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Isolating a PRCS with misaligning or removing sections of lines, pipes, or ducts

Does your entry procedures/practices allow for “misaligning or removing sections of lines, pipes, or ducts” as a means to isolate a PRCS?  If yes, do your procedures/practices specify the length of “sections of lines, pipes, or ducts” that have to be removed in order to meet the intent of “isolation”?  I can not recall where […]

The tale of two LOTOs – worlds apart (Compressed Air)

If you have equipment that uses compressed air (CA) as an energy source, you will understand my frustrations with how poorly we manage this hazardous energy source.  Typically, compressed air is provided via a plant-wide header system with drops for machine/equipment.  These drops will then use a hose to deliver the compressed air to the

EPA RMP citations @ Anhydrous Ammonia storage and refrigeration process (NH3 & $244K)

Respondent stores and uses ammonia at the facility in parts of the storage and refrigeration process. Respondent’s storage and refrigeration process contains more than the threshold quantity (10,000 pounds) of ammonia. Respondent’s storage and refrigeration process does not meet the eligibility requirements for Program 1 under 40 C.F.R. ยง 68.10(b) and is subject to the

EPA RMP citations @ food facility (NH3 & $85K – COVID19 penalty reduction)

SPECIAL NOTE:  This is the first time I have seen a penalty reduction from the COVID-19 impacts on the business. Respondent operates an ammonia refrigeration process with 15,416 pounds of anhydrous ammonia. The Respondent has one RMProgram level 3 covered process, which stores or otherwise uses a toxic substance in an amount exceeding its applicable

Another example of why breathing air couplings are incompatible with outlets for nonrespirable worksite air or other gas systems (1910.134(i)(8)

A petrochemical refinery was undergoing a turnaround. A contractor crew had been assigned the job of sandblasting the inside surfaces of a reactor vessel (permit-required confined space). Although UNWRITTEN COMPANY POLICY called for the use of air compressors for supplying respirator air, this crew, with the supervisor’s knowledge, had previously used plant air to supply

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