This inspection was for the purpose of determining compliance with Section 112(r)(7) accidental release prevention requirements of the Clean Air Act, as amended in 1990. The scope of this Inspection may include, but is not limited to: reviewing and obtaining copies of documents and records Interviews and taking of statements reviewing of chemical storage, handling, […]
Respondent is a Poultry Processor doing business in the States of Alabama, Arkansas, and Mississippi. On November 10, 2016, the EPA issued to Respondent a Notice of Concern letter which informed the Respondent that EPA had concerns that the Respondent was not in compliance with the CAA Section 112(r). The Respondent and EPA met on
On Sunday, February 23rd at approximately 12:34 AM, the Joplin Fire Department responded to a reported structure fire with people possibly still inside. A Joplin Police Department officer in the neighborhood patroling arrived at the same time we were getting the call and was able to assist all occupants out of the structure through the
This is a lesson in reporting your releases! Two releases of anhydrous ammonia from a refrigeration process result in $150,000 in fines ($75K for EPCRA and $75K for CERCLA) and a $425,000 SEP to install detectors and emergency shutdown systems. The Complaint alleges that: Respondent violated Section 103(a) of the Comprehensive Environmental Response, Compensation, and
Respondent owns a chemical supply outlet where chlorine was present in a process above the 2,500 pounds TQ, and sulfur dioxide was in a present in a process above the 5,000 pounds TQ from at least March 16, 2010. Respondent was required to submit and have in place an RMP for the facility. Under 40
On March 2, 2012 Employee #1 of a food processing company was standing-by while a contractor was pressure testing a newly installed compressed air unit. The pipe exploded when the contractor tried to tighten a joint on a leaking pipe and employee #1 was struck in the head by a two-inch steel pipe.
We have discussed “pressure testing” and the hazards associated with these required tests many times. This is an example of what can go wrong when doing these tests with a compressed gas vs. hydrostatically! A mechanical contractor was increasing the pressure into the 4-inch compressed air line from approximately 125psi to the TEST PRESSURE of
OSHA has dined a Delaware Rail Car Tank Cleaning And Repair Facility $371,276 for Safety and Health Hazards. This same company, different location, was cited last year after a PRCS fatality inside a Rail Car (PRCS fatality cleaning a railcar (Oxygen Deficient and $551K): Membership Content). This inspection was initiated due to a complaint, but surely
Earlier today I posted a recent OSHA citation where a facility was cited for not having procedures regarding the means to isolate and verify ZES for pneumatic energy sources (i.e. plant air). For some reason, on nearly all of my LOTO projects I find that air sources are a bastardized source of energy when it
This OSHA citation involves items other than LOTO. Still, the LOTO citations caught my eye precisely because the equipment-specific procedures did NOT state how pneumatic sources (e.g., air) were to be verified at a Zero Energy State (ZES). The means to verify a ZES is a critical step in LOTO, and far too often, the
A lot of older plants in the USA use their water piping as their main ground for a lot of purposes. In one such plant, the grounding connections for the flammable liquid transfers were tied into the water piping. One day a water pipe failed and caused quite a bit of damage; the price to
A number of years ago a former client decided that process safety was not worth the effort and wanted to get their process below the 10,000 pounds TQ for their LPG. They hired a local architect/engineering firm that had no experience with the storage, handling, and processing of LPGs. This “architect/engineering firm” advised the facility
