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 issues RMP GDC citations @ a Program 2 plant growth media manufacturing facility (TDI & $137K)

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 […]

EPA issues RMP citation @ a Program 2 Ammonia Fertilizer facility (NH3 & $146K)

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

EPA RMP citations @ speciality chemical plant (C3H6O, NH3, C6H13N & $27K)

Respondent is the owner and/or operator of the Facility and has developed an RMProgram accidental release prevention program for the Facility. On July 23, 2019 – July 25, 2019, the EPA conducted an on-site inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and

EPA RMP citations @ wastewater treatment plant (Cl2 & SO2 & $80K)

The Respondent operates a wastewater treatment plant where Chlorine, propane, and sulfur dioxide (anhydrous) are present above their thresholds. The Respondent operates a wastewater chlorination process at the stationary source. 40 C.F.R. § 68.130 specifies a 2,500-pound threshold for chlorine, a 10,000-pound threshold for propane, and a 5,000-pound threshold for sulfur dioxide (anhydrous). The Respondent’s

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.

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

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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