Application cont'd - doe-hdbk-1101-20040022

DOE-HDBK-1101-2004

1) When a hydrocarbon fuel is used exclusively onsite, the PSM Rule does not apply so

long as the fuel is not a part of a process containing another highly hazardous material

covered by the Rule [Q10].

2) The PSM Rule also does not apply to flammable liquids that are stored in atmospheric

tanks [Q11, Q12, Q13, Q14, Q15] or transferred through associated piping when those

liquids are kept below their normal boiling point without benefit of chilling or

refrigeration. Atmospheric storage tanks containing flammable liquids are not exempt if

they are located close enough to a covered process that they could be involved in a

catastrophic release [Q16, Q17]. Similarly, flammable liquids stored in barrels and

drums, would be exempt from coverage so long as they are not stored in such close

proximity to a covered process that an incident in that process could involve the

containers [Q18]. Where this exemption is invoked, the boiling point (or 10% point of

distillation) of the flammable liquid, and its proximity to and absence of interconnections

with other covered process equipment should be documented.

The process involves any quantity of an explosive or pyrotechnic HHC in a

manufacturing process. Storage and use of explosives outside the manufacturing process

are covered by 29 CFR 1910.109 [Q15]. Compliance with the DOE Manual 440.1-1,

DOE Explosive Safety Manual, should promote compliance with the PSM Rule, but does

not preclude the need to comply with the PSM Rule as well [Q19, Q20].

In addition to the instances cited above, the PSM Rule does not apply to the following situations.

Retail facilities (at which over half of the income is obtained from direct sales to end

users).

Oil or gas well drilling or servicing operations. The PSM Rule may apply to other

operations associated with drilling, such as separation or treatment of flammable liquids

and gases produced by these wells [Q21]. OSHA has determined that DOE petroleum

reserves must comply with the PSM Rule.

Remote facilities that are normally unoccupied [See glossary definition of normally

unoccupied remote facility).

Figure 1.2 provides a general logic diagram for determining the applicability of the PSM Rule in

DOE. No documentation for exclusion is required by the Rule. However, DOE contractors

should maintain a list of covered processes and, where the Rule is subject to interpretation,

document the basis for excluding a process [Q23].

Questions

Note: Where OSHA speaks of employers, this Handbook uses DOE contractors. Where OSHA

speaks of contractors, this Handbook uses subcontractors.

Does the calculated process inventory for a specific HHC apply to an entire plant, or

is each process unit viewed as a separate location?