Here we have a darn near perfect example as to why OSHA/EPA are now asking businesses with PSM/RMP covered process to "justify" their "maximum intended inventory(s)" of their Highly Hazardous Chemicals (HHC)/Extremely Hazardous Substances (EHS).  The business had, at the time of the EPA inspection four (4) 1-ton cylinders of Chlorine in the same room (i.e. 8,000 pounds).   Here is a process description from the business's 2015 RMP...

NOTE:  This case, as unfortunate as it is, stands in a very small group of State Fire Code violations, and in my memory stands atop of the pile @ $302,500.  It is rare for a state to issue code violations and even more rare for the dollar amount to be so high.  The one thing that this case has in common with the other state code violations... they almost always come after a serious accident.  

Today the GA Insurance and Safety Fire Commission has released their findings from their investigation into the deadly February 2017 Nitrogen leak. State inspectors determined that the incident was caused by the over-pressurization of a bulk storage tank. As a result of the investigation, the commission has issued civil penalties against the gas supplier totaling $302,500.  The investigation revealed:

Both OSHA’s and EPA’s process safety standards require operating procedures to contain the “steps required to correct or avoid deviation(s)”, but what exactly does this mean?  I really wish OSHA/EPA would have phrased it as “avoid or correct” as putting the words in this order is actual reality. Let's look at a simple process set-up where the process has two (2) alarm levels:

1) Hi-Level Alarm, and
2) Hi-Hi-Level Alarm

When the operator gets the hi-level alarm, he/she responds to this first alarm with the intent of AVOIDING the deviation. The process has NOT YET gone into a “deviated state” (i.e. has not exceeded the safe upper level), so the steps taken are actually to AVOID the deviation of “exceeding safe upper level”.

FAQ Number: 1784

Date Published: August 04, 2017 

Question: Does a facility have to count theft/diversion chemicals of interest in transportation packaging towards the screening threshold quantity if the packaging is on or attached to motive power to include overnight?

Answer: Yes. 6 CFR Part 27.203(c) states that facilities must calculate theft/diversion chemicals of interest in transportation packaging, as defined in 49 CFR 171.8, when calculating whether a facility is at or above the screening threshold quantity as defined in Appendix A.

6 CFR Part 27.203(b)(ii) indicates that release chemicals of interest attached to motive power are not counted towards the facility’s screening threshold quantity (release is only counted when detached from the motive power). However, the Rule does not provide that same exception for theft/diversion chemicals of interest in transportation packaging on or attached to motive power. Therefore, theft/diversion chemicals are reportable whether or not attached to motive power. For further explanation of “motive power”, see page 65398 of the preamble Vol. 72, No. 223, Tuesday, November 20, 2007.

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Flaring took place over several days at a bulk propane plant after an unidentified third-party carrier, who is used to haul propane to the site, inadvertently offloaded anhydrous ammonia into propane storage tanks at the site.  “It was a driver error on their end, and ultimately there was anhydrous that was in the storage tank in the truck that was delivered into ours”.  There have been no injuries associated with this incident.  As part of an emergency response plan, a team emptied the tank by flaring. The process was expected to take 48 to 60 hours.  “Ultimately, we want our facility back up and running to deliver propane to our customers as soon as possible, and the valves and stuff on our vessel are brass, and they’re made for propane and not for anhydrous”.  “So we do need to get the anhydrous out of the tank sooner than later, so we chose to do it immediately.”  CLICK HERE for more

This week we learned of a lawsuit in KS regarding the location of a proposed (actually permitted) cold storage facility. Landowners near the facility have filed suit asking a judge to reverse the county commission’s approval of the 411,000 square feet cold-storage facility near their homes. Neighbors say the plan doesn’t provide the right setbacks or enough screening from the plant.  Neighbors have been doing their research to ...

 
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