When determining whether a threshold amount of a regulated substance is present in a process (e.g., a tank), must the owner or operator of a stationary source consider the total capacity of the process, or the actual amount of regulated substance contained in the process?… Membership Required You must be a member to access this...
Should tank capacity be considered when determining thresholds? (EPA RMP) Read More »
How far apart do separate vessels have to be to be considered different processes?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Process identification and distance between vessels (EPA RMP) Read More »
I had a release where several people were treated at the hospital and released; they attributed their symptoms to exposure. We do not believe that their symptoms were in fact the result of exposure to the released substance. Do we have to report these as offsite impacts?… Membership Required You must be a member to...
Do I have to report accidents that resulted in medical treatment? (EPA RMP) Read More »
Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What is considered hot work and what are the requirements related to hot work?… Membership Required You...
EPA’s Hot Work Definition and Requirements Read More »
I’ve noticed that for certain chemicals, RMP*Comp gives substantially different distances to the toxic endpoint than previous versions. Why?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Different distances to toxic endpoints with different versions of RMP*Comp Read More »
The prevention program requirements under 40 CFR Part 68, Subparts C and D, include hazard reviews and process hazard analyses. Is a hazard review synonymous with a process hazard analysis (PHA)? No!… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Is a hazard review synonymous with a process hazard analysis (PHA)? Read More »
The Program 3 prevention program requirements under 40 CFR Part 68 are almost identical to the requirements of OSHA’s process safety management (PSM) standard. OSHA exempts certain industries from the PSM standard. Why does EPA not exempt those same industries from the CAA §112(r) risk management program requirements?… Membership Required You must be a member...
Why are industries exempt under OSHA’s PSM subject to RMP? Read More »
What if the quantity in the process fluctuates? I may not have a threshold quantity now, but I will intermittently exceed the threshold quantity…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
What if the quantity in the RMP Covered process fluctuates? Read More »
The owner or operator of a stationary source covered by the risk management program regulations must conduct a worst-case release scenario analysis as part of the required hazard assessment (40 CFR §68.25). The worst-case release is defined as the release of the largest quantity of a regulated substance from a vessel or process line failure…...
Worst-case release from smaller process with larger distance to endpoint Read More »
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)). Why did…...
Administrative controls considered when determining worst-case release quantity Read More »
As part of the hazard assessment, owners and operators of Program 2 and Program 3 covered processes must identify and analyze alternative release scenarios (40 CFR §68.28). What criteria should be used when selecting an alternative release scenario?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...
Criteria for selecting alternative release scenarios Read More »
The accident occurred in the hexane-based rapeseed oil extraction process. After grinding the seed and obtaining meal that is then steam-cooked (100°C), pressing in a continuous screw press is used to obtain 2/3 crude oil and flakes containing 1/3 oil. This oil is extracted from the flakes in the extraction process: the flakes are transported…...
Hexane explosion in an oil extraction plant (Double Fatality – PRCS) Read More »
