SAFTENG Safety Info Posts SAFTENG Safety Info Posts
2nd Quarter UPDATE with 289 Shocker and Accident Photos
Now over 13,750 exclusive unsafe acts/conditions and accident/injuries photos
and over 1,000 ppt's & doc's from more than 2,776 contributors!
 
Many THANKS to my renewing "Partner in Safety"
azco logo
since 2011
 
EPA RMP Citations @ a Refinery ($120K )
Safety Info Posts - PSM and RMP Citations/Analysis
Written by Bryan Haywood   
Thursday, 21 August 2014 20:05

Count 1. Violation of 40 C.F.R. § 68.69(c)

40 C.P.R.§ 68.69(c) requires, in relevant part, that owners and operators must annually certify that operating procedures are current and accurate.

Respondent requires that operating procedures certifications are complete by May 26 of each calendar year. Respondent failed to certify procedures by this deadline for two processes in 2009. Through its failure to annually certify that operating procedures were current and accurate, Respondent violated 40 C.F.R. § 68.69(c).

 
Process Safety and calibrated direct-reading instrument
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Thursday, 21 August 2014 13:56

On the most basic level, can a PSM/RMP program function and comply with all regulatory requirements and NOT have a calibrated direct-reading instrument?

This is not meant to be a trick question, but rather looking to "ground me" in my expectations.  Having grown up in the PSM/RMP era in petrochem for 20 years, having a calibrated direct-reading instrument available was like having my hardhat and safety glasses available.  I do not think a day went by where I did not personally rely on a portable gas detector.  In fact, several of my plants we were REQUIRED to wear a detector at all times while signed into the unit.  But the $64M question is...

Last Updated on Thursday, 21 August 2014 14:04
 
2013 HAZMAT Loading/Unloading Incidents
Safety Info Posts - Hazardous Materials
Written by Bryan Haywood   
Wednesday, 20 August 2014 20:40

U.S. Department of Transportation
Pipeline and Hazardous Materials Safety Administration
Office of Hazardous Material Safety
2013 (All Column Values) Hazmat Summary by Transportation Phase

Screen Shot 2014-08-20 at 9.43.23 PM

Screen Shot 2014-08-20 at 9.45.04 PM

CLICK HERECLICK HERE to work with the database

Last Updated on Wednesday, 20 August 2014 20:48
 
10 years of NH3 and CL2 release data (2004-2014)
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Wednesday, 20 August 2014 13:11

Last week I shared an article from allgov.com that provided some data on Ammonia releases.  The article was not well received by some folks and others appreciated the info, which is par for the course when you post this kind of material.  But some have gone off the deep-end and called the article "spin" and "propoganda" against ammonia.  For the record, the article's data was NOT 100% factual, but as it turns out it was actually MORE FAVORABLE to ammonia than what my data analysis shows.  The allgov.com article appears to have used other sources, but I used the following sources for my data:

  • Hazardous Substances Emergency Events Surveillance (HSEES)
  • National Toxic Substance Incidents Program (NTSIP)
  • United States Coast Guard National Response Center
  • The Right-to-Know Network, RMP Data Base

This posting is to provide factual numbers for the two most widely used PSM/RMP chemicals (NH3 and CL2) and compare uncontrolled releases from their primary containment.

Last Updated on Wednesday, 20 August 2014 20:38
 
54 incidents & 4 updates (8/17/14)
Safety Info Posts - Incident Alerts
Written by Bryan Haywood   
Sunday, 17 August 2014 20:50
Last Updated on Sunday, 17 August 2014 20:54
 
OSHRC decision on PSM Contractor Training and Work Permits
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Saturday, 16 August 2014 19:31

The host facility, an anhydrous ammonia storage facility,  contracted with a company, who in turn, contracted with Respondent (sub-contractor) to perform services on pipelines within the facility. Respondent provides sixteen different services or “lines”, as it refers to them. Each of these lines is comprised of crew members that have been trained and tested in that particular discipline. Some of the crew members are trained in multiple lines, and, based on their respective amount of experience, may be designated as a crew lead. One of these lines involves the installation of isolation plugs (also referred to as mechanical plugs) into pipelines. These plugs serve as a barrier between flammable gases in the pipelines and hot work, such as welding. The plug has a series of bolts that are tightened in order to expand a two-part rubber seal that presses outward against the pipe. Once the rings are expanded, the plug is filled with water and pressurized by bleeding off the air within the plug. A through-port is installed and connected to a hose, which is placed in a bucket of water approximately 35 to 50 feet away. The purpose of the hose and bucket is to detect the accumulation of pressure behind the plug, which results from hydrocarbons being released from the pipe due to the presence of heat. If there is pressure build-up, the hot work is supposed to be stopped by the individual monitoring the plug and will not recommence until the pressure is reduced. The plug also has a gauge that measures the pressure of the water in between the rubber seals. As was the case here, improper installation and/or handling of the plug can result in serious injuries.

