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 @ power plant (NH3 (Anhydrous and Aqueous) & $13K)

I usually do not post such small cases, but this 540-megawatt electrical generation facility is sort of unique as it uses 87,840 pounds of anhydrous ammonia in a closed refrigeration system used to cool gas turbine inlet air and increase power output. It also uses 44,840 pounds of aqueous ammonia to reduce NOx emissions by…...

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EPA RMP citations @ power plant (NH3 (Anhydrous and Aqueous) & $13K) Read More »

EPA RMP citations @ refinery (NH3 and Flammables & $191K after a release during SD)

Respondent is the owner and operator of the petroleum refinery. Respondent has filed RMPs with EPA since June 21, 1999, with its most recent filings on April 22, 2015, April 23, 2020, and September 2, 2020. The Facility has 14 Program 3 covered processes at the Facility. Each of these 14 covered processes has greater…...

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EPA RMP citations @ refinery (NH3 and Flammables & $191K after a release during SD) Read More »

EPA RMP citations @ Nitrogen manufacturer (NH3 and NH4NO3 & $1.5M after 2 NH3 releases)

EPA has reached an agreement with a Nitrogen manufacturer to resolve federal civil environmental violations of the Clean Air Act’s chemical accident prevention measures and of federal laws requiring timely notification of chemical accidents. EPA identified these violations following an anhydrous ammonia release that led to thirteen workers being injured at the facility in Arizona…....

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EPA RMP citations @ Nitrogen manufacturer (NH3 and NH4NO3 & $1.5M after 2 NH3 releases) Read More »

EPA RMP citations @ chemical facility (EtO & $38K after vessel failure and release))

At the Facility, Respondent produces, processes, stores, or handles more than 10,000 pounds of ethylene oxide. On November 3, 2019, the Glycol 2 Production Unit experienced a release of ethylene oxide.  Respondent’s Glycol 2 Production Unit experienced an ethylene oxide release involving the knockout pot D-410 of the Ethylene Oxide Scrubber Process. In response to…...

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EPA RMP citations @ chemical facility (EtO & $38K after vessel failure and release)) Read More »

EPA RMP citations @ pesticides facility (Cl2 & $77K after leak)

Respondent operated a facility to store and distribute pesticides, fertilizers, and industrial chemicals, including chlorine. At all times relevant to this CAFO, the facility produced, used or stored more than 10,000 pounds of chlorine and was subject to the requirements of CAA § 112(r)(7). The process was subject to Program 3 requirements because it was…...

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EPA RMP citations @ pesticides facility (Cl2 & $77K after leak) Read More »

EPA RMP citations @ petrochem facility (Flammables & $33K after pipe failure (CUI) led to an LOPC event)

Respondent is the owner and operator of a facility where on October 13, 2019, there was an incident at the Facility that resulted in an accidental release. On April 4, 2020, the EPA requested, and Respondent provided, documentation and information concerning the Incident and Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R…....

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EPA RMP citations @ petrochem facility (Flammables & $33K after pipe failure (CUI) led to an LOPC event) Read More »

EPA RMP citations @ food facility (NH3 & $103K)

Respondent is a Gourmet Pasta Company that uses anhydrous ammonia in two refrigeration “processes,” as defined by 40 C.F.R. § 68.3, in two separate systems of pipes and vessels at the Facility (the “Processes”). On October 12, 2016, Respondent conducted a Process Hazard Analysis (“PHA”) for the Facility. On March 30, 2017, Respondent filed an…...

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EPA RMP citations @ food facility (NH3 & $103K) Read More »

EPA RMP citations @ chemical manufacturer (Cl2 & $62K)

Respondent is the owner and/or operator of a facility that uses chlorine in its chemical manufacturing process. EPA conducted an inspection of the Facility on November 29, 2017, to assess compliance with Section 112(r)(7) of the CAA (the “Inspection”) and the regulations at 40 C.F.R. Part 68. Respondent filed an RMP for the Facility with…...

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EPA RMP citations @ chemical manufacturer (Cl2 & $62K) Read More »

EPA RMP citations @ Anhydrous Ammonia storage and refrigeration process (NH3 & $244K)

Respondent stores and uses ammonia at the facility in parts of the storage and refrigeration process. Respondent’s storage and refrigeration process contains more than the threshold quantity (10,000 pounds) of ammonia. Respondent’s storage and refrigeration process does not meet the eligibility requirements for Program 1 under 40 C.F.R. § 68.10(b) and is subject to the…...

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EPA RMP citations @ Anhydrous Ammonia storage and refrigeration process (NH3 & $244K) Read More »

EPA RMP citations @ food facility (NH3 & $85K – COVID19 penalty reduction)

SPECIAL NOTE:  This is the first time I have seen a penalty reduction from the COVID-19 impacts on the business. Respondent operates an ammonia refrigeration process with 15,416 pounds of anhydrous ammonia. The Respondent has one RMProgram level 3 covered process, which stores or otherwise uses a toxic substance in an amount exceeding its applicable…...

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EPA RMP citations @ food facility (NH3 & $85K – COVID19 penalty reduction) Read More »

EPA RMP citations @ fertilizer distributor (NH3 & $20K)

Respondent owns and operates an agricultural storage, feed, and supply business. On or about August 13, 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. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of anhydrous ammonia…...

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EPA RMP citations @ fertilizer distributor (NH3 & $20K) Read More »

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