PSM and RMP Citations/Analysis

Respondent owns and operates an agricultural chemical manufacturing facility. On November 2, 2017, Respondent had an accidental release of chlorine at the Facility. Respondent determined the amount of chlorine released to be 0.014 pounds and reported that the release occurred when hooking up a rail car containing chlorine in which an unloading valve was inadvertently…...

PLEASE NOTE this entire inspection citation is based on the facility not having their piping labeled per ASME A13.1 – A13.1-2015, Scheme for the Identification of Piping Systems Respondent is the owner of a polymer manufacturing plant and based on the observations of EPA inspectors during the Inspection, EPA has determined that Respondent has handled…...

Respondent is a cooperative with two (2) facilities that store ammonia. On June 26th and September 6, 2012, EPA conducted inspections of the facilities to determine the Respondent’s compliance with the Risk Management Program 2 Prevention Program requirements. The inspections confirmed that the facilities had more than a threshold amount of anhydrous ammonia. Facility #1…...

On or about September 18, 2018, 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 in a process at its facility. From the time Respondent first…...

Respondent owns and operates the chemical manufacturing and distribution facility. Anhydrous ammonia is a “regulated substance” pursuant to 40 C.F.R. § 68.3 with a threshold quantity, as listed in 40 C.F.R. § 68.130, of 10,000 pounds. Ammonia in the concentration of greater than 20% is a “regulated substance” pursuant to 40 C.F.R. § 68.3 with…...

I am not sure how much of the $4 million was for RMP, as there were other issues in this Consent Decree and I have only pulled out the RMP issues. On or about September 4, 2017, heater tube 23 ruptured in the CRU2/HTU2 charge heater process due to creep, a molecular failure mechanism that…...

OSHA has cited a texas chemical company for exposing employees to workplace safety and health hazards after a fire and explosion at the plant in November 2019. The company faces $514,692 in fines. OSHA opened an investigation after vapor formed at the base of a butadiene finishing tower ignited and caused several explosions and fires…....

Respondent owns and operates an agricultural storage and supply facility where on August 16, 2016, an accidental release of anhydrous ammonia occurred when filling a storage tank. The release resulted in the hospitalization of an employee. On or about March 12, 2019, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance…...

Respondent owns and operates an agricultural feed, fertilizer, chemical, and grain storage and supply business with two different facilities in Iowa. On March 7, 2016, an accidental release of anhydrous ammonia occurred at one Facility while an employee was replacing a pump near a supply vessel and resulted in injuries to the employee. On or…...

A gas distributor and its parent company have agreed to pay $257,000 to settle RMP violations discovered during inspections following a fatal 2013 explosion at a Texas facility.  On the morning of February 9, 2013, at the La Porte #1 facility, there were explosions and a fire. The Incident occurred in the Gravimetric Unit (“Unit”)…...

NOTE:  I have always said city/county governments get huge breaks in $’s when it comes to RMP citations.  A private company who performed this poorly in an inspection would have gotten 10X’s the citation $’s. On November 9, 2016, an authorized EPA representative conducted a compliance inspection of the Water Treatment Plant (“Facility”) to determine…...

At its stationary source, the Respondent operates a Polystrene Foam Production facility using butane and has 132,235 pounds of butane in onsite storage. At its stationary source, the Respondent has one RMProgram level 3 covered process, which processes butane in an amount exceeding its applicable threshold of 10,000 pounds. On August 30, 2018, the EPA…...