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/EPCRA Citations @ seven different refrigeration processes in 4 states (NH3 & $580K w/ $750K improvements)

EPA announced seven settlements with companies in four New England states for alleged violations of chemical accident prevention and reporting laws. All the cases address the safe use of anhydrous ammonia in refrigeration and cooling units. Collectively, the seven companies have spent more than $750,000 to comply with the laws and will pay more than […]

EPA RMP citations @ chemical facility (VA & $14K)

EPA has determined that Respondent violated the Risk Management Program (RMP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Clean Air Act (CAA), as noted on the enclosed Risk Management Plan Inspection Findings and Alleged Violations Summary (“Summary”), which is hereby incorporated by reference. In consideration of the penalty assessment factors

EPA RMP GDC citations @ pet food manufacturing facility (NH3 & $89K, w/ $90K SEP)

Respondent operates a facility where it processes fish to produce ingredients used by pet food manufacturers. 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 Bay. At

EPA RMP citations @ chemical facility (NH3 & $20K, w/ $76K SEP)

Respondent operates a chemical manufacturing which has 2,400,000 pounds of ammonia in onsite storage. Respondent has one RMProgram level 3 covered process. On August 16, 2017, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the compliance with the RMProgram requirements and the implemented recognized and

EPA RMP citations @ food and cold storage facilities (NH3 & $70K)

Respondent owned and operated two food warehousing facilities. One is used for food manufacturing and refrigerated warehouse and storage and the other is used for refrigerated storage. Respondent, as owner/operator of the Facilities, has handled and/or stored anhydrous ammonia at an amount greater than the threshold quantity of 10,000 pounds in a process since at

EPA RMP GDC release investigation @ refinery (Flammables and Toxics; improper flange/gasketing arrangement)

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

EPA RMP GDC @ chemical facility (Xylene Release due to overfilling RX & $31K)

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 RMP Inspection (hydrazine, methyl‐hydrazine, and 1, 1‐Dimethylhydrazine)

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

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