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 @ ice plant (51 pound NH3 release & $40K)

Respondent owns and operates a facility that produces, processes, handles, and/or stores a regulated extremely hazardous substance, anhydrous ammonia. The facility uses anhydrous ammonia in a closed-circuit refrigeration system to produce and store ice. Though the ice maker process runs continually, employees are not normally present at the facility outside of business hours.  On March

EPA RMP General Duty citations @ soft drink manufacturing facility (NH3 release & $35K)

Respondent owns and operates a soft drink manufacturing facility where it manufactures soft drinks and fills various can sizes and bottles for consumption. As a part of its manufacturing operations, the Facility utilizes a refrigeration cooling system, Ammonia is the refrigerant in the cooling system. The cooling system is used to lower the temperature at which

EPA RMP citations @ Water Treatment Plant & Waste-Waste Water Plant (CL2, SO3 & $80K)

Respondent is a municipality operating two “stationary sources”, the Water Treatment Plant (WTP) and the Waste-Water Treatment Plant (WWTP). At the time of the inspection, respondent had submitted and registered RMPlans for each of its stationary sources at the WTP and the WWTP and had developed an RMProgram accidental release prevention program for each of

EPA RMP General Duty Clause citations @ cold storage distribution facility (NH3 & $184K)

The Respondent’s facility consists of a large distribution warehouse, including a cold storage area, over 100 truck loading bays, 80 trucks, a truck maintenance garage, a diesel fueling depot, an administrative office, and an employee cafeteria and locker rooms. There is an approximately 1,500 square foot ammonia refrigeration machinery room (the “Machinery Room”) located at the

EPA RMP citations @ combined-cycle cogeneration power plant (NH3 & $109K)

Respondent owns a combined-cycle cogeneration power plant facility. From approximately 1991 to December 2013, the Facility was operated as a combined-cycle cogeneration power plant. Beginning in April 2012, the Facility halted full-time operations and began operating one or two days per year in order to conduct ISO-New England capability tests; however, the ammonia refrigeration system

EPA RMP citations @ gelatin production facility (NH3 & $23K)

Information collected during the September 14, 2016 inspection of Respondent’s Facility revealed that Respondent failed to develop and implement a risk management program that complied with the requirements of 40 C.F.R. Part 68. EPA alleges that Respondent has violated the CAA and federal regulations promulgated pursuant to the CAA as follows: Count 1 Respondent failed

EPA RMP General Duty citations @ commercial refrigeration facility (NH3 & $54K)

Respondent is the owner and operator or a commercial refrigeration facility that utilizes compressed anhydrous ammonia as the refrigerant. On or about January 28-29, 2015, EPA conducted an inspection at, and obtained information regarding the facility’s compliance with Sections 112(r)(1) and (7) of the CAA and the implementing regulations at 40 C.F.R. Part 68. Preliminary

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