PSM and RMP Citations/Analysis

This is an interesting outcome, of which I have no knowledge as to how this deal was struck.  But there was no monetary penalty and the facility has 60 days to make some seriously big changes/improvements.  The biggest thing I noticed is that EPA is requiring the facility to make changes to comply with the…...

As part of the agency’s national emphasis program for chemical facilities, OSHA inspected the company on Feb. 6, 2016, and found multiple violations of federal process safety management regulations, including not developing set written procedures for maintaining process equipment, which resulted in repeat violations.  In addition, OSHA issued citations for serious violations for the following:…...

Respondent owns and operates a chemical plant to produce many grades of high density polyethylene (HDPE). On August 2, 2015, Respondent identified a release of hexane into the adjacent facility to Respondent cooling water system and released to atmosphere. The cause was due to two of 658 “U” tubes from the LHC Tails Cooler failed…...

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. Respondent operates polyhydric alcohol production process that uses ethylene oxide, propylene oxide, and ethylenediamine in the polyhydric alcohol production process. Respondent has one RMProgram level 3 covered process, polyhydric…...

Respondent owns and operates a 210,000 square foot fresh fruits and vegetables processing and cold storage facility. The facility includes one RMProgram regulated closed-looped ammonia refrigeration system. The refrigeration system represents an RMProgram level 3 covered process which currently stores or otherwise uses 27,300 pounds of anhydrous ammonia, in amounts exceeding the applicable threshold of…...

Respondent owns and operates a container molding facility where it manufactures and recycles high density polyethylene containers ranging in size from fifty-five to 330 gallons (“containers”). The larger containers are encased in a steel cage for extra support. As part of its recycling operations, the Facility accepts used containers which routinely contain small amounts of…...

Respondent operates a meat processing facility that uses 24,300 pounds of ammonia as its refrigerant. Respondent has one RMProgram level 3 covered process, an ammonia refrigeration process, which stores or otherwise uses a toxic chemical in an amount exceeding its applicable threshold of 10,000. During calendar year 2014, EPA opened an RMProgram compliance monitoring investigation…...

Respondent owns and operates a chemical manufacturing facility that has an Acrylonitrile Manufacturing process. On or about December 1-3, 2015, an EPA inspector conducted an inspection of Respondent’s facility.  A contractor was removing a six-inch blind and installing four-inch and three quarters inch blinds to prepare the Heads Column in the Acrylonitrile Unit for caustic cleaning. The…...

Respondent owned and operated a refinery. On March 31-April3, 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 refinery submitted a single RMP with covered processes that are subject to Program 3 requirements. The regulated flammable substances that are above the threshold…...

A food additive manufacturer’s failure to handle hazardous materials and respond properly to an emergency led to an explosion that injured four workers, including two contractors who scaled an 8-foot security fence topped with triple-strand barbed wire to escape the fireball.  An OSHA investigation found the business violated process safety management procedures for the handling…...

July 7, 2016 UPDATE – Company is Contesting all citations OSHA has issued nine serious safety violations to a food industry provider of cold storage warehousing and logistical services. A January 2016 complaint investigation found the company violated OSHA’s process safety management procedures for using ammonia in its refrigeration warehouse facility. An investigation by the…...

Respondent owned and operated the a chemical manufacturing facility. On September 8-11, 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 faility’s RMP lists three covered processes subject to Program 3 requirements. The regulated flammable substances that are held above the…...