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 @ cold storage facility (NH3 & $10K w/ $26K SEP)

The U.S. Environmental Protection Agency, Region 10, has reached a settlement with a seafood cold storage facility in Unalaska, Alaska, for violations related to a 125-pound ammonia release on December 3, 2016 that seriously injured one of the facility’s workers. The facility’s failure to provide timely information about the ammonia release also put first responders at…...

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EPA RMP citations @ seafood processing plant (NH3 & $45K w/ $175K SEP)

Respondent owns a stationary source where anhydrous ammonia was present in a process above the 10,000 pound TQ from at least June 1, 2014. Therefore, Respondent was required to submit and have in place an RMP for the facility. Respondent submitted an RMP to EPA on April 9, 2015. Respondent has a Program 3 covered…...

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EPA RMP citations @ ammonia manufacturer (NH3, 11,000 pound release & $25K w/ $200K SEP)

Respondent is primarily engaged in the production of anhydrous ammonia, urea fertilizer, and urea ammonium nitrate, which includes two ammonia units (A1 and A2), a urea production unit, a UAN unit, and various ancillary units, including a carbon dioxide pipeline compressor station and a hydrogen recovery unit. Respondent produces, processes, stores, or handles more than…...

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EPA RMP citations @ ammonia manufacturer (NH3, 11,000 pound release & $25K w/ $200K SEP) Read More »

EPA RMP citations @ cold storage facility (NH3 & $95K)

Respondent is the owner and/or operator of a stationary source that uses, handles, and/or stores more than a threshold quantity of anhydrous ammonia, a regulated substance, as specified at 40 C.F.R. §§ 68.115 and 68.130.  EPA conducted an inspection of the Facility on December 12, 2016 and EPA observed alleged violations of 40 C.F.R. part 68…....

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EPA RMP Program 2 citations @ chemical manufacturer (NH3 & $55K)

On or about September 14, 2016, representatives of the EPA conducted an inspection (the 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’s Facility had greater than 10,000 pounds of anhydrous ammonia in a process. From the time…...

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EPA RMP citations @ seafood processing plant (NH3 & $19K)

EPA found that Respondent had violated regulations implementing Section 112(r) of the Act at 40 C.F.R. Part 68 by failing to comply with the regulations as noted below.  Four EPA representatives inspected the facility on August 13, 2014.  In consideration of Respondent’s size of business, its full compliance history, its good-faith effort to comply, and…...

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EPA RMP citations @ cold storage (NH3 & $23K)

Respondent operates a food distribution plant with 33,400 pounds of ammonia for cold food storage purposes and is a RMProgram level 3 covered ammonia refrigeration process.  On February 11, 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,…...

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EPA RMP citations @ CO2 plant (flammable mixture and NH3 & $?????

There appears to have been no monetary fine issued with this agreement; instead, it looks as if the facility has agreed to correct all the deficiencies by June 2018. Respondent uses, handles, and/or stores more than a threshold quantity of a flammable mixture and anhydrous ammonia, both regulated substances. The EPA conducted an inspection on…...

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OSHA issues PSM Citations @ Food Plant (NH3 & $114K)

One of OSHA “significant cases” in the month of August was a PSM case at a Frozen Specialty Food Manufacturing facility in KS.  Here is a breakdown of the citations:   NOTE: this case is PENDING ABATEMENT OF VIOLATIONS, PENDING PENALTY PAYMENT… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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EPA RMP citations @ chemical manufacturer (Formaldehyde & $9K)

On May 14, 2014, EPA conducted a compliance inspection of Respondent’s facility to determine its compliance with the Risk Management Program (“RMP”) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Act. EPA found that Respondent had violated regulations implementing Section 112(r) of the Act by failing to comply with the regulations as…...

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EPA RMP citations @ beef slaughter and packaging facility (NH3 & $15K w/ a $50K SEP)

Respondent owns and operates a beef slaughter and packaging facility and has Anhydrous Ammonia in excess of 10,000 pounds. On or about September 9, 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.  From the time Respondent first had onsite greater than…...

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EPA RMP citations @ beef slaughter and packaging facility (NH3 & $15K w/ a $50K SEP) Read More »

EPA RMP citations @ three (3) fluid milk production facilities (NH3 & $270K)

Respondent owns or operates three (3) fluid milk production facilities located in MI, IL, and MO (until operations ceased in 2014). At each of these facilities, Respondent operates or operated at all times relevant to this CAFO a closed-loop refrigeration system which utilizes or utilized anhydrous ammonia. Each system uses and stores, or used and…...

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