Program 1 eligibility under 40 CFR §68.10(b) is contingent upon the process NOT having had an accidental release of a regulated substance that led to offsite death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk management plan submission. Additionally, as part of the hazard assessment required […]
As one of its core research focuses, the U.S. Environmental Protection Agency’s (EPA’s) Homeland Security Research Program (HSRP) is interested in refining its tools and methodologies to better characterize the fate and transport of hazardous contaminants during all phases of an emergency response. Atmospheric dispersion modeling is one tool that can be used for effective
If you’re installing/repairing/modifying your chemical process piping using ASME B31.3 and 31.5, these standards have some strict QA/QA requirements for who can make the welds to join the piping. These welders MUST be qualified in accordance with ASME Code, Section IX, “Welding Qualifications.” ASME Code, Section IX, Part QW-103.1, states that: “Each manufacturer or contractor
We have seen hundreds of changes to our businesses since March and many of these changes were needed for worker protection, but recently we came across one such change that had serious potential to cause a bad event! Maybe you have seen the latest and greatest devices for aiding in our “social distancing” efforts. These
An increased number of gas release incidents have occurred in the Gulf of Mexico Region due to leaks from cracked welds, ring gaskets, flange gaskets, inlet nozzles, pipeline risers, suction headers, pressure safety valves (PSVs), and fuel gas lines. These gas release incidents involve deficiencies in Quality Assurance and Mechanical Integrity programs and are caused
Just because we intend to handle minimal quantities of the HHC/EHS, the task of “catching a sample” from a covered process can, in fact be one of the more hazardous tasks our operators perform. Remember, Risk = Frequency X Severity, so operators catch many samples over their shift means this task is a high-frequency task.
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?
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
In section 2, element 2.5, of an RMP, facilities must report the quantity of toxic chemical that the facility used for the worst-case analysis. When reporting this data element in RMP*eSubmit for a mixture, should facilities report the entire weight of the toxic mixture potentially being released or only the amount of the regulated toxic
I am not sure what it is about fresh air intake for exhaust ventilation systems, but we should call them “Rodney”, as in Rodney Dangerfield, because they get no respect. As I said in 2016 and 2018 in my articles: The Ventilation Design Basis begins with our intakes FRESH AIR intakes for a ventilation system
Today a longtime friend and SAFTENG member shared an article in our FaceBook group regarding a food pantry in TN that accidentally gave out fifty-four (54) 1-gallon containers of 50% Hydrogen Peroxide (H2O2) in their food packages. Now I have no idea what a food pantry is doing with 50% Hydrogen Peroxide, much less that
Both of these tools are necessary in the process safety arena; however, they have very different and distinct roles in process safety management. In my career I found it best to perform the PHA first and based on the deviations identified in the PHA, we would write our SOPs to cover those deviations. And of
