is!

UPDATED 8/17/14 Routinely we hear the argument that Anhydrous Ammonia should not be on OSHA’s or EPA’s chemical lists for PSM/RMP inclusion.  Like most industries that use a single highly hazardous chemical as a “utility” in their process(es) v.s. manufacturing the HHC or using the HHC in the manufacturing process, these industries feel “their chemical”…...

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