Last Updated on Saturday, 16 August 2014 19:40
 
Safety Bulletin - Entry of a confined space on board a cargo ship resulting in three fatalities (Marine Accident Investigation Branch (MAIB)
Safety Info Posts - Permit Required Confined Spaces
Written by Bryan Haywood   
Saturday, 16 August 2014 14:15

At approximately 0645 (UTC+1) on 26 May 2014, three crew members on board a cargo ship were found unconscious in the main cargo hold forward access compartment, which was sited in the vessel’s forecastle. The crew members were recovered from the compartment but, despite intensive resuscitation efforts by their rescuers, they did not survive.

Last Updated on Saturday, 16 August 2014 14:24
 
EPA RMP Citations @ agricultural chemical manufacturing facility (NH3 and aqueous ammonia; $101K) )
Safety Info Posts - PSM and RMP Citations/Analysis
Written by Bryan Haywood   
Saturday, 16 August 2014 13:29

Respondent owns and operates an agricultural chemical manufacturing facility. Respondent has been subject to the RMP requirements since June 21, 1999, as provided in 40 C.F.R. § 68.1O(a)(1), because the facility used, stored, manufactured, or handled more than the TQ of 10,000 pounds of anhydrous ammonia in a single process as of that date. Respondent became subject to the RMP requirements for aqueous ammonia on July 1, 2010, the date on which the facility first used, stored, manufactured, or bandied more than the TQ of20,000 pounds of aqueous ammonia in a single process.

Last Updated on Saturday, 16 August 2014 13:35
 
EPA RMP Citations @ liquefied petroleum gas manufacturing and storage facility (LPG; $74,000)
Safety Info Posts - PSM and RMP Citations/Analysis
Written by Bryan Haywood   
Saturday, 16 August 2014 12:41

Respondent owns and operates a liquefied petroleum gas manufacturing and storage facility. On January 26, 2005 Respondent submitted to U.S. EPA a Risk Management Plan (RMP) for its Facility. On July 5, 2012, U.S. EPA conducted an inspection at Respondent's Facility to determine its compliance with 40 C.F.R. Part 68. Respondent held 10,000 lbs. or more of butane and propane for use in its operations at its Facility and, thus, exceeded the applicability threshold established by 40 C.F.R. § 68.130, and became subject to 40 C.F.R. Part 68. Respondent acknowledged in its RMP, that its Facility was required to meet Program 3 eligibility requirements. Based on U.S. EPA's inspection of Respondent's Facility conducted on June 5, 2012, and a review of Respondent's additional information received by U.S. EPA subsequent to that date, U.S. EPA alleged that Respondent violated the Hazard Assessment and Program 3 Prevention Program regulations as follows:

Last Updated on Saturday, 16 August 2014 12:44
 
EPA RMP Citations @ ethanol facility (mixture with a NFPA rating of 4; $31,227 w/ SEP $23,716 )
Safety Info Posts - PSM and RMP Citations/Analysis
Written by Bryan Haywood   
Saturday, 16 August 2014 12:03

Respondent's denaturant process contains a mixture with a NFPA rating of 4, and is therefore a flammable mixture as specified in 40 C.F.R. § 68.115(b)(2). On or about May 2-3, 2012, EPA conducted an inspection to determine compliance with RMP 40 C.F.R. Part 68. Respondent's denaturant process stores approximately 715,000 pounds, with the entire weight of the mixture being treated as a regulated substance. Respondent was required under 40 C.F.R. Part 68, to develop and implement a Risk Management Program that includes a hazard assessment, a prevention program, an emergency response program, and to file a Risk Management Plan. Records collected during the inspection showed that Respondent failed to fully comply with 40 C.F.R. Part 68, specifically:

Last Updated on Saturday, 16 August 2014 12:46
 
«StartPrev12NextEnd»

Page 1 of 2
 

wreck it all 

Members Usage Guide

 

 Please Support My

Partners in Safety!

 

MEA-SFTENG

 

 organdonor

 

 safteng_man

911_4

Some of Our Key Clients

What They Are Saying About Us...

“Bryan is an excellent safety trainer and has a vast amount of safety knowledge. His session are done in an enjoyable manner presenting the information in an interesting way that grabs your attention and gets you the information you need for success. He is one of the good guys in safety today a...

Mike Staublin
Date: Apr 01, 2010