PCI' PSM and RMP Digest

SUBMIT by June 21, 2009

Keith — Wed, 21 Jan 2009 21:14:17 +0000

June 21, 1999 was the deadline for filing initial RMP's for those processes in operation at that time. The RMP must be resubmitted every 5 years, so this year, 2009, all those RMP's that were filed in 1999 will be due for re-submittal.

The EPA is making things somewhat easier by releasing software for online submittal. But, there is still an amount of work that must be done to properly file the information. All of the 14 elements of PSM must be reviewed to assure that all the information is up to date and accurate. It may be possible that your audit or PHA will need to be updated prior to submittal. Get started now to assure all your information is up to date and accurate.

If your ammonia inventory has changed, your worst case and alternative case scenarios may change, which in turn effects the toxic endpoint radius, which could change the estimated population.

If you need any assistance, send us a note or call, and we can help assure your information is accurate and on time.

Original post blogged on b2evolution.

You can quote me on this

Keith — Fri, 02 Jan 2009 15:36:49 +0000

I don’t quote any code or regulation without using the code or regulation as a guide. I learned early in my career that as soon as I utter the words “the code says….” someone would actually open the book I was referring to and point out some mistake. Even today, with all of the talking and interpreting and consulting, I will find that when I read the actual text, I see words that put an entirely different spin or interpretation on the topic at hand.

Original post blogged on b2evolution.

Last Chance

Keith — Mon, 15 Dec 2008 19:25:07 +0000

With the year’s end just around the corner, now may be a good time to review your PSM program and assure that all the things you’re supposed to do have been done. A lot of little tasks can be overlooked and cause a finding during your compliance audits. Have your operating procedures been reviewed and certified? What about your three year refresher training? And there could be some mechanical integrity issues out there, too. Did all this year’s MOC’s get closed out? The final review or signatures can often be overlooked.

Original post blogged on b2evolution.

Turnover

Keith — Mon, 01 Dec 2008 18:43:51 +0000

A lot of effort and resources have been spent by companies on PSM programs and implementation only to have the program fall to the wayside when personnel changes occur. We witness many programs that must be completely restarted from the ground up only because continuity is lost when a key person responsible for PSM leaves that role.

Original post blogged on b2evolution.

RMP floppies to become extinct!!!

Keith — Sat, 15 Nov 2008 16:43:25 +0000

EPA has announced that RMP*eSubmit will become available in early 2009. If you have filed an RMP, you will receive notice for the changes and how to obtain the new software.

So one of the last official uses of those pesky floppies will come to an end, and we will all be able to submit easier, faster, and more reliably, (not that reliability has been an issue)

A fact sheet for the new application can be downloaded here at http://www.epa.gov/OEM/docs/chem/RMP2009Reporting.pdf

Original post blogged on b2evolution.

Language barriers in ammonia refrigeration

Keith — Mon, 10 Nov 2008 20:59:21 +0000

In my travels around the country inspecting refrigeration systems, one thing that is consistent is the inconsistency of language. What some plants call a recirculator, others may call a pump package, or suction accumulator, or some other name. I recall one recirculator that the operators called the “pit tank”. When my curiosity could no longer be contained and I asked the operators why the recirculator was called “pit tank”, I was told that long ago the engine room equipment was in a pit inside the engine room. All the equipment had since been replaced with new stuff and the pit was filled with concrete, but the name of the old package stuck. And decades later, it was still called the pit tank, and probably will be forever.

Original post blogged on b2evolution.

Welcome to PCI's Digest

Keith — Wed, 29 Oct 2008 14:18:17 +0000

PCI has started this web page to provide a forum for the ammonia refrigeration industry to meet and discuss issues that are presented by complying with OSHA PSM and EPA RMP regulations. This area is open to all persons with any interest in these and any other relevant issue.

Comments should be limited to issues of ammonia refrigeration only, however, if a person has relevant advice learned from another industry that could be useful to our processes, then, by all means, join in.

Original post blogged on b2evolution.