PSM and RMP Citations/Analysis

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…...

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…...

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…....

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…...

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…...

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,…...

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…...

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?...

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…...

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…...

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…...

Respondent owns and operates a petrochemical facility which manufactures specialty chemicals in a variety of operating units. Respondent produces, processes, handles, or stores one or more regulated substances listed in 40 C.F.R. Part 68 above the threshold quantity. In April 2016, Respondent began work to replace a tube exchanger on the Petro I unit. The replacement…...