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 @ propane facility (LPG & $275K)

NOTE: This was a facility that was found to be covered by EPA’s RMP rule but had not submitted a RMP and was found to not have a functioning process safety management program.   On or about July 7, 2011, U.S. EPA issued an Information Request to Respondent to determine whether the Facility was in…...

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EPA RMP Citations @ food facility (NH3 & $6K)

On March 24-25, 2015, an authorized representative of the EPA conducted a compliance inspection of the Respondent’s facility, to determine compliance with the Risk Management Plan (RMP)’regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the CAA. The EPA found that the Respondent had violated regulations implementing Section 112(r) of the CAA by…...

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EPA RMP Citations @ fertilizer facility (NH3 & $1K)

PLEASE NOTE:  I normally do not post this type of citation as it is insignificant in dollar amounts; however, this one seems very odd so I posted it.  Painting over a name plate, which is actually still legible (even if it was not, it was cleaned and fully legible) was a $1500 citation AND was…...

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EPA RMP Program 2 Citations @ fertilizer facility (NH3 & $5K)

Respondent (s) is a private company which has 2 full time employees and sells NH3 as a fertilizer to farmers.  The facility had 175,079 pounds of Anhydrous Ammonia on site at the time of the inspection.  On May 21, 2015, EPA conducted a compliance inspection of the Respondent’s facility to determine compliance with the Risk…...

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EPA RMP Program 2 Citations @ fertilizer facility (NH3 & $26K)

Respondent is the owner and/or operator of a facility that sells anhydrous ammonia to farmers for use as a fertilizer. At all times relevant to this action, Respondent processed, handled and stored anhydrous ammonia at its facility. On or about May 29, 2013, and April 29, 2014, EPA conducted inspections of Respondent’s facility to determine…...

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EPA RMP Program 2 Citations @ fertilizer facility (NH3 & $3K)

On March 19, 2015, EPA conducted a compliance inspection of the Respondent’s facility to determine compliance with the Risk Management Plan (RMP) regulations. The EPA found that the Respondent had violated regulations implementing Section 112(r) of the CAA by failing to comply with the regulations as noted on the enclosed Risk Management Program Inspection Findings…...

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EPA RMP Citations @ synthetic rubber facility (Anhydrous ammonia, 1, 3-butadiene, and acrylonitrile & $8K w/ $33K SEP)

Respondent owns and operates a facility that produces synthetic rubber, styrene butadiene rubber (SBR), using a hot emulsion polymerization process. Anhydrous ammonia, 1, 3-butadiene, and acrylonitrile are each a “regulated substance” as set forth in 40 C.F.R. § 68.130. Respondent has the following processes at the stationary source:… Membership Required You must be a member...

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EPA RMP Citations @ synthetic rubber facility (Anhydrous ammonia, 1, 3-butadiene, and acrylonitrile & $8K w/ $33K SEP) Read More »

EPA RMP GDC @ solvent blending, storage, and distribution facilities

Respondent owns and operates several solvent blending, storage, and distribution facilities located in Iowa and Kansas.  On July 17, 2007, a series of fires and explosions occurred at a KS Facility. The cause of the incident was a static charge that ignited Special Naphtholite 66/3 (VM&P), an EHS listed under Section 112(r)(3) of the CAA,…...

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EPA RMP citations @ frozen desserts facility (NH3 & $122K, with REMOVAL of NH3)

A frozen desserts is required to pay $122,518.89 to EPA’s Superfund program, with interest.  The company manufactures and stores frozen desserts at its facility, which shares a building as a restaurant and theater and is located in close proximity to homes, schools and other businesses. After a 2010 ammonia release and a 2013 fire at…...

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EPA RMP Citations @ Chemical Facility (NH3, CL2, C2H3Cl & $874K)

The Respondent owns and operates a chemical manufacturing facility.  On or about April 8 – 12, 2013, an EPA instructor conducted an inspection of the Respondent’s facility after several incidents with on-site and off-site impacts…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA RMP Citations @ controlled temperature laboratory (NH3 & $85K)

GENERAL ALLEGATIONS Respondent operates a controlled temperature laboratory, where it conducts research on the effect of cold temperatures on equipment, structures and technological systems, at its Cold Regions Research and Engineering Laboratory.  The Facility is located approximately two miles north of the center of Hanover, New Hampshire. The 30-acre site is bordered on the north…...

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EPA RMP General Duty Citations @ disposal facility (Flammables, Hotwork & $37,500)

Respondent owns and operates a disposal facility associated process equipment.  At the facility the Respondent stored produced water, including residual hydrocarbons, in a 500-barrel fiberglass tank. Produced water stored in this tank was generated from multiple wells. Produced waters, and their associated vapors, are extremely hazardous substances due to their flammability and explosive nature. On…...

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