PSM and RMP Citations/Analysis

The respondent was the owner or operator of a 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 and its associated regulations. Respondent produced, processed, handled, or stored a regulated substance…...

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,…...

Respondent operated a facility that manufactures ammonium phosphate fertilizers and sulphuric acid. EPA conducted an on-site investigation of Respondent’s operations at the Facility pursuant to CAA Section 112(r), EPCRA Sections 304-12, and CERCLA Section 103 on January 30, 2020 (the “Inspection”). Respondent has informed EPA that the Facility no longer has any ammonia onsite as…...

The respondent owns and operates a single-site aerosol can manufacturing facility that uses, stores, and handles Isobutane (CAS# 85-28-5), a regulated substance, at the Facility in amounts over the threshold quantity for Isobutane of 10,000 lbs. The facility used, stored, and handled Butane (CAS# 106-97-8), a regulated substance, at the Facility in amounts over the…...

Respondent was the “owner or operator” of the Facility. The Facility’s refrigeration system used approximately 5,913 pounds of anhydrous ammonia. Accordingly, at the time of the violations alleged herein, Respondent operated a stationary source that handled and stored anhydrous ammonia, listed at 40 C.F.R. § 68.130, and thus was subject to the General Duty Clause…...

Respondent is the owner and operator of a facility where EPA inspected from May 17 to May 19, 2022, to determine Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68 (“the Inspection”).  The Respondent’s facility is a metal alkyl manufacturing facility.  The facility produces a variety of highly reactive metal alkyls…...

Respondent owns or operates the AMPI production facility that uses anhydrous ammonia in its refrigeration processes. From December 20, 2021, to May 17, 2022, EPA conducted an offsite compliance monitoring investigation of the Facility. During that investigation, the EPA representatives identified alleged violations of section 112(r)(1) of the CAA and section 312 of the EPCRA…....

Respondent is the owner and operator of a facility that has more than 10,000 pounds of anhydrous ammonia and Hydrogen in processes. Information gathered during the EPA inspection revealed that Respondent uses anhydrous ammonia in the production of food ingredients and produces and stores hydrogen, and therefore, is engaged in a process at its facility…....

This case is interesting, as I have always challenged the concept that an engine room (membership required)with large roll-up utility doors and windows and personnel/fire doors that are found propped open more often than not would contain the “catastrophic release of NH3”.  It seems this EPA inspector was one who attended one of my 5-Day…...

This case is interesting, as I have always challenged the concept that an engine room (membership required)with large roll-up utility doors and windows and personnel/fire doors that are found propped open more often than not would contain the “catastrophic release of NH3”.  It seems this EPA inspector was one who attended one of my 5-Day…...