PSM and RMP Citations/Analysis

Respondent owns and operates a metal parts heat treatment operation and maintains a maximum inventory of 60,000 pounds of anhydrous ammonia, at the Facility, which exceeds the threshold quantity of 10,000 pounds. Respondent uses anhydrous ammonia in its heat treatment process. EPA inspectors completed an announced CAA 112(r) inspection on June 15 through June 16,…...

Respondent is supplied with raw chemical feedstocks by tanker truck or railcar. Chemical unloading operations occur on the eastern portion of the Facility at dedicated tank truck and railcar unloading stations. Several chemicals are stored in bulk at the Facility in dedicated aboveground storage tanks (ASTs), including, nitric acid (one tank), hydrogen peroxide (four tanks),…...

Respondent operates a granular monoammonium phosphate (GMAP) process and a diammonium phosphate (DAP) process at the Facility, meeting the definition of “process” as defined by 40 C.F.R. § 68.3. A different Respondent operates an anhydrous ammonia process at the Facility, meeting the definition of “process” as defined by 40 C.F.R. § 68.3. The GMAP and…...

Responding to a report of workers being exposed to anhydrous ammonia, federal investigators found a Madison ice cream plant lacked sufficient process safety management procedures to control the release of hazardous chemicals.  Investigators with the U.S. Department of Labor’s Occupational Safety and Health Administration determined the Ice Cream facility failed to document that equipment was…...

Respondent formerly operated an ammonia refrigeration process at a distribution center and warehouse, maintaining a maximum inventory of the regulated toxic substance anhydrous ammonia at the facility exceeding the threshold of 10,000 pounds. At the Facility, the respondent operated a process, as defined in 40 C.F.R. § 68.3, that includes the use, storage, handling, and…...

On or about January 31, 2023, representatives of the EPA inspected Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had over 10,000 pounds of anhydrous ammonia in a process at its facility. Information gathered during the EPA inspection…...

Respondent owns and operates a chemical warehouse and repackaging facility. From November 2 through November 5, 2021, EPA performed an inspection of the Facility to evaluate compliance with Section 103 of the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”), EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during the Inspection…...

Respondent has a liquid natural gas pretreatment process at the Facility, meeting the definition of ” process” as defined by 40 C.F.R. § 68.3. Respondent receives natural gas by pipeline and pretreats the natural gas to remove carbon dioxide, sulfur compounds, water, mercury, and heavy hydrocarbons. The regulated substance under 40 C.F.R. Part 68 Chemical…...

Respondent is the owner and operator of an oil refinery. On September 9-13, 2019, the EPA inspected the Facility to determine compliance with 40 C.F.R. part 68. Based on the observations of the EPA inspectors at the inspection, the EPA has determined that Respondent uses, handles, and/or stores more than the threshold quantity of Flammable…...

A global manufacturer of industrial gas could have prevented a May 2023 explosion that severely injured several employees by following required operating procedures in the manufacturing process where diborane — a toxic, colorless, and pyrophoric gas — is produced, distilled, mixed, and transferred. OSHA determined the explosion occurred as a 25-year-old product technician used a…...

Respondent is an “owner or operator” of the Facility, which produced, used, or stored anhydrous ammonia, a hazardous substance. On April 25, 2019, the EPA conducted an inspection to determine compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, 42 U.S.C. § 9603, and the Emergency Planning and Community Right-to-Know Act…...

Respondent has a semiconductor manufacturing process at the Facility. The Facility has three covered processes using silane, ammonium hydroxide (conc 20% or greater), and anhydrous hydrogen chloride, meeting the definition of “process.” Respondent has greater than threshold quantities of anhydrous hydrogen chloride, silane, and ammonia (concentration 20% or greater) in covered processes at the Facility…....