Flexible hoses are often used to temporarily transfer hydrocarbons and other process fluids to facilitate turnaround activities (clearing equipment, de-inventorying, purging, etc.) and transfer process fluids/products to rail cars and/or/or tanker trucks for shipment. Flexible hoses may also be installed within process piping systems to mitigate the effects of thermal expansion, vibration, or movement during…...
Facilities should have a written program to ensure flanges are properly made up. Proper makeup of every flange in a piping system is important for reliability. Proper makeup includes: … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
The ever-controversial “check valve” has now been defined as to when it should be formally included in the piping MI inspection process. As we have discussed many times, if we claim a check valve in our PHA and/or SOP as a “safeguard,” then by all means, this valve has been defacto identified as a “safety…...
The endpoint concentrations for regulated toxic substances under the risk management program rule (40 CFR Part 68 Appendix A) are listed in units of milligrams per liter (mg/L). Is this equivalent to parts per million (ppm)?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Passive mitigation is defined in § 68.3 as “equipment, devices, or technologies that function without human, mechanical, or other energy input.”… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
According to the definition of “process” in 40 CFR §68.3, any group of vessels that are interconnected is considered to be a single process. If a stationary source has two interconnected vessels and one contains 6,000 pounds of BUTANE while the other contains 6,000 pounds of PROPANE, is this a covered process under 40 CFR…...
What does EPA plan to do to verify the accuracy and completeness of submitted Risk Management Plans (RMPs)?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Would the risk management program regulations cover the loading and unloading of transportation containers?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Some landfills collect methane gas and either vent, flare, or store it for subsequent fuel use. Are methane processes at landfills subject to the requirements of the EPA Risk Management Program?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Oleum, which is a mixture of sulfuric acid and sulfur trioxide, is listed as a regulated toxic substance in 40 CFR §68.130. Sulfur trioxide is also listed individually as a regulated toxic substance. Suppose a single process consists of one vessel containing oleum and one vessel containing sulfur trioxide. Must the amount of sulfur trioxide…...
Why are hydrochloric acid and hydrogen chloride listed separately in the list of regulated substances at 40 CFR §68.130?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Several toxic substances are listed as regulated substances under 40 CFR §68.130 with concentration qualifiers (e.g., “conc 37% or greater”). What does this concentration mean? When determining whether a threshold amount of these substances exists in a process, should I consider the weight of the entire solution, or simply the amount of the regulated toxic…...
