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.

EPA RMP citations @ WWTP (Cl2 & $10K w/ $64K SEPs)

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…...

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EPA RMP citations @ WWTP (Cl2 & $10K w/ $64K SEPs) Read More »

EPA RMP citations @ dairy (NH3 & $86)

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…...

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EPA RMP Program 2 citations @ fertilizer facility (NH3 & $51K)

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…...

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OSHA PSM citations @ polysilicon facility (H2 Compressor Explosion & $25K)

A hydrogen compressor explosion led to some injuries and a TOSHA inspection, resulting in some PSM citations…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA PSM citations @ polysilicon facility (H2 Compressor Explosion & $25K) Read More »

EPA RMP & GDC citations @ chemical manufacturing facility (Cl2 & H2 & Action Plan)

Respondent has owned and operated a chemical manufacturing facility since at least January 2013. The facility manufactures chlorine, sodium hydroxide, solid sodium hydroxide, hydrochloric acid and calcium hypochlorite. The Facility is primarily a manufacturer of chlorine, which is produced through the electrolysis of a sodium chloride being derived from a salt vein deep under the…...

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EPA RMP & GDC citations @ chemical manufacturing facility (Cl2 & H2 & Action Plan) Read More »

EPA RMP & EPCRA citations @ cold storage facilities (NH3 & $329K for RMP and $90K for EPCRA)

Respondent is the owner and/or operator of five (5) cold storage facilities. Two of the facilities are both in the same industrial group, are located across a road from each other and are therefore located on one or more contiguous properties. Both are under the control of Respondent and are buildings that contain equipment that…...

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EPA RMP & EPCRA citations @ cold storage facilities (NH3 & $329K for RMP and $90K for EPCRA) Read More »

EPA RMP citations @ agricultural chemical manufacturing facility (CH4S, C3H9N, C2H7N, NH3 & $72K )

Respondent owns and operates an agricultural chemical manufacturing facility. On or about August 18-19, 2015, EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of methyl mercaptan in a…...

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EPA RMP citations @ agricultural chemical manufacturing facility (CH4S, C3H9N, C2H7N, NH3 & $72K ) Read More »

EPA RMP citations @ fertilizer distributor (NH3 & $137K)

Respondent Ag’s facility includes bulk ammonia storage operations. On or about September 11, 2013, EPA inspected the facility to determine compliance with Section 112(r) of the CAA, 42 U.S.C. § 7412(r), and 40 C.F.R. Part 68. At the time of the September 2013 inspection, Respondent had greater than 10,000 pounds of anhydrous ammonia stored in…...

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EPA RMP citations @ fertilizer distributor (NH3 & $137K) Read More »

EPA RMP citations @ winery (NH3, with 284 pound release; $330K)

On September 11, 2012, a Facility experienced a 284-pound release of anhydrous ammonia from its ammonia refrigeration system. The incident occurred when a worker attempted to defrost an ammonia chiller and opened the oil valve instead of the hot gas valve, causing ammonia to release into the environment. As a result of the release, an…...

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EPA RMP citations @ winery (NH3, with 284 pound release; $330K) Read More »

EPA RMP citations @ dairy (NH3, with 1,290 pound release; $22K for the release; $135K for RMP)

The Respondent owns a milk production facility and according to the U.S. Census data from 2010, several thousand people live near the Facility. The Facility has been in use as a dairy since 1886, and at the time of EPA’s inspection, included a milk production site, office space, chemical storage, warehousing, and production areas. The Facility…...

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EPA RMP citations @ dairy (NH3, with 1,290 pound release; $22K for the release; $135K for RMP) Read More »

EPA RMP citations @ agricultural chemical manufacturing facility (CH4S, C3H9N, C2H7N, NH3 & $71K)

From the time Respondent first had on site greater than 10,000 pounds of methyl mercaptan, isopropylamine, and/or dimethylamine in a process, and/or greater than 20,000 pounds of aqueous ammonia in a process, Respondent was subject to the requirements of 40 C.F.R. Part 68 because it was an owner and operator of a stationary source that…...

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EPA RMP citations @ agricultural chemical manufacturing facility (CH4S, C3H9N, C2H7N, NH3 & $71K) Read More »

EPA RMP citations @ meat processing facilities (NH3 & $0 w/ EPA Work Plan)

Respondent owns and operates meat processing facilities located in Pennsylvania. As stated in Respondent’s RMP for each of the PA Facilities, Respondent has anhydrous ammonia in the following approximate quantities: 88,000 pounds at the Wyalusing Facility; 20,500 pounds at the Hazleton Facility. On June 27, 2017, EPA conducted an inspection of the Wyalusing Facility to…...

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