Chemical Process Safety (PSM/RMP)

The BULLETIN – Summer 2022

I have been referring SAFTENG members to subscribe to the “Bulletin,” a FREE publication from the National Board of Boiler and Pressure Vessel Inspectors.   This publication is an EXCELLENT resource for those safety professionals dealing with pressure vessel safety, especially those in the process safety arena.  Their latest edition covers two (2) very significant changes…...

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The CSB’s Accidental Release Reporting Rule Data

The regulation governing the reporting of accidental releases can be found in title 40 Code of Federal Regulations (CFR) Part 1604, Reporting of Accidental Releases. The regulation requires the owner or operator of a stationary source to report any accidental release resulting in a fatality, serious injury, or substantial property damage​s. The purpose of this…...

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Massachusetts Office of Technical Assistance Advisory Preventive Hazard Evaluation for Process Safety

Massachusetts Fire Code hazardous material processing regulation (527 CMR 33)  requires a hazard evaluation or limited process safety program for many companies that have never faced this requirement before, (though many companies have been essentially performing these tasks as good practice).  Many companies covered by this regulation must now document that a hazard evaluation has…...

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Was the Jordan Cl2 a true Worst-Case Release Scenario?

This past week we witnessed a tragic incident involving chlorine (Cl2), a 25-ton ISO container, and a crane/sling failure.  The incident claimed 13 workers’ lives and sent another 250 to hospitals for emergency care.  Many have claimed this to be the “worst-possible outcome”.  Here in the USA, we call these “Worst Case Release Scenarios” (WCS). …...

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Is Auto-Refrigeration an “inherent safeguard” for liquidfied pressurized gases Worst-Case Release scenario

As we saw in Jordan last week, gases stored as liquids can “auto-refrigerate” in large-scale accelerated releases.  In the aftermath pictures, we can see a clear frost line along the bottom of the ISO container, which is evidence of a refrigerated liquid level within the container. (See pic and explanation below)… Membership Required You must...

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Worst-case Release Scenario for Separate, Interconnected Vessels

Pursuant to the risk management program regulations, facilities must perform an offsite consequence analysis for the worst-case release scenario. Do the quantities of two separate vessels that are interconnected with a closed valve need to be aggregated for the worst-case release scenario analysis?  NO… Membership Required You must be a member to access this content.View...

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Hot Work Permit Procedures and Date in Section 7.13 (EPA RMP)

Stationary sources subject to the Program 3 Prevention Program requirements in 40 CFR Part 68, Subpart D, must include in their Risk Management Plan (RMP) the date of the most recent review or revision of hot work permit procedures in Section 7.13. What are hot work permit procedures and what date should the stationary source…...

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If a covered process has an accident, when does it lose eligibility for Program 1 status?

A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). Those criteria include a requirement that the process cannot have had an accidental release of a regulated substance that led to offsite death, injury, or environmental response or restoration…...

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Does the distance to endpoint start at the process or stationary source boundary?

When selecting the worst-case release scenario for Program 2 and 3 processes as required by 40 CFR §68.25, a stationary source owner or operator must analyze the release scenario that results in the greatest distance to an endpoint. Does the “greatest distance to an endpoint” refer to the greatest total distance from the process (e.g.,…...

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Who Must Develop an Emergency Response Program? (EPA RMP)

The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. Do all facilities subject to…...

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Are Mechanical Controls Considered Administrative Controls as they relate to the WCS?

For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity (40 CFR §68.25(b)). Are mechanical…...

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RMP Records Maintained Onsite

Pursuant to 40 CFR Part 68, Subpart G, the owner or operator of a stationary source subject to the risk management program regulations in Part 68 must develop and submit a risk management plan (RMP). Does the owner or operator have to maintain a written copy of the RMP on site at the stationary source?…...

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