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 @ WWTP (Cl2 & $71K)

Respondent is a municipality in the state of Kansas, which owns and operates a Water Treatment Plant. On or about August 24, 2016, representatives of the 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. Information gathered during the EPA inspection revealed that […]

EPA RMP GDC citations @ anaerobic biodigester (Flammables & H2S; $10K w/ $39K SEP)

Respondent operates enclosed, anaerobic biodigester systems that process food processing, biomass waste streams to produce a biogas intermediate that contains methane. This biogas is further processed (in an enclosed system) to produce a final compressed natural gas that is sold as a transportation fuel. Gaseous hydrogen sulfide has on occasion been released in small concentrations when

EPA RMP citations @ refinery (Flammables and HF Acid & $46K w/ $168K SEP)

Respondent owns and operates a refinery which produces, processes, handles, or stores, over the threshold amount, hydrogen, methane, ethane, ethylene, propane, propylene, butane, iso-butane, pentane, pentene, and iso-pentane. All are listed at 40 C.F.R. § 68.130 as regulated substances based on their flammability. At the Facility, the Respondent also produces, processes, handles, or stores, over

DOJ Consent Decree on RMP General Duty Clause @ fish processing and canning facility (Ammonia, Chlorine, and Butane)

This is from a recently posted Consent Decree for a fish processing facility.  From all I have seen this facility did NOT have RMP Covered processes using Anhydrous Ammonia, Chlorine or Butane and all of these actions stem from a General Duty Clause agreement, which is by far the most significant GDC agreement I can remember. 

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

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

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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