PSM and RMP Citations/Analysis

Respondent owned, leased, operated, controlled or supervised a facility for ethanol fuel production. Respondent conducted activity involving anhydrous ammonia at the Facility, including using, storing, handling or moving on-site anhydrous ammonia ( anhydrous ammonia process). Respondent conducted activity involving a flammable mixture that included natural gas condensates (flammable mixture) at the Facility, including using, storing,…...

Respondent is the owner or operator of an egg production facility which employs a refrigeration process using anhydrous ammonia in its egg production system. Pursuant to Section 112(r)(1) of the CAA, also known as the General Duty Clause, the owners and operators of stationary sources producing, processing, handling or storing substances listed pursuant to Section…...

This case is being posted, even though the citation was under $10,000 because it is a GDC case and involved improper storage of materials that would react to create an extremely hazardous substance.  EPA used both NFPA 30, 2015 and the IFC, 2015; as well as NFPA 704 in their assessment.  The respondent has owned…...

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;…...