PSM and RMP Citations/Analysis

Respondent is the owner and/or operator of a candy manufacturing facility, which 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: a. Respondent produces food products b. Respondent has on-site for storage, 18,000 pounds of anhydrous ammonia c. Respondent…...

It’s never a good sign when the EPA inspector is in the process and the operator’s personnel detector goes into alarm and the worried inspector is told… it was typical for the alarm to sound during sampling.  This led the inspector to inquire about this level of exposure for a repeated task such as sampling…...

Respondent operates a “stationary source” and has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the stationary source.  Respondent operates an ammonia refrigeration process that has on-site storage of 15,416 pounds of anhydrous ammonia.  On December 11, 2018, the EPA conducted an on-site inspection…...

Respondent owns and operates an adhesive and sealant manufacturing facility, which employs about 30 persons, is one of several plants that Respondent operates nationwide with about 45,000 employees worldwide. In the Facility’s manufacturing processes, the facility uses various highly flammable and/or toxic chemicals that are stored in outdoor tanks ranging in size from about 5,000…...

Respondent owned and operated the petroleum refining facility which produces, processes, stores, or handles more than the threshold quantities of flammable substances. Respondent’s hydrocracker unit (HCU) is a covered process under Program 3 of the RMP regulations. On April 10, 2020, there was an incident at the facility. One of the facility’s covered processes was…...

Respondent owns a wastewater treatment plant. Chlorine, propane, and sulfur dioxide (anhydrous) are each a ” regulated substance”, as set forth in 40 C.F.R. § 68.130. The Respondent has a wastewater chlorination process at the stationary source. The Respondent’s facility has propane in excess of the 10,000-pound threshold, however, such propane is not used in…...

Respondent’s facilities are located in Missouri. On or about March 30-April 1, 2010, EPA conducted an inspection of the Carthage, Missouri facility to determine compliance with 40 C.F.R. Part 68. On or about September 27-29, 2010, EPA conducted an inspection of the Louisiana, Missouri facility to determine compliance with 40 C.F.R. Part 68.  Information collected…...

Respondent is the owner and/or operator of operates a pulp bleaching mill. Respondent has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. Respondent has on-site 19,022 pounds of chlorine dioxide in one RMProgram level 3 covered process, which stores or otherwise uses…...

Respondent owns and operates a facility with the North American Industry Classification System (NAICS) code of 311230 Breakfast Cereal Manufacturing. The manufacturing facility produces cereal products and snack bars. A refrigeration system is used for the operation of chillers, compressors, and condensers that support manufacturing activities, including the cereal processing area. The refrigeration system uses…...

You have to be really special to get EPA’s Criminal Investigation Division involved in your RMP inspection – DONT BE SPECIAL! But once again we have a NH3 refrigeration facility just not “getting it”… The case was prosecuted by Assistant U.S. Attorney Terrence P. Donnelly, with the assistance of Dianne Chabot, EPA Regional Criminal Enforcement…...

The CAFO resolves alleged CAA violations that Complainant asserted occurred in conjunction with Respondent’s storage and handling of toluene diisocyanate, an extremely hazardous substance, at its former plant growth media manufacturing facility. Respondent reports that the Facility ceased operations on or about December 3, 2020. Respondent also reports that subsequently, all equipment, inventory, raw materials…...

Respondent is the owner and/or operator of a chemical and fertilizer distribution facility. The Facility has an anhydrous ammonia storage system and loading and unloading equipment that has at all relevant times contained more than 10,000 pounds of anhydrous ammonia and constitutes a single “covered process” under 40 C.F.R. § 68.3.  The Facility has an…...