Application cont'd - hdbk11010028

DOE-HDBK-1101-96

25.

Does the PSM Rule apply to onsite movement of HHCs in containers, trucks, or railcars?

The PSM Rule applies to the onsite movement and storage of HHCs in containers or vehicles

operated by employees. Onsite and offsite movement of HHCs by commercial carriers is

regulated by other agencies such as the U.S. Department of Transportation (DOT), the Office

of Pipeline Safety, and the U.S. Coast Guard.

For example, a railroad tank car is subject to PSM requirements if it contains more than the TQ

of an HHC. However, the exception for flammable liquids stored in atmospheric tanks or

transferred below their normal boiling point without the benefit of chilling or refrigeration may

apply so long as the rail car is not pressurized.

26.

A process contains a material not covered by the PSM Rule. However, release of this

material to the atmosphere in sufficient amounts would generate (e.g., through oxidation,

fire, reaction with moisture, etc.) an HHC in excess of its TQ. Is this process covered?

A process is not covered under the PSM Rule unless it contains an HHC that exceeds its TQ.

However, when DOE contractors recognize situations with significant potential impacts to

workers, the public, the environment, or facilities and operations; they should consider

applying appropriate PSM safety management elements.

27.

A process normally contains no HHCs, but under upset conditions, the process could

generate an HHC in an amount in excess of the TQ. Is the process covered?

Processes are covered by the Rule only if, at any time under normal processing circumstances,

they contain an HHC in excess of its TQ. The ability to generate an HHC during an upset

condition does not invoke coverage by the PSM Rule. However, when DOE contractors

recognize situations with significant potential for safety and health impacts, they should

consider applying appropriate PSM practices to protect worker health and safety.

28.

An Appendix A chemical is created within and then immediately consumed in a process.

Does the brief existence of this short-term intermediate chemical cause this process to be

covered by the Rule? If the inventory of this intermediate can only exceed the TQ under

upset conditions, is it a covered process?

A process is covered if, at any time in one location, it contains an HHC in excess of its TQ.

This process is covered as long as the intermediate existed under normal conditions in the

process. If the intermediate chemical could exist above the TQ only under upset conditions,

then the process is not covered. However, when DOE contractors recognize situations with

significant potential for safety and health impacts, they should consider applying appropriate

PSM practices to protect worker health and safety.

29.

Please clarify the exemptions for the following types of operations covered under the

workplace fuel criteria: hazardous waste incinerators, refinery fuel gas systems, liquified

petroleum gas (LPG) storage for vehicle fueling, natural gas systems for utility boilers,

and natural gas systems used to sweep flare systems.