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 @ chemical manufacturing plant (1,3-butadiene & $20K)

Respondent operates a chemical manufacturing plant that has one RMProgram level 3 covered chemical manufacturing process, which stores or otherwise uses 1,3-Butadiene in an amount exceeding its applicable threshold of 10,000 pounds. On November 9, 2015, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the…...

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EPA RMP General Duty citations @ frozen food processing facility (NH3 & $36K – release of 1,559 pounds)

Respondent’s facility is a frozen food processing facility which primarily produces frozen dinners and entrees. As part of this process, Respondent uses ammonia in its plate freezers. On May 2, 2016 at approximately 2:35 p.m., a change in position of the stacking trays or plates located in Plate Freezer 1-6 caused the routine horizontality a1mm to…...

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EPA RMP citations @ poultry processing facility (NH3 & $56K)

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…...

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EPA RMP citations @ breakfast food plant (NH3 & $40K)

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…...

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EPA RMP citations @ refinery (Flammables & HF Acid & $182K)

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…...

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EPA RMP citations @ plastics and resins manufacturing facility (Vinyl Acetate & $15K, w/ $59K SEP)

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”…...

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EPA RMP citations @ fertilizer plant (NH3 & $72K)

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,…...

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EPA RMP citations @ chemical plant (Chlorine & $48K)

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…...

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EPA RMP citations @ food facility (NH3 & $106K, w/ 20 facility audits)

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…...

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EPA RMP General Duty Clause citations @ food plant (NH3 & $30K)

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…...

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EPA RMP citations @ chemical plant (Flammables & $70K, w/ $80K SEP)

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…...

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EPA RMP citations @ chemical manufacturing facility (NH3 & $37K)

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…...

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