Respondent is a Gourmet Pasta Company that uses anhydrous ammonia in two refrigeration “processes,” as defined by 40 C.F.R. § 68.3, in two separate systems of pipes and vessels at the Facility (the “Processes”). On October 12, 2016, Respondent conducted a Process Hazard Analysis (“PHA”) for the Facility. On March 30, 2017, Respondent filed an […]
I am going to bet that if you’re reading this article that your facility has a flammable gas that gets transferred from one container to another. And I will also bet that these transfers are done under the safety blanket of “bonding and grounding” as we do for our flammable liquids. But did you know,
Respondent is the owner and/or operator of a facility that uses chlorine in its chemical manufacturing process. EPA conducted an inspection of the Facility on November 29, 2017, to assess compliance with Section 112(r)(7) of the CAA (the “Inspection”) and the regulations at 40 C.F.R. Part 68. Respondent filed an RMP for the Facility with
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
If we had a dime for each time we get pushback on the most fundamental aspect of Lockout/Tagout (LOTO), we could all retire! NEVER is an authorized employee allowed to work under someone else lock – PERIOD! When servicing and maintenance that requires LOTO is performed, then EACH authorized worker MUST HAVE EXCLUSIVE CONTROL of
At 9:50 a.m. on June 5, 2018, Employee #1 was in an 8 foot by 8-foot pit that was approximately 10 feet deep, cleaning out built-up sediment using a brush and 5-gallon bucket. Employee #1 was being helped by Employee #2, who was dumping the waste outside of the building that the pit was in.
Does your entry procedures/practices allow for “misaligning or removing sections of lines, pipes, or ducts” as a means to isolate a PRCS? If yes, do your procedures/practices specify the length of “sections of lines, pipes, or ducts” that have to be removed in order to meet the intent of “isolation”? I can not recall where
In light of the recent EPA citation at a bulk storage facility for anhydrous ammonia (NH3) I thought it would be fitting to highlight a best practice from the state of Illinois for this type of process. Most states are in the process of updating their state codes for the safe storage and handling of
If you have equipment that uses compressed air (CA) as an energy source, you will understand my frustrations with how poorly we manage this hazardous energy source. Typically, compressed air is provided via a plant-wide header system with drops for machine/equipment. These drops will then use a hose to deliver the compressed air to the
If you have read your meter’s manual you have most certainly come across it’s “correction calculation”, usually in the back of the manual. But Isobutane is not a common flammable, so why did it make it on the list of those popular flammables? It is because of the “green movement”… yes, Isobutane (R-600a) is a
