PSM and RMP Citations/Analysis

Lack of emergency planning for ammonia leaks put workers at a beverage plant in harm’s way three (3) times in the past year. As a result, the Department of Labor & Industries (L&I) has fined the business $154,000 for multiple willful, serious and general workplace safety violations.  In each of the incidents, when the leaks…...

Respondent owned and operated a pesticide and specialty chemical manufacturing facility located in Louisiana. On January 8, 2014, EPA Region 6 conducted an on-site CAA 40 C.F.R. Part 68 and Section 112(r) Partial Compliance Evaluation of the Facility. The facility has 11 regulated substances that are held above the threshold quantities identified in 40 C.F.R.§…...

Respondent owns and operates a facility in Houston, Texas. The Facility processes, handles, and/or stores regulated substances and other extremely hazardous substances, including ethylene and ethylene oxide.  The Facility has a number of laboratory and pilot plant processes, including a Reversible Acid Pretreatment Pilot Plant (RAPT PP) and an Ethylene Oxide Pilot Plant (EOPP). On February…...

Respondent has submitted and registered an RMPlan to the EPA for its Stationary Source and has developed an RMProgram accidental release prevention program for the Stationary Source. At its Stationary Source, the Respondent operates a river barge terminal. The facility stores anhydrous ammonia and blends fertilizers for sale to farmers and cooperatives. Anhydrous ammonia is received…...

A cryogenic natural gas liquid (“NGL”) facility with capacity to process approximately 1.0 billion cubic feet per day of raw natural gas while recovering around 1.4 gallons per million cubic feet of NGL product in the ethane rejection mode of operation suffered a release of approximately 19,000 pounds of NGL at the truck loading area…...

OSHA issued the nine citations and fined a refinery $164,775 for process safety lapses resulting in a Nov. 22 fire that injured six workers.  8 of the 9 citations were “serious” and each carried a fine of $12,675. The ninth, listed as a “repeat,” was $63,373.  The refinery is contesting the citations and associated penalties.  The…...

Respondent operates a natural gas processing plant where raw natural gas is received via pipeline and processed to remove heavy natural gas liquids (NGLs) (i.e., butane, ethane, methane, pentane, propane, isobutane and isopentane ). After being processed and purified into a finished by-product, the NGL mixture is stored in pressurized tanks and transferred into tanker…...

Respondent is a municipality doing business in the Commonwealth of Kentucky. On November 13, 2014, the EPA issued to Respondent a notice of potential violation (“NOPV”), providing notice that the EPA found that Respondent had potentially committed the alleged violations described in Section E of this Agreement and providing Respondent an opportunity to confer with…...

Respondent is a municipality doing business in the Commonwealth of Kentucky. On October 27, 2015, the EPA issued to Respondent a notice of potential violation (“NOPV”), providing notice that the EPA found that Respondent had potentially committed alleged violations and providing Respondent an opportunity to confer with the EPA. On April 5, 2016, and May…...

Respondent submitted and EPA has approved a single RMPlan that includes an accidental release prevention program for its stationary source. EPA alleges for the purpose of this Agreement: At the time of the EPA inspection, the Respondent had an RMProgram level 2 covered process that stores or otherwise uses peracetic acid, which is a regulated…...

SPECIAL NOTE:  I normally do not post small cases like this; however, this case involves a facility not counting railcars that have been disconnected from their motive power in the Maximum Intended Inventory for the Process Quantaties. On September 1, 2015 an authorized representative of the EPA conducted a compliance inspection of the Respondent’s facility to…...

On Dec. 2, 2016, OSHA issued citations to a poultry processing facility for five serious safety violations, including one issued as a violation of the OSH Act’s general duty clause. Two hazard alert letters were issued on Dec. 2, 2016. OSHA’s inspection began on June 3, 2016, after the employer reported that a worker suffered…...