This has been a huge battle in the power generation and semi-conductor industries! To me, it is very clear – as soon as the trailer is “dropped”, meaning the semi that was pulling the tube-trailer has been detached, then that trailer becomes a “stationary process”. EPA has several documents making this point and for those who visit my PSM/RMP Case Page you have seen first hand that EPA issues citations against this practice. But last month, EPA issued their official position regarding “tube-trailers”…