PSM and RMP Citations/Analysis

Respondent owned and operated a Natural Gas Processing facility, which produces, processes, stores, or handles more than 10,000 pounds of a flammable mixture, including pentane, isobutate, isopentane, butane, propane, and ethane in the form of natural gas, natmal gas liquids, condensate, and/or crude oil.  Pentane, isobutate, isopentane, butane, propane, and ethane are identified at 40…...

One of the things I find extremely unfair with EPA citations is that they are based on “revenue” of the business, as well as other factors.  I like it when it is applied to a “for-profit” business, but it is disproportionately UNFAIR when it is applied to a public utility like a water treatment plant. …...

The Company owns and operates a fruit processing plant and controlled temperature storage warehouse, near a mixed business-residential area approximately one half mile northeast of a college campus and approximately one-half mile east of a downtown area.  The facility uses anhydrous ammonia in a “closed-loop” refrigeration system. According to the Respondent, as of February 2,…...

Respondent owns and operates a food service distribution facility that handles approximately 12,000 pounds of anhydrous ammonia at the Facility.  EPA conducted an inspection of the Facility on October 18, 2017 (“Inspection”) to determine Respondent’s compliance with CAA Section 112(r)(7) and the Chemical Accident Prevention Provisions at 40 C.F.R. Part 68.  Respondent submitted an initial…...

Respondent operates a cold food storage facility and has on-site for use, 14,000 pounds of anhydrous ammonia for cold food storage purposes. The respondent’s process is an RMProgram level 3 covered process. On March 29, 2017, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the…...

Respondent operates an ammonia refrigerant facility with 19,000 pounds of ammonia for food refrigeration purposes. The process is an RMProgram level 3 covered process. On March 24, 2016, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the…...

On or about August 22-23, 2017, EPA conducted an inspection (the inspection) of the Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information collected as a result of the inspection revealed that Respondent failed to implement the risk management program at the Facility.  The following substances are a…...

Respondent is the owner and operator of a pork harvesting, processing, and packaging facility which utilizes 250,000 pounds of anhydrous ammonia in its refrigeration system.  On April 20, 2016, EPA inspected the Facility in order to determine the Facility’s compliance with the Chemical Accident Prevention Provisions of 40 C.F.R. Part 68.  Based upon the information…...

SAFTENG NOTE:  This is the first time I have come across a citation from either OSHA or EPA where they took issue with the Ammonia Flammability Limits as depicted on the NFPA 704 Diamond located on the engine/machinery room door.  The facility had not updated their label to show NH3 as an F=3 for indoors;…...

Respondent is a municipality in the state of Nebraska, which owns and operates a Water Treatment Plant.   Information gathered during the EPA inspection revealed that Respondent had greater than 2,500 pounds of chlorine in a process at its facility.  From the time Respondent first had on site greater than 2,500 pounds of chlorine in a…...

Respondent operates a dairy plant and has on-site, 13,000 pounds of anhydrous ammonia which is used in its ammonia refrigeration process.  Respondent submitted a single RMPlan that included an accidental release prevention program, to the EPA for its stationary source.  At its stationary source, the Respondent has one RMProgram level 3 covered process.  On January…...

Respondent operates ammonia storage and transfer process which contains 840,000 pounds of anhydrous ammonia for storage and transfer. Respondent has one RMProgram level 2 covered process.  On March 3, 2016, the EPA conducted an onsite inspection of the RMProgram related records and equipment to assess the Respondent’s compliance with the RMProgram requirements and the implemented…...