PSM and RMP Citations/Analysis

Respondent owned and operated a primary metal products manufacturing facility that produces annually over 300,000 tons of powdered metal which is used in the production of automotive parts. Hydrogen is handled in the production of powdered metal, and hydrogen is a regulated flammable substance listed under 40 C.F.R. § 68.130. The Facility receives scrap iron…...

Respondent owns and operates the egg production facility which utilizes anhydrous ammonia in a refrigeration process. On or about August 1-2, 2017, EPA conducted an inspection to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68 (EPA inspection). Information gathered during the EPA inspection revealed that Respondent had greater than 10,000…...

NOTE: this case has some very interesting citations and used RAGAGEPs that may not be the best fit, but when a facility does not adopt a RAGAGEP, EPA (and OSHA) will be more than happy to “suggest” one in their citations! Respondent is the owner and/or operator of a natural gas processing facility. The Facility…...

The Facility is a “stationary source” that processed, handled, and stored isopropyl alcohol. Isopropanol (isopropyl alcohol, CAS #67-63-0) is a highly flammable liquid and extremely hazardous substance. On or about April 13, 2017 there was a fire at the Facility resulting in an accidental release.  Between May and July 2017, EPA requested and the business provided…...

Respondent is the owner and operator of a Facility that utilizes approximately 32,000 pounds of anhydrous ammonia in its refrigeration system at the Facility. Respondent uses anhydrous ammonia in a series of interconnected pipes and vessels in a refrigeration system at the Facility (the “Process”). On June 26, 2017, EPA conducted an inspection of the…...

Respondent is the owner and operator of a food storage and distribution facility which includes refrigerated process areas and storage areas with a refrigeration system that uses anhydrous ammonia with a capacity of 14,722 pounds. Respondent uses anhydrous ammonia in a refrigeration “process,” as defined by 40 C.F.R. § 68 .3. in a typical vapor…...

Respondent is food company which owns and operates buildings, structures, installations, equipment, pipes or pipelines, and storage containers, located on a single site or on contiguous or adjacent sites, where it deposited, stored, disposed of, or placed, Ammonia CAS# 7664-41-7. Between June 21 and July 19, 2013, Respondent spilled, leaked, emitted, discharged, or allowed to…...

Respondent operates a specialty chemical manufacturing facility that includes an aboveground storage tank, tanker truck, tanker car, tote and drum chemical storage areas. At its stationary source, the Respondent has 500,000 pounds of carbon disulfide in onsite storage and Respondent has one RMProgram level 3 covered process, which stores or otherwise uses carbon disulfide in…...

Respondent is food facility that produces frozen French fries and other potato products.  It operates two (2) ammonia-based refrigeration systems at its facility.  Both E1 and E2 contain refrigeration systems which use anhydrous ammonia as a coolant.  On March 17, 2010, Respondent filed a program 3 RMP for the Facility (the “2010 RMP”), and updated…...

Respondent is a municipality which owns and operates a Water Treatment Plant. On or about May 16-17, 2016, EPA inspected the Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68.  From the time Respondent first had on site greater than 2,500 pounds of Chlorine in a process, Respondent…...

At 8:45 a.m. on June 8, 2017, a contractor was painting some pipes when a scissor lift struck and ruptured a pipe, releasing anhydrous ammonia gas/vapor. The contractors suffered respiratory trauma as well as received several burns. One contractor was hospitalized…. Membership Required You must be a member to access this content.View Membership LevelsAlready a...

The EPA and the DOJ have entered into a Stipulation of Settlement with insecticide manufacturer to address alleged chemical accident prevention violations at its former facility. The company will pay a $3.1 million civil penalty.  On November 15, 2014, an incident occurred, and nearly 24,000 pounds of methyl mercaptan (MeSH) were released within the insecticide unit. …...