PSM Determination
PSM Determination
(OP)
A client has asked me to determine if a compressor site would be subject to PSM. Under the "infrequently occupied remote site" rule my answer was "no", but he said that he understood that there was a "hydrocarbon inventory" limit of 50,000 lbm (the site has none of the Appendix A chemicals). I can't find anything about hydrocarbon inventory in 1910.119. Can someone point me to that place in the code where this hydrocarbon inventory issue would be addressed?
David Simpson, PE
MuleShoe Engineering
"Belief" is the acceptance of an hypotheses in the absence of data.
"Prejudice" is having an opinion not supported by the preponderance of the data.
"Knowledge" is only found through the accumulation and analysis of data.
The plural of anecdote is not "data"





RE: PSM Determination
Good luck,
Latexman
Need help writing a question or understanding a reply? forum1529: Translation Assistance for Engineers
RE: PSM Determination
a.2 gives the exceptions and lists normaly unoccupied facilities as exempt.
I would say you would want to read the exact wording of the code and determine if it is a "normally unoccupied facility".
RE: PSM Determination
David Simpson, PE
MuleShoe Engineering
"Belief" is the acceptance of an hypotheses in the absence of data.
"Prejudice" is having an opinion not supported by the preponderance of the data.
"Knowledge" is only found through the accumulation and analysis of data.
The plural of anecdote is not "data"
RE: PSM Determination
You might want to check this interpretation of NURF from the regulator whose voice counts more than some lawyer... "Only periodically" is not 49.9% IMHO.
https://www.osha.gov/pls/oshaweb/owadisp.show_docu...
My motto: Learn something new every day
Also: There's usually a good reason why everyone does it that way
RE: PSM Determination
David Simpson, PE
MuleShoe Engineering
"Belief" is the acceptance of an hypotheses in the absence of data.
"Prejudice" is having an opinion not supported by the preponderance of the data.
"Knowledge" is only found through the accumulation and analysis of data.
The plural of anecdote is not "data"
RE: PSM Determination
My motto: Learn something new every day
Also: There's usually a good reason why everyone does it that way
RE: PSM Determination
Good luck,
Latexman
Need help writing a question or understanding a reply? forum1529: Translation Assistance for Engineers
RE: PSM Determination
I am shocked that you would consider an agent of your government to be arbitrary and capricious and to use vague regulatory language as a revenue source.
LittleInch,
I don't have an opinion on this subject at all. If I could find an objective basis for a decision I would provide that to my client, but "objective" seems to be fluttering in the high winds here. The regulatory language was written by lawyers who couldn't make a living in private practice. Mostly it fails every possible "fair and unambiguous language" test. My client is following the advice of counsel on this one.
David Simpson, PE
MuleShoe Engineering
"Belief" is the acceptance of an hypotheses in the absence of data.
"Prejudice" is having an opinion not supported by the preponderance of the data.
"Knowledge" is only found through the accumulation and analysis of data.
The plural of anecdote is not "data"
RE: PSM Determination
My motto: Learn something new every day
Also: There's usually a good reason why everyone does it that way
RE: PSM Determination
David Simpson, PE
MuleShoe Engineering
"Belief" is the acceptance of an hypotheses in the absence of data.
"Prejudice" is having an opinion not supported by the preponderance of the data.
"Knowledge" is only found through the accumulation and analysis of data.
The plural of anecdote is not "data"
RE: PSM Determination
Good luck,
Latexman
Need help writing a question or understanding a reply? forum1529: Translation Assistance for Engineers
RE: PSM Determination
David Simpson, PE
MuleShoe Engineering
"Belief" is the acceptance of an hypotheses in the absence of data.
"Prejudice" is having an opinion not supported by the preponderance of the data.
"Knowledge" is only found through the accumulation and analysis of data.
The plural of anecdote is not "data"