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Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of contractor safety procedures in Section 7.14 and the date of the most recent review or revision of contractor safety performance in Section 7.15.
What are the requirements related to contractor procedures and performance?...
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The Chemical Accident Prevention Provisions require the completion of a worst-case release scenario analysis (40 CFR §68.25). This analysis includes estimating the greatest distance to endpoint as defined by the parameters in §68.22.
Is there a required minimum or maximum distance for the distance to endpoint in the worst case release scenario?
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Pursuant to 40 CFR Part 68, Subpart G, the owner or operator of a stationary source subject to the risk management program regulations in Part 68 must develop and submit a risk management plan (RMP).
Does the owner or operator have to maintain a written copy of the RMP on site at the stationary source?
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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 shall certify annually that these operating...
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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 receptor means offsite residences, institutions (e.g.,...
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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 the owner or operator need to include accidental...
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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?
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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?
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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 controls such as alarms considered administrative controls...
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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 the risk management program...
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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 comes to the required utilization of hoses such as loading/unloading hoses. I am a huge...
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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 to the scenario forced fresh-air ventilation into the space...
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