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 @ pesticide and specialty chemical manufacturing facility (CL2 & $124K)

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.§ […]

EPA RMP General Duty citations @ Ethylene Oxide Pilot Plant (EO & $36K)

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

EPA RMP citations @ Barge Terminal (NH3 & $72K)

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

EPA RMP citations @ natural gas processing plant (Natural Gas & $53K)

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

EPA RMP citations @ WWTP (Cl2 and SO2 & $16K)

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

EPA issues RMP & EPCRA citations after 300 pound NH3 release (NH3 & $108K)

The CAFO resolves the following CAA and CERCLA violations that EPA alleges occurred in conjunction with Respondent’s handling of ammonia at its cold storage warehouse: Failure to Comply with RMP emergency contact requirements, in violation of 40 C.F.R. § 68.160(b)(6); Failure to comply with Program 3 safety information requirements, in violation of 40 C.F.R. 68.65;

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