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.

Boston Seafood Distributor to Pay $700K for RMP GDC Violations

A seafood distribution company that formerly operated in Boston, Mass. will pay a cash penalty, subject to court approval, settling allegations by the U.S. EPA that the company violated federal environmental laws relating to the use of anhydrous ammonia, sulfuric acid, and lead at its facility. Under the settlement, the company has agreed to pay…...

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EPA RMP record citations @ refinery (Flammables & $2.95M civil, $150M in upgrades/repairs, w/ $10M SEP)

NOTE: The overall value of this settlement exceeds $160 million, which makes it the largest settlement in the history of the EPA’s enforcement of the Risk Management Plan Rule under Clean Air Act Section 112(r). This is also the first case in which the United States and a state have jointly brought suit to enforce…...

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EPA RMP record citations @ refinery (Flammables & $2.95M civil, $150M in upgrades/repairs, w/ $10M SEP) Read More »

EPA RMP GDC citations @ pet food manufacturing facility (NH3 & $89K, w/ $90K SEP)

Respondent operates a facility where it processes fish to produce ingredients used by pet food manufacturers. The Facility is located in a designated industrial area within approximately 300 feet (0.05 mile) of JFK Memorial Highway, less than 500 feet (0.09 mile) from the nearest residence, and approximately 600 feet (0.11 mile) from Buzzard’s Bay. At…...

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EPA RMP GDC citations @ pet food manufacturing facility (NH3 & $89K, w/ $90K SEP) Read More »

EPA RMP citations @ chemical facility (NH3 & $20K, w/ $76K SEP)

Respondent operates a chemical manufacturing which has 2,400,000 pounds of ammonia in onsite storage. Respondent has one RMProgram level 3 covered process. On August 16, 2017, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the compliance with the RMProgram requirements and the implemented recognized and…...

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EPA RMP citations @ chemical facility (NH3 & $20K, w/ $76K SEP) Read More »

EPA RMP citations @ food and cold storage facilities (NH3 & $70K)

Respondent owned and operated two food warehousing facilities. One is used for food manufacturing and refrigerated warehouse and storage and the other is used for refrigerated storage. Respondent, as owner/operator of the Facilities, has handled and/or stored anhydrous ammonia at an amount greater than the threshold quantity of 10,000 pounds in a process since at…...

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EPA RMP citations @ food and cold storage facilities (NH3 & $70K) Read More »

EPA RMP GDC release investigation @ refinery (Flammables and Toxics; improper flange/gasketing arrangement)

Respondent owned and operated a petroleum refinery and it’s RMP lists covered processes subject to Program 3 requirements, including the Ultracracker (ULC) unit which consists of three sixty-three-foot-tall pressure cylindrical reactors, each containing five individual catalyst beds. The hydrocracking reaction converts the larger hydrocarbon chains into smaller, more valuable hydrocarbons. On March 10, 2018, operators…...

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EPA RMP GDC release investigation @ refinery (Flammables and Toxics; improper flange/gasketing arrangement) Read More »

EPA RMP GDC @ chemical facility (Xylene Release due to overfilling RX & $31K)

The facility uses xylene as a cleaning agent to clean the reactors. Xylene is an extremely hazardous flammable substance, and is stored at the facility. On August 14, 2017, at 11:24am, an operator was cleaning the RX-2 reactor with xylene between tolling processes. The operator overfilled the reactor with xylene, leaving the reactor without a vapor space…....

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EPA RMP GDC @ chemical facility (Xylene Release due to overfilling RX & $31K) Read More »

EPA Region 6 RMP Inspection (hydrazine, methyl‐hydrazine, and 1, 1‐Dimethylhydrazine)

EPA Region 6 inspector arrived on May 1, 2018, for an announced inspection with an inspector from the Louisiana Department of Environmental Quality (LDEQ). The scope of the inspection was a partial compliance evaluation (PCE) and included an evaluation of the compliance of the facility. On April 18, 2018, the facility received an announcement email…...

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EPA Region 6 RMP Inspection (hydrazine, methyl‐hydrazine, and 1, 1‐Dimethylhydrazine) Read More »

EPA Region 6 RMP Inspection Report (Chlorine Process)

Environmental Protection Agency (EPA) Region 6 Inspector (1) and Louisiana Department of Environmental Quality (LDEQ) Inspectors (3) arrived at the facility on May 1, 2018, for an announced inspection. On April 19, 2018, the facility received an announcement email, which outlined the directions for conducting an on-site inspection, as well as a list of documents…...

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EPA RMP Inspection prior to Start-Up and RMP Applicability

I came across this EPA Region 6 RMP inspection report while doing some research for a client and this is an amazing insight into the difficulties and details of implementing a Process Safety Management System. I always take out names and company names when I post inspection reports, as it is NEVER about the company,…...

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EPA RMP citations @ food facility (NH3 & $34K)

This inspection appears to have begun as an RMP GDC, but when the facility submitted an RMP after the first inspection, they stated the process was a Program 3, and thus it appears EPA paid them another visit.  On both visits, EPA seems to have found items of concern. Respondent is the owner and/or operator of…...

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OSHA PSM citations @ refinery (Explosion, Flammables & $83K)

OSHA has cited a refinery for failing to control the use and release of highly hazardous chemicals after an explosion and fire injured several employees. The company faces $83,150 in proposed penalties.  Here is a break down of the citations:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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