OSHA Emerg. Response Violation
Senerio:
Employee while making rounds noticed a slight smell of NH3 at the common water sump for our 3-750 ton evaporative condensors.
The Refer Mech. went up on the roof to investigate (Evaporative Condensors sit approx. 35' in the air with thier highest level @ Approx 50' elevation)
He visually noticed a slight, barely noticible, intermitant, puff of vapor at the highest elavation of the condensor.
Employee then shut off the vapor valves to and the liquid valves from this condensor.
Upon inspection a pin hole approx .020" in diameter was discovered in one of the condensor tubes.
Due to the size of the tube bundle, the calculated amount of the release, (790 pounds) this was a reportable release.
OSHA did an inspection of our PSM program and cited a violation for the employee shutting off the valves.
OSHA considered shutting these valves an emergency response, and we did not have a written procedure for handleing of small releases.
QUESTION: Where can I find direction/information on determining what is a small or incidental release and how to write an emergency response SOP for small releases that are incidental or are unknown but do not require evacuation of employees or all out HAZMAT response?
Re: OSHA Emerg. Response Violation
Quote:
Originally Posted by
NH3GUY
Senerio:
Employee while making rounds noticed a slight smell of NH3 at the common water sump for our 3-750 ton evaporative condensors.
The Refer Mech. went up on the roof to investigate (Evaporative Condensors sit approx. 35' in the air with thier highest level @ Approx 50' elevation)
He visually noticed a slight, barely noticible, intermitant, puff of vapor at the highest elavation of the condensor.
Employee then shut off the vapor valves to and the liquid valves from this condensor.
Upon inspection a pin hole approx .020" in diameter was discovered in one of the condensor tubes.
Due to the size of the tube bundle, the calculated amount of the release, (790 pounds) this was a reportable release.
OSHA did an inspection of our PSM program and cited a violation for the employee shutting off the valves.
OSHA considered shutting these valves an emergency response, and we did not have a written procedure for handleing of small releases.
QUESTION: Where can I find direction/information on determining what is a small or incidental release and how to write an emergency response SOP for small releases that are incidental or are unknown but do not require evacuation of employees or all out HAZMAT response?
You might want to try searching www.epa.gov, it might be able to answer your question or your local LEPC
