Facilities should have a written program to ensure flanges are properly made up. Proper makeup of every flange in a piping system is important for reliability. Proper makeup includes:  … HomeRead More »

The ever-controversial “check valve” has now been defined as to when it should be formally included in the piping MI inspection process.  As we have discussed many times, if we claim a check valve in our PHA and/or SOP as a “safeguard,” then by all means, this valve has been defacto identified as a “safety critical valve”.  Here is the official definition...

The endpoint concentrations for regulated toxic substances under the risk management program rule (40 CFR Part 68 Appendix A) are listed in units of milligrams per liter (mg/L). Is this equivalent to parts per million (ppm)? … HomeRead More »

Passive mitigation is defined in § 68.3 as “equipment, devices, or technologies that function without human, mechanical, or other energy input.” … HomeRead More »

According to the definition of “process” in 40 CFR §68.3, any group of vessels that are interconnected is considered to be a single process. If a stationary source has two interconnected vessels and one contains 6,000 pounds of BUTANE while the other contains 6,000 pounds of PROPANE, is this a covered process under 40 CFR Part 68? … HomeRead More »

What does EPA plan to do to verify the accuracy and completeness of submitted Risk Management Plans (RMPs)? … HomeRead More »

Would the risk management program regulations cover the loading and unloading of transportation containers? … HomeRead More »

Some landfills collect methane gas and either vent, flare, or store it for subsequent fuel use. Are methane processes at landfills subject to the requirements of the EPA Risk Management Program? … HomeRead More »

Oleum, which is a mixture of sulfuric acid and sulfur trioxide, is listed as a regulated toxic substance in 40 CFR §68.130. Sulfur trioxide is also listed individually as a regulated toxic substance. Suppose a single process consists of one vessel containing oleum and one vessel containing sulfur trioxide. Must the amount of sulfur trioxide in the oleum be aggregated with the amount of pure sulfur...

Why are hydrochloric acid and hydrogen chloride listed separately in the list of regulated substances at 40 CFR §68.130? … HomeRead More »

Several toxic substances are listed as regulated substances under 40 CFR §68.130 with concentration qualifiers (e.g., “conc 37% or greater”). What does this concentration mean? When determining whether a threshold amount of these substances exists in a process, should I consider the weight of the entire solution, or simply the amount of the regulated toxic substance in the solution? …...

Scenario: Drums containing regulated substances (listed in 40 CFR §68.130) are stored in several separate locations at a stationary source. There is no possibility that an accidental release in any individual storage area would impact any of the other storage areas. Must the overall amount of the regulated substance present at the stationary source be considered when determining whether the threshold...