PSM and RMP Citations/Analysis

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…...

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…....

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…...

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…...

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,…...

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…...

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?...

Respondent operates a facility where it processes fish to produce ingredients used by pet food manufacturers (the “Facility”). 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…...

Respondent owned and operated two food warehousing facilities. One is used for food manufacturing and refrigerated warehouse and storage. The other is used for refrigerated storage. On January 26, 20 17, EPA conducted a compliance inspection at the food manufacturing facility, as well as a records review of the risk management plan (submitted to EPA…...

Respondent is the owner and operator of the facility where anhydrous ammonia is a “regulated substance” pursuant to 40 C.F.R. § 68.3. On or about November 15, 2017, EPA conducted an inspection of Respondent’s Facility to determine compliance with 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had greater than…...

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, which is a regulated substance, listed under 40 C.F.R. § 68.130. Respondent meets the Program 3 eligibility requirements under 40 C.F.R. § 68.10. On December 12, 2016, EPA conducted an inspection…...

Respondent is a Plant Food Company and is an owner or operator of vessels containing anhydrous ammonia located at the Facility. The vessels are a “stationary source” pursuant to 40 C.F.R. § 68.3. On or about March 1, 2017, EPA conducted an inspection of the Facility to determine compliance with Section 112(r) of the CAA…...