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...
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...
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...
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…...
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…...
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…...
Chlorine, CAS No. 7782-50-5, is an extremely hazardous substance regulated and listed in 40 C.F.R. § 68.130. As the owner and operator of a stationary source, with respect to the use and storage of ferric chloride and sodium hypochlorite, Respondent has a duty under the General Duty Clause, Section 112(r)(1) of the CAA, to design…...
I like to explain the documentation for our pressure vessels much in the same context as our birth certificates. For every pressure vessel in service today, we must have that vessel’s U-1 Form. And please don’t tell me about the OSHRC decision stating otherwise. I really don’t care what a group of lawyers think about…...
In the USA we use ASME Section VIII, Appendix M-5, and the National Board’s Part 4 when we need to install a block valve before or after a relief valve (RV). In Saskatchewan, Canada their safety authority has a program titled “Pressure Relief Path Stop Valve Control Program“. It is a really nice start to…...
These little safety devices cause such big troubles because of pure ignorance. I continue to have silly debates with very smart people about meeting the absolute bare minimums from so many different recognized and generally accepted good engineering practices (RAGAGEPs). As of today, I have written about Hydrostatic Relief Valves 84 times. This week, I…...
This question is one that gets a lot of attention and the debate can become heated. OSHA’s minimum standard, written in 1974, requires the fire watch to be maintained for 30-minutes after completion of welding or cutting operations. But in the past decade, many insurers and standards that are more up-to-date are now requiring that…...
A sealed, unclassified electrical control enclosure, part of a listed and certified force-ventilated commercial hydrogen processing unit enclosure, exploded when the equipment manufacturer’s technician pressed the machine stop switch to complete the factory commissioning procedure. The technician was forcefully hit by the flying metal panel holding the switch and sustained serious injuries requiring lengthy hospitalization…...
