Questions cont'd - doe-hdbk-1101-20040030

DOE-HDBK-1101-2004

This process is covered. DOE contractors may wish to adopt the following approach.

Extend the boundary upstream and downstream to the point at which there is no

reasonable potential for a catastrophic release. At least the equipment immediately

upstream and downstream from the vessel containing the TQ of the HHC should be

included in the boundaries of the process.

32.

A batch process uses an HHC, above its TQ, in one of its many processing steps. Is

this step, and its associated equipment, a covered process?

Yes. In addition, the same strategy discussed in Questions 30 and 31 may apply to the

equipment used in a batch process. A DOE contractor may apply a similar approach in

setting the boundaries around the processing steps that are covered under the Rule.

33.

Must the inventory of HHCs contained in offsite interconnecting pipelines be

included in the inventory calculation? If so, can reliable isolation devices at the

fence line be used to limit the inventory used in the coverage calculation?

DOE contractors should consider the amount of material that could reasonably be

released if a loss of containment occurred onsite. If this amount represents a catastrophic

release to the workplace (i.e., it exceeds the TQ for an HHC), then the process is covered.

OSHA has not yet recognized the use of isolation devices as adequate mechanisms to

limit inventories for purposes of determining coverage under the PSM Rule. However, if

isolation devices are considered as preventative or mitigative control measures against

catastrophic releases, then documentation should be provided as to their effectiveness and

34.

Does the PSM Rule apply to laboratory and research operations?

A laboratory or research operation involving at least the TQ of one or more HHCs is

subject to the PSM Rule.

35.

Does the PSM Rule apply to EPA regulated and permitted Resource Conservation

and Recovery Act (RCRA) hazardous waste treatment, storage, and disposal (TSD)

facilities, when such facilities keep onsite in one location a hazardous waste chemical

in a concentration and quantity that exceeds the applicable TQ of Appendix A.

Yes. Contractors having TSD facilities which contain covered processes must comply

with the PSM Rule.