Bryan Haywood

EPA RMP citations @ pork processing plant (NH3 & $79K)

Respondent was engaged in the pork processing business and operated a closed-loop refrigeration system at the Facility which utilized anhydrous ammonia as a refrigerant. Respondent also owned and operated an anhydrous ammonia storage tank at the Facility. Respondent used and stored up to 153,000 lbs. of anhydrous ammonia in the Facility’s refrigeration system and stored…...

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EPA RMP General Duty Clause citations @ cold storage distribution facility (NH3 & $184K)

The Respondent’s facility consists of a large distribution warehouse, including a cold storage area, over 100 truck loading bays, 80 trucks, a truck maintenance garage, a diesel fueling depot, an administrative office, and an employee cafeteria and locker rooms. There is an approximately 1,500 square foot ammonia refrigeration machinery room (the “Machinery Room”) located at the…...

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EPA RMP citations @ combined-cycle cogeneration power plant (NH3 & $109K)

Respondent owns a combined-cycle cogeneration power plant facility. From approximately 1991 to December 2013, the Facility was operated as a combined-cycle cogeneration power plant. Beginning in April 2012, the Facility halted full-time operations and began operating one or two days per year in order to conduct ISO-New England capability tests; however, the ammonia refrigeration system…...

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EPA RMP citations @ fertilizer distributor (NH3 & $10K)

On September 1, 2016, EPA conducted a compliance inspection of the Respondent’s facility to determine compliance with the Chemical Accident Prevention Provisions (CAPP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the CAA. The EPA found that the Respondent had violated regulations implementing Section 112(r) of the CAA by failing to comply…...

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Permit-Required Confined Space Alert – Hopper (MSHA)

A miner entered a feed hopper to remove bolts on the skirt board. When he heard a bull dozer that typically pushes material into the hopper approaching, the miner tried to escape through the opening at the bottom of the hopper. The bull dozer pushed material into the hopper, unaware that the miner was inside, burying him up to his…...

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Flammable Liquid Vapors, Tanker Truck, & Hot Work results in double fatality at an Russian oil and gas field

A December 2015 video at Russian oil and gas field in Siberia recently came to light and although it is tough to watch two workers perish, it is a video that needs to be shared to show the hazards of Hot Work on flammable liquid containers.  The video shows two workers using a torch to thaw…...

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Hydrostatic Relief done RIGHT!

Recently I had the pleasure of working with a team of engineers and EHS professionals on a PHA project for an Anhydrous Ammonia process. For those who may not know, hydrostatic relief valves are required on Anhydrous Ammonia processes, that are NOT associated with mechanical refrigeration, and unfortunately, there is little guidance on their design…...

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A review of OSHA’s “Shaming Campaign”

NOTE: a reduction in penalty can come about many different ways, so a reduction in penalty does not imply that the hazardous condition did not exist at the time of the inspection.  Many reductions in penalties occur due to negotiations requiring abatement of the hazard and extra’s like training supervisors in OSHA 10-hr course.   …...

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