PSM and RMP Citations/Analysis

Respondent owns and operates a cellophane manufacturing facility that uses Carbon disulfide in excess of the 20,000 pounds RMP TQ. On or about September 11 and 12,2019, 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. From the time Respondent first had onsite…...

Oil and vapor releases into the air and fiery flares at a refinery in February and May led to an investigation that found the operator failed to meet federal workplace chemical safety standards and endangered workers.  OSHA cited the refinery for 20 violations of the Process Safety Management standard with $259,407 in proposed penalties. OSHA…...

Respondent owns and operates an ammonia refrigeration system at its meat processing facility which began operation in February 2019. The ammonia refrigeration system had an initial charge of 17,000 pounds of anhydrous ammonia when operations began, making the facility subject to requirements of Chemical Accident Prevention Provisions in accordance with 40 C.F.R. § 68.10(a) and…...

Respondent operates a petrochemical manufacturing process at the Facility, utilizing regulated substances to produce vinyl chloride monomer, meeting the definition of ” process”, as defined by 40 C.F.R. § 68.3. Sulfur dioxide, hydrogen chloride, vinyl chloride and propylene (collectively, “regulated substances”) are each a “regulated substance” pursuant to 40 C.F.R. § 68.3. EPA conducted an…...

Respondent is the owner and/or operator of a Brewery and has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility: Respondent operates an ammonia refrigeration plant. Respondent has on-site for use, 160,300 pounds of anhydrous ammonia. Respondent has one RMProgram…...

Respondent owned and operated a petroleum refinery with the Standard Industrial Classification (SIC) code 2911. The Facility produces, processes, stores, or handles more than the threshold quantities of flammable and toxic substances identified in 40 C.F.R. § 68.130. The regulated flammable substances that are held above the threshold quantities identified in 40 C.F.R. § 68.130…...

Respondent is the owner and operator of a facility that has five inorganic chemical manufacturing processes, meeting the definition of “process”, as defined by 40 C.F.R. § 68.3. Bromine, ammonia (anhydrous), chlorine, sulfur trioxide, propylene oxide, oleum (fuming sulfuric acid), and sulfur dioxide (anhydrous) are each a “regulated substance” pursuant to 40 C.F.R. § 68.3…....

An explosion and fire that killed a press operator and hospitalized eight other employees at a paint resins and coatings manufacturer could have been prevented had the employer not altered a kettle reactor vessel improperly and then returned the vessel to service after it failed following the alterations, a federal workplace safety inspection has found…....

Respondent is the operator of a chemical manufacturing and distribution facility that ses anhydrous ammonia to produce several chemicals, including ammonium sulfate (made by reacting ammonia with sulfuric acid) and aqueous ammonia (a solution of anhydrous ammonia and water). Anhydrous ammonia arrives by railcar and is distributed through pipes to chemical processes around the Facility…....

We don’t see these every day and to be honest, the incidents, the violations, and the compliance plan are too much for me to break down.  I have broken out the incidents and the citations that EPA issued for each of these incidents, but you will have to go to the CAFO to get the…...

Respondent owns and operates a facility that processes, stores, and distributes produce. On June 21, 2018, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Sections 304–12 of the Emergency Planning and Community Right-to-Know Act, and Section 103 of the Comprehensive Environmental Response, Compensation and Liability Act, 42 U.S.C. §…...

Respondent owns and operates a facility that processes and packages fruit and vegetable products. Between June 5 and June 7, 2018, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Sections 304–12 of the Emergency Planning and Community Right-to-Know Act, and Section 103 of the Comprehensive Environmental Response, Compensation, and…...