Chemical Process Safety (PSM/RMP)

HVAC Contractor’s Scissor Lift causes NH3 release & fatality

At 11:09 a.m. on December 19, 2022, an HVAC contractor was installing a heating unit when a coworker operating a scissor lift struck a NH3 pipe/valve that caused a release of ammonia. The contractor, 68, was overcome by ammonia and died.  The lift operator was hospitalized for treatment for his exposure to ammonia…. Membership Required...

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Natural Gas Excess Flow Valves on Residental Feeds

Today I saw our local Natural Gas service provider discussing installing an Excess Flow Valve with my neighbor.  So naturally, that caught my ear, so I mossed over to learn more.  It seems that most Natural Gas service providers are offering the installation of an Excess Flow Valve on the feed to homes.  Of course,…...

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Attention to detail needed with Respiratory Protection and Cl2 exposure

At 11:00 a.m. on May 23, 2019, an employee removed a regulator from a chlorine gas cylinder to perform yearly maintenance and repacking. When the employee attempted the close the shutoff valve, the valve malfunctioned and stopped turning while still slightly open without the employee’s knowledge. When the employee removed the regulator, chlorine gas escaped…....

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Line Break gone bad (pyrophoric materials)

Two workers were injured on an offshore platform while installing a skillet, the steel circular joining plate inside a section of piping. The incident occurred while the workers were on scaffolding and unbolting a 10-inch flange (Figure 1). After determining the skillet was the wrong size, the supervisor instructed a third worker to join the…...

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Lack of Maintenance to Uninterruptible Power Supply Systems Leads to Failures (BSEE Alert)

Uninterruptible Power Supply (UPS) is a pretty common backup power supply in industrial settings where “power failure” can lead to the loss of control systems, emergencyshutdown systems, and emergency mitigation systems.  But like ALL SAFEGUARDS we take credit for in our Hazard Analyzes, these UPS must be in our mechanical integrity program for testing/validation regularly…...

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Is a public road considered a public receptor?

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). One of those criteria is that the distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance to any public receptor. Are…...

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Is a double walled tank “passive mitigation”?

Performance of the hazard assessment required under 40 CFR Part 68, Subpart B, includes analysis of both worst-case release scenarios (40 CFR §68.25) and alternative release scenarios (40 CFR §68.28). In each of these analyses, passive mitigation systems may be taken into consideration. If a tank has a “double wall,” does that qualify as “passive…...

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Maintenance requirements for leased tanks

 I use propane as a raw material in my manufacturing process. I lease the tank from the propane supplier. The supplier does all the maintenance. My staff never work on the equipment. What should I do?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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States with authority to implement / enforce the risk management program rule

Which states have been granted a delegation of EPA’s authority to implement and enforce the risk management program rule?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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What is the definition of a “technically qualified individual”?

Certain exemptions may apply to determine whether more than a threshold amount of a regulated substance is present at a stationary source under 40 CFR Part 68. One exemption is for regulated substances that are “manufactured, processed, or used in a laboratory at a stationary source under the supervision of a technically qualified individual as…...

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After a reportable accident, do I have to revise my RMP?

I recently submitted my five-year RMP update required by section 68.190 (b)(1) and included my accident history for the previous five years. Two months later, we had another reportable accident. Do I have to do anything to revise my RMP?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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Who is responsible for preparing and submitting an RMP for leased propane tanks?

If an owner of a stationary source leases propane tanks from a gas supplier, who is responsible for preparing and submitting the risk management plan (RMP) addressing the propane tanks?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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