Chemical Process Safety (PSM/RMP)

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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How does this active mitigation system affect my selection and analysis of an alternative release scenario?

I run a wastewater treatment plant that is subject to the risk management program regulations in 40 CFR Part 68 for a covered process containing chlorine. A chlorine scrubber system at the plant is designed to prevent any possible releases from reaching a toxic endpoint offsite. How does this active mitigation system affect my selection…...

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Determining frequency of ER coordination activities

The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). Are stationary sources responsible for determining if coordination activities should occur more often than annually?… Membership Required You must be a member...

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Are Mechanical Controls Considered Administrative Controls?

To analyze 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 controls such as…...

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How close must a stationary source be to a weather station in order for that station’s data to be applicable to the stationary source?

How close must a stationary source be to a weather station in order for that station’s data to be applicable to the stationary source?… 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 EPA’s criteria for selecting stationary sources to audit?

The implementing agency will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following seven (7) criteria:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Facility Siting of Pressurized Liquidfied Flammable Gas storage tanks

As we have discussed, OSHA does not have a “flammable gas” standard for those flammable gases outside the scope of its Liquefied Petroleum Gas (LPG) standard 1910.110.  So in most of my work with flammable gases, I will use 1910.110 or NFPA 58 as my RAGAGEP.  I do this as many facilities already have some…...

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We do not live in a 0.0 psi atmopshere!

I have been surprised at our profession’s lack of basic understanding regarding pressure and vacuum.  I think most people of the general public have no idea that we live under 14.7 pounds of pressure per square inch on our bodies.  We say this is what it is at SEA LEVEL, which means a lot.  As…...

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LOPC event is a classic example of the domino or swiss cheese model (CSB Report – Fatal Propylene Explosion)

The incident occurred shortly after 4:30 am on January 23, 2020, when an accidental release of propylene accumulated and exploded inside the building. The CSB found that before the incident, a hose disconnected from its fitting inside a coating booth and released propylene, a flammable hydrocarbon vapor, which accumulated inside the coating building. When employees…...

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Management of Hazardous Chemicals at Chemical Warehousing and Chemical Distribution Facilities (EPA/OSHA)

In 2021, the EPA published a Joint Safety Advisory with the Occupational Safety and Health Administration and the Department of Homeland Security Cybersecurity and Infrastructure Security Agency, focused on managing chemicals safely, securely, and in compliance with federal programs for Chemical Warehousing and Chemical Distribution Facilities. In this video, we will address the types of…...

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