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EPA RMP GDC @ refrigerated food distribution warehouse (NH3 & $101K)

At all relevant times, Respondent owned and operated a refrigerated food distribution warehouse with an ammonia refrigerant system which contains approximately 9,617 pounds of ammonia. EPA inspected the facility on August 9, 2018. Prior to the August 9, 2018, inspection, Respondent had not performed a hazard analysis nor developed standard operating procedures for the ammonia […]

Definition of Confined Space, as it may apply to large product heating and aging furnaces (OSHA LOI)

Background Product parts are heated in the furnaces using natural gas to temperatures ranging from 700ºF to 2200ºF to facilitate material processing. The furnace doors are actuated remotely from either the cab of a forklift or a control panel. Parts are loaded and unloaded from the furnaces using forklifts during production runs. The furnaces range

Personal Fall Arrest System or Ladder Safety System on Fixed Ladders, and Fixed Ladders Used on Grain Silos for Emergency Escape (OSHA LOI)

Background: Multiple sections of off-set ladders are being designed to be installed on the outside of a grain silo that is 80 feet or more in height. Rest platforms will be installed at each off-set and will be provided with guardrail systems to meet OSHA’s requirements. The rest platforms measure 3 feet by 3 feet

EPA RMP Program 2 citations @ agriculture retail facility (NH3 & $20K, w/ $80K SEP)

On or about August 10, 2018, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had the capacity to store 650,000 pounds of anhydrous ammonia at the Facility, and regularly stored

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