PSM and RMP Citations/Analysis

NOTE: I have posted this inspection because of the level of detail the inspectors went.  There has been a significant shift in the quality of findings from BOTH OSHA and EPA in their process safety inspections.  This EPA inspection team was well aware that the IIAR Bulletins are being phased out and replaced with ANSI/IIAR…...

Respondent operates an ammonia refrigeration system which uses 30,345 pounds anhydrous ammonia (ammonia). Respondent has one RMProgram level 3 covered process, which stores or otherwise uses an extremely hazardous substance in an amount exceeding its applicable threshold of 10,000 pounds. On December 21, 2017, the EPA conducted an onsite inspection of the RMProgram related records…...

Respondent is the owner and/or operator of a meat processing facility that uses, handles, and/or stores more than a threshold quantity of anhydrous ammonia. Respondent is required to prepare and implement an RMP to detect and prevent or minimize accidental releases of such substances under section 112(r)(7) of the CAA. Respondent meets the Program 3…...

Section 304(a) of EPCRA and the regulations found at 40 C.F.R. Part 355, Subpart C, require the owner or operator of a facility at which a hazardous chemical is produced, used or stored, to immediately provide notice to the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) as described in Section…...

On August 18, 2018, the EPA issued to Respondent a Notice of Potential Violation (“NOPV”), providing notice that the EPA found that Respondent had potentially committed the alleged violations described in Section V of this Agreement and providing Respondent an opportunity to confer with the EPA. On February 14, 2019, representatives of Respondent and the…...

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…....