Chemical Process Safety (PSM/RMP)

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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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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Should tank capacity be considered when determining thresholds? (EPA RMP)

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...

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Do I have to report accidents that resulted in medical treatment? (EPA RMP)

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...

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EPA’s Hot Work Definition and Requirements

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...

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Different distances to toxic endpoints with different versions of RMP*Comp

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...

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