This is one of the most common misunderstood RMP/PSM compliance issues for facilities that use rail cars as storage tanks and or use "tube trailers" as storage tanks.  EPA has been clear since 1998 on how these rail cars that are hooked up to the process and those that are "stored on spurs" are to be managed in regards to RMP threshold determination and "defintion of a process".

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Intro to Process Safety Management.

February 13, 2017 

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