Materials of Construction and Compatibility MATTER

This is from an EPA Multimedia inspection that looked at a chemical process that was below the TQ, so they used the RMP GDC to inspect.  What they found in the flammable process was that…

… several of the facility’s components were made of aluminum. One condenser was installed with malleable iron tubes instead of stainless steel. Because of this, iron was being leached from the tubes and into the non-process water during operation which led to nearly continuous non-process effluent violations. This led to elevated iron levels in Respondent’s wastewater.

Respondent’s SMO 30% SDS lists aluminum, lead, brass, zinc, and tin as incompatible materials. SMO is corrosive to these metals. Respondent insulated its SMO piping with aluminum insulation. EPA observed corroded insulation that could have been exposed to SMO.

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