The owner or operator of a facility who must prepare a Risk Management Plan (RMP) for a Program 3 process is required to develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information (40 CFR §68.69(a)). The owner or operator…...
Pursuant to the hazard assessment requirements in 40 CFR Part 68, Subpart B, an owner or operator is required to conduct an offsite consequence analysis and analyze a worst-case release scenario and alternative release scenarios as part of a risk management plan (RMP). When completing these scenarios, public receptors need to be identified. A public…...
Pursuant to 40 CFR §68.42(a), the owner or operator of a stationary source subject to the risk management program regulations must document significant accidental releases of regulated substances from a covered process in the five years prior to the submission of an initial or updated risk management plan (RMP). For the five-year accident history, does…...
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? … Membership Required You must be a member to access this content.View Membership...
A flammable substance listed in 40 CFR §68.130 is excluded from the risk management program regulations when it is used as a fuel or held for sale as a fuel at a retail facility (§68.126). What is the definition of fuel for the purposes of this exclusion?… Membership Required You must be a member to...
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…...
The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. Do all facilities subject to…...
What I am going to suggest in this article is NOT necessarily a code or standard requirement, but just some SOUND ADVICE on how to improve safety around expansion/seismic joints where hoses are utilized to allow for flexibility. As my clients know, I HATE hoses in a chemical process and I am OCD when it…...
I am sure the thought has crossed everyone’s mind who has issued an entry permit for a HAZ ATM entry… “should the attendant be in breathing air as well?”. Is there an exposure potential for the attendant to the HAZ ATM from within the PRCS? Most attendants are stationed right outside the entry portal, add…...
One of the biggest mistakes I see in my auditing and the biggest frustration I have when facilities state they treat all of their confined spaces as PRCS is that most have not recognized the fact that a roll-off trash compactor and/or large palletizers are actually Permit-Required Confined Spaces. For example, we have a large…...
Our behind the scenes debate continues and now a number of clients have joined in with their take on the matter. The fundamental part of our debate has come down to two (2) positions: does a fall inside or into a Confined Space make that CS a Permit-Required Confined Space? if you said yes to…...
Respondent operates an ammonia refrigerant system which contains approximately 8,487 pounds of ammonia which is processed, handled, and stored in the ammonia refrigerant systems, and ammonia is a regulated extremely hazardous substance listed under Section 112(r)(3) at 40 C.F.R. § 68.130. EPA inspected the Facility on June 7, 2018. Prior to the June 7, 2018…...
