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Tag Archives: EPA
Update: Congressional Review Act & RMP Rule
The EPA’s RMP Rule update is NOT part of the initial 5 regulations that the House has decided to disapprove via the Congressional Review Act. (Bloomberg) …and here it is! US Rep. Markwayne Mullin (R-Okla.) introduced Congressional Review Act … Continue reading
Posted in EPA, General Information
Tagged EPA, RMP
Comments Off on Update: Congressional Review Act & RMP Rule
While there are Executive Branch delays to the EPA’s new RMP updates, another possibility is that congress can use the Congressional Review Act to nullify the changes. This week, a group of associations joined in a letter requesting exactly that. Multi-Association … Continue reading
OSHA replaces the ChemNEP inspection protocol
Since 2011, Ammonia Refrigeration facilities with 10,000lbs. or more of Anhydrous Ammonia have been subject to ChemNEP inspections under CPL 03-00-14. OSHA has replaced this program with a new program that makes some changes: Merges the Petroleum and Chemical NEPs … Continue reading
Merry Christmas from the EPA!
Yesterday the EPA released their long-awaited changes to the RMP rule which will take effect in roughly 60 days. (Don’t worry too much – the earliest actual compliance date for the new requirements is an additional year away and many … Continue reading
Who is Certified / Qualified to Train Process Operators?
Variations of this question are a favorite of OSHA/EPA inspectors and generally the question is infuriating. It reminds me of the stories of medieval monks arguing over how many angels can dance on the head of a pin – it’s … Continue reading
Posted in Compliance, EPA, Operator Training, OSHA
Tagged EPA, Operator Training, OSHA
Comments Off on Who is Certified / Qualified to Train Process Operators?
Misunderstanding MOC
Recently a valve manufacturer that I respect posted a LinkedIn advertisement for one of their new relief valves. I love new technology so I was really interested in it but noticed something they posted in the graphic: “No PSM Changes … Continue reading
Posted in Compliance, Good Engineering Practices, Management of Change
Tagged EPA, Management of Change, OSHA
Comments Off on Misunderstanding MOC
Region 7 Ammonia Safety Day
If you are within a couple hundred miles of Kansas City, Kansas it’s worth attending the 7th annual Region 7 Ammonia Safety Day which is held at the Kansas City Community College on May 28th, 2014. More information including the schedule and enrollment … Continue reading
Posted in Community Involvement, Compliance, CSB, EPA, Operator Training, OSHA
Tagged CSB, EPA, Operator Training, OSHA, PSM, RMP
Comments Off on Region 7 Ammonia Safety Day
Relief Systems – Understanding Design and Design Basis
In compliance audits all over the country, we’re finding that the requirements for documenting the relief systems are not being met in many PSM programs. How bad is the situation? About 1/3rd of the relief documentation we see shows that … Continue reading
Posted in Compliance, Good Engineering Practices
Tagged EPA, OSHA, RAGAGEP
Comments Off on Relief Systems – Understanding Design and Design Basis
EPA RMP Executive Summary
As part of GCAP’s PSM course, we pull the publically available RMP from RTKnet.org for each facility in the class. We’ve seem some strange things in the Executive Summary and wanted to share some guidance on what exactly should and should not … Continue reading
$205,000 fine for dumping 40 pounds of ammonia
Kodiak fish processor North Pacific Seafoods pleaded guilty Tuesday in federal court to illegally dumping ammonia into the Kodiak city sewer, while the processor’s chief engineer faces charges of his own. District Court Judge Ralph Beistline imposed $205,000 in criminal … Continue reading
Posted in Community Involvement, Compliance, EPA, Incidents
Tagged EPA, Fines, Incidents
Comments Off on $205,000 fine for dumping 40 pounds of ammonia
