PSM and RMP Citations/Analysis

NOTICE:  The OSHA cases found in these posts may be taken from OSHA citations BEFORE the “informal conference” takes places.  These cases are posted for AWARENESS and EDUCATIONAL purposes only.  I have scrubbed company names and locations from my postings, but not from the OSHA and EPA documents.  These posts are in NO WAY meant to shame any company, just providing information showing the things OSHA/EPA are finding in their PSM/RMP inspections.

EPA RMP Citations @ Gas Plant (Flammables & $196K w/ $111K SEP)

Respondent owns and operates a Gas Plant. On or about July 11 and 12, 2023, representatives of the EPA inspected the 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 greater than 10,000 pounds of propane and greater…...

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EPA RMP Citations (NH3 & $105K)

Respondent is the owner and/or operator of the Facility, which operates a chemical storage and distribution facility. The respondent had on-site storage for 50,000 pounds of cyclohexylamine, 1,800,000 pounds of chlorine, 1,500,000 pounds of sulfur dioxide (anhydrous), 265,000 pounds of ammonia (anhydrous), 350,000 pounds of ammonia (concentration 20% or greater), and 17,000 pounds of hydrofluoric…...

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EPA RMP citations @ Water Treatment Plant (Cl2 & $2K)

I usually do not waste time posting the Expedited Settlement Agreements, as these cases are typically minor record-keeping violations with low-dollar amount citations. However, one thing that irks me is how public utilities receive lenient treatment regarding the amount they pay for violating the EPA’s RMP regulations. And to make matters worse, they dare to…...

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EPA RMP Citations @ food facility (NH3 & $135K)

Respondent is the owner and/or operator of a facility that operates an ammonia refrigeration plant with 39,000 pounds of anhydrous ammonia. Respondent has one RMProgram level 3 covered process, which stores or otherwise uses anhydrous ammonia in an amount exceeding its applicable threshold of 10,000 pounds. On July 18, 2023, the EPA conducted an on-site…...

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EPA RMP/EPCRA citations @ refinery (HF and SO2 & $270K)

Respondent operated a facility that refines petroleum products using a hydrofluoric acid alkylation process. Hydrofluoric Acid is a “regulated toxic substance” listed under CAA Section 112(r)(3), 42 U.S.C. § 7412(r)(3), with a TQ of 1,000 lbs. See 40 C.F.R. § 68.130, Tables 1 and 2. On June 2-3, 2022, EPA performed an inspection of the…...

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EPA RMP & EPCRA Citations @ Food Plant (NH3 & $210K

Respondent operated a facility that utilizes anhydrous ammonia to provide cooling capabilities to processing, shipping, cooler areas, silos, and chillers for its beef and meat products. On March 30, 2022, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, EPCRA Sections 304-312,…...

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OSHA PSM Citations @ Food Processor (NH3 & 131K)

The state of VA has fined a food processor $131,535 for a July 31, 2024 anhydrous ammonia leak that hospitalized 33 people. The leak triggered the evacuation of 287 employees working at the facility. Five of the 33 victims were hospitalized with serious conditions, 17 had serious but non-life-threatening conditions, and 11 had minor symptoms…....

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EPA RMP Citations @ Food Facility (NH3 & $152K)

Respondent operated a facility (the “Facility”) to process, store, and distribute prepackaged salads, fresh-cut vegetables, and other food products. At all times relevant to this CAFO, Respondent produced, used or stored more than 10,000 pounds of ammonia (anhydrous) at the Facility and was subject to the requirements of CAA § 112(r)(7). At all times relevant…...

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EPA RMP citations @ Agriculture Supply business (NH3 & $33K)

Respondent owns and operates a facility that wholesales animal feeds, fertilizers, agricultural chemicals, pesticides, seeds, and farm supplies, including agricultural anhydrous ammonia. On or about August 9, 2023, EPA inspected the 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…...

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EPA RMP citations @ water treatment plant (Cl2 & $13,500)

This is what drives me crazy! A water treatment plant that falls under EPA’s RMP and yet has made zero effort to comply with the standard gets 11 citations, and the fine was $13,500, which was “adjusted” down to $10,800. This is a PUBLIC entity handling Chlorine (Cl2) in a densely populated area (see Google…...

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EPA RMP GDC & EPCRA citations @ cheese manufacturing facility (NH3 & $178K)

The respondent was the owner or operator of the cheese production facility that used anhydrous ammonia in its refrigeration processes. Respondent was required to have a material safety data sheet for anhydrous ammonia under the Occupational Safety and Health Act of 1970, 29 U.S.C. § 651 et seq. , and its associated regulations. Respondent produced,…...

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6,000 pound NH3 release leads to $169K EPCRA/CERCLA citations

The respondent was an owner or operator of the ice manufacturing facility where anhydrous ammonia is used in the manufacturing of ice. Anhydrous ammonia, CAS #7664-41-7, has a reportable quantity of 100 pounds, as indicated in 40 C.F.R. Part 355, Appendix A. On July 27, 2023, at or about 4:34 a.m. CDT, a release of…...

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