Safety Info Posts

EPA RMP citations @ refrigerated warehouse and storage facilities (NH3 & $37K)

Respondent is the owner or operator of the refrigerated warehousing and storage area. Respondent’s refrigerated distribution center includes a Program Level 3 covered process, as provided by 40 C.F.R. § 68.10(d). Respondent uses 74,000 pounds of ammonia (anhydrous), a regulated substance in an amount that exceeds the threshold quantity as part of its covered process…...

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EPA RMP citations @ food processing facility (NH3 & $17K)

On October 26, 2018, Respondent became the owner and operator of the facility upon the completion of a merger. According to Respondent’s RMP, Respondent handles approximately 22,477 pounds of anhydrous ammonia at the Facility. EPA conducted an inspection of the Facility on April 18, 2018, to evaluate the Facility’s compliance with CAA Section 112(r). On…...

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How a transformer becomes a Permit-Required Confined Space

On November 30, 2015, an employee entered a large transformer, top cover removed, which had previously been filled with nitrogen. The employee fell unconscious one he/she entered the space. Another employee entered to retrieve the first employee and also fell unconscious. Another employee (#3) followed and also fell unconscious. Employees #1 and #2 died. Employee…...

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Fatal Flash Fire inside PRCS (non-intrinsically safe light)

A 52-year-old male was fatally injured when he was burned due to a flash fire inside a 23’ long x 6’ diameter stainless steel tank. The company was contracted to restore a stainless steel tank so that it could be returned to the dairy process as a Sugar Tank. At the time of the incident,…...

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Fatal flammable liquid (Alcohols, (Ethanol), n.o.s.) transfer (Tanker to tote)

At 1:00 p.m. on July 24, 2019, two (2) employees were filling a tanker truck from a portable bulk container (IBC) when a flash fire occurred. Employee #1 was standing on top of the ethanol tanker truck and his body, clothing, the tanker, tote, and hose caught on fire. Employee #1 attempted to slide down…...

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Flammable Liquid transfer WITHOUT a spring-loaded CLOSE valve

At 3:11 p.m. Employee #1, who had worked with the company for three months as a forklift operator/ repacking, was working alone in the repacking area making a transfer of acetone (flammable liquid) from an elevated 793-gallon stainless steel intermediate bulk container (tote) to a 350-gallon stainless steel tote on the floor. In order to…...

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EPA RMP Program 2 citations @ agricultural storage and supply facility (NH3 & $20K w/ $25K SEP)

Respondent owns and operates an agricultural storage and supply facility. On August 16, 2016, an accidental release of anhydrous ammonia occurred at Respondent’s Facility when filling a storage tank. The release resulted in the hospitalization of an employee. 22. On or about March 12, 2019, representatives of the EPA conducted an inspection of Respondent’s Facility…...

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Ammonia Refrigeration, flange connections, gaskets, and torque (EPA Region VI)

Many years ago I had an open debate with a “grandfather of refrigeration” on his turf in front of about 30 other refrigeration professionals and the debate was about “flange connections”, ASME B16, and TORQUE and how it all applied to covered processes regardless of what the HHC/EHS was, including anhydrous ammonia in a refrigeration…...

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Air-Line respirator with Auxiliary bottle has an APF of 1,000 or 10,000?

So what is the Assigned-Protection Factor (APF) for an air-line respirator, commonly used inside PRCSs which has, or has the potential to have an IDLH atmosphere?  Is it 1,000 or 10,000?  I have always been taught/trained that the simple air-line respirator (Pressure-demand/Positive pressure mode) WITHOUT the Auxilary/Back-up cylinder the APF is 1,000, but the addition…...

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What does a “suitable telltale indicator” look like when we have a dual relief system (Part II)

My January article “What does a “suitable telltale indicator” look like when we have a dual relief system” was a hit as I received numerous requests for information on how to get these special gauges.  As I promised each of you in the ammonia refrigeration industry, here is what I have used on my NH3…...

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Bypassing safety devices is a no-no! (BSEE Alert)

On December 30, 2019, the Bureau of Safety and Environmental Enforcement (BSEE) Inspectors working offshore discovered that a level safety high had been improperly deactivated with a zip tie, resulting in the issuance of a P-103 incident of noncompliance (INC). There have been multiple instances across the Gulf of Mexico in which operators have failed…...

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Pressure Relief Valve Testing on Pneumatic Systems (USCG Bulletin)

Although this Coast Gaurd Bulletin is specific to maritime vessels, it can and should be applied to relief valves on land as well.  There are some really good practices in this bulletin, such as when to perform the test in-situ vs. bench testing.  The incident happened when a relief valve on the associated compressor was…...

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