This morning, North of Chicago, a 2,000-gallon (8,750 pounds of NH3) nurse tank appears to have suffered a catastrophic failure releasing all 1,700 gallons/8,750 pounds of NH3 onto the road and ditches.   The reason I wonder if this was in the realm of a “Worst Case Release Scenario” is that we had Temps in the low 50’s, Night-time (the event occurred at 4:30 am) and we...

You’re getting ready to perform your pressure testing and the boss says the six-pack of Nitrogen or Oxygen (he can’t remember which) is out back.  You walk out back and this is all you see… what do you do?  By the way, pressure testing with Oxygen is illegal in most states and VERY UNSAFE in the first place!  But your boss said these are the cylinders for the testing… Upon...

Once or twice a year I check on the top 10 or 20 RMP accident histories to find any interesting trends.  I have been doing this for about 12 years and since starting them, Anhydrous Ammonia always finds it’s place as the top Toxic involved.  There are some who want to believe that Anhydrous Ammonia should not even be on the OSHA/EPA list of HHC/EHS and many more who believe that 10,000...

Failing to report a 172-pound release of NH3 (RQ=100 pounds) via an RV to the NRC, SERC, and LEPC in a “timely manner” can be costly! Respondent is a Wisconsin corporation, with a cream cheese and yogurt manufacturing facility. At all times relevant to this CAFO, the Facility was a facility at which a hazardous chemical was produced, used or stored. On April 17, 2017, EPA representatives...

This CAFO both initiates and resolves an administrative action for the assessment of monetary penalties, pursuant to Section 113(d) of the CAA. As discussed below, the CAFO resolves the following CAA violations that Complainant alleges occurred in connection with Respondent ‘s storage and handling of anhydrous ammonia at its cold storage and distribution facility: failure to design and maintain...

The business was convicted of one violation under the Environmental Protection Act and was fined $100,000 plus a victim fine surcharge of $25,000, with eight months to pay the fine. Background: The business operates a facility in the County of Lambton, which produces food grade carbon dioxide and is supplied with raw carbon dioxide from a neighboring supplier.   The carbon dioxide flows...

While doing some “Pre-Start Up Review” work for a client, I was tasked with reviewing the Emergency Response aspect of the facility’s ability to respond to an NH3 incident.  As part of this review I asked the question… Have we coordinated our emergency response needs with the LEPC and the local FD(s)?  This is a NEW facility and it will NOT have on-site ER capabilities...

This is a reminder that despite decades of work by to improve confined space entry by maritime safety organizations, training institutions, and vessel owners/operators, the risks have NOT BEEN ELIMINATED.  This is illustrated by a recent casualty where three (3) persons were asphyxiated while working onboard a laid-up Mobile Offshore Drilling Unit (MODU). Although the investigation...

This morning we had some serious weather pass through the Cincinnati area and many areas lost power.  Ironically I was conversing with a client in MI about the topic of emergency lighting inspections when the power at the facility I am at this week went out.  Of course, this facility’s emergency lighting activated and worked properly so that the employees could make their way to our...

THIS CASE IS NOT A FINAL ORDER OF THE REVIEW COMMISSION AS IT IS PENDING COMMISSION REVIEW This case arose from an anhydrous ammonia (NH3) release that occurred on May 23, 2017, at a Power Plant. OSHA conducted an investigation and subsequently issued a two-item citation for alleged violations with proposed penalties of $18,108.  In this case, the OSHRC discussed when a response to a release is...

As I have said many times before, the world of process safety can be a very confusing and strange sandbox to play in.  There are so many rumors and innuendoes stemming from the fact that our PSM/RMP world is made up of a weave of RAGAGEPs, many of which practicing process safety professional can’t fully understand and apply.  Just recently I was told by a piping contractor that “hex...