PSM and RMP Citations/Analysis

Respondent owns and operates a poultry processing facility which handles and stores approximately 49,000 pounds of anhydrous ammonia in its ammonia refrigeration system. EPA conducted an inspection of the Facility on March 31, 2014 to determine Respondent’s compliance with CAA Section 112(r)(7) and the Chemical Accident Prevention Provisions at 40 C.F.R. Part 68. The Chemical…...

Respondent operates a breakfast food production facility that uses ammonia as its refrigerant and has on-site for use, 15,000 pounds of ammonia. Respondent has one RMProgram level 3 covered process, an ammonia refrigeration process. On May 20, 2014, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of…...

Respondent owns and operates a Refinery and on August 26-28, 2014 EPA Region 6 conducted an unannounced, onsite CAA 40 C.F.R. Part 68 and Section 112(r) Partial Compliance Evaluation of the Facility. The facility’s Risk Management Plan (RMP) lists covered processes subject to Program 3 requirements with flammable substances that are held above the threshold quantities identified…...

Respondent is the “owner or operator” of a plastics and resins manufacturing facility. On May 15, 2014, EPA inspectors visited the Facility to assess Respondent’s compliance with Section 112(r) of the CAA and with Sections 302-312 of the Emergency Planning and Community Right-to-Know Act (“EPCRA”). Respondent uses vinyl acetate monomer in one or more “processes”…...

Respondent operates a river barge terminal, which stores anhydrous ammonia and blends fertilizers for sale to farmers and cooperatives (NAICS code: 42459; Other Farm Product Raw Material Merchant Wholesaler). Anhydrous ammonia is received via barge and rail, stored, and distributed for both direct application and for blending into mixed-grade fertilizers for crop production nutrients. Approximately,…...

Respondent operates a chemical manufacturing plant which has more than 2,500 pounds of chlorine in a process, making the process a RMProgram level 3 covered chemical manufacturing process, which stores or otherwise uses chlorine in an amount exceeding its applicable threshold of2,500 pounds. On November 10, 2015, the EPA conducted an onsite inspection of the…...

This is another incident involving hot-gas defrost and liquid hammering effect causing a large diameter pipe to fail and releasing 183 pounds of NH3. This failure actually occurred inside the building (vs the 2010 Mobile, AL hammering release occurred on the roof of the building) and had far-reaching and serious consequences. Respondent owns and operates…...

Respondent produces meat and protein products for sale by third-party customers. As part of this process, Respondent uses anhydrous ammonia in a chill tank to prepare and preserve the products. Ammonia is a regulated substance listed in Table 1 to 40 CFR § 68.130. On the evening of January 15, 2016, after the Facility had…...

Respondent’s facility contains a process that produces ethylene, propylene, benzene, butadiene, and toluene. Respondent’s facility has toxic and flammable regulated substances in a process in excess of the threshold quantities listed in 40 C.F.R. § 68.130. An EPA inspector conducted an inspection of Respondent’s facility on November 18-20, 2014. Following the inspection and a review…...

Respondent owned and operated a chemical manufacturing facility that manufactures nitrogenous fertilizer. The facility processes natural gas to produce anhydrous ammonia. Anhydrous ammonia is the only regulated substance present at the facility and is used in the following processes or areas of the process: ammonia manufacturing, ammonia storage and loading, nitric acid (56%) manufacturing, nitdc…...

Respondent owned and operated an oil refinery which operates a variety of processes to produce petroleum products (e.g., propane, butane, gasoline, diesel, jet fuel, furnace oil, etc.) from raw crude oil. On August 11-14, 2014, EPA conducted an inspection of the Facility focused on compliance with CAA§ 112(r) and 40 C.F.R. Part 68. The regulated…...

Respondent’s facility is a poultry processing facility and uses 145,000 pounds of ammonia (anhydrous) as part of its covered process. On March 26, 2016, at approximately 8:05.p.m., the refrigeration staff received an odor complaint. Upon inspection, they discovered a pressure release valve (PRV) released prematurely on the marination tanks located on the roof. The staff…...