PSM and RMP Citations/Analysis

Respondent is the owner and operator of a facility that stores and circulates anhydrous ammonia through two refrigeration systems at its facility and, therefore, is engaged in a process at its facility. On or about September 13, 2023, a representative of the EPA conducted an inspection of the Respondent’s Facility to determine compliance with Section…...

The Respondent’s July 23, 2019, RMP submission outlines a maximum inventory of the regulated flammable substance butane and LPG at the Facility that exceeds the threshold quantity of 10,000 pounds of butane and LPG as outlined in Table 3 at 40 C.F.R. § 68.130. Respondent’s aerosol-propelled adhesive process at the Facility was, at the time…...

Respondent operated a facility (the “Facility”) that stores and distributes anhydrous ammonia. The Facility receives anhydrous ammonia from oceangoing vessels and stores it in two interconnected insulated tanks. The Facility includes three pressure tanks storing fertilizer-grade ammonia (Fl through F3) and four pressure tanks storing refrigeration-grade ammonia (R1 through R4). Respondent produces, stores, and distributes…...

Respondent owns and operates a prepared foods processing plant located within one mile of a residential area, an elementary school, a pond, a river, and many businesses. Respondent uses anhydrous ammonia in a refrigeration process,” as defined by 40 C.F.R. § 68.3, in a series of interconnected pipes and vessels at the Facility (the “Process”)…....

Respondent operates a chemical manufacturing facility which has on-site for use, 25,299,678 pounds of anhydrous ammonia and 355,094 pounds of ammonia (concentration 20% or greater). Respondent has two RMProgram level 3 covered processes, that store or otherwise use anhydrous ammonia and ammonia (concentration 20% or greater) in amounts exceeding their applicable thresholds of 10,000 pounds…...

Respondent owns and operates a Gas Plant. On or about July 11 and 12, 2023, representatives of the EPA inspected the 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 greater than 10,000 pounds of propane and greater…...

Respondent is the owner and/or operator of the Facility, which operates a chemical storage and distribution facility. The respondent had on-site storage for 50,000 pounds of cyclohexylamine, 1,800,000 pounds of chlorine, 1,500,000 pounds of sulfur dioxide (anhydrous), 265,000 pounds of ammonia (anhydrous), 350,000 pounds of ammonia (concentration 20% or greater), and 17,000 pounds of hydrofluoric…...

I usually do not waste time posting the Expedited Settlement Agreements, as these cases are typically minor record-keeping violations with low-dollar amount citations. However, one thing that irks me is how public utilities receive lenient treatment regarding the amount they pay for violating the EPA’s RMP regulations. And to make matters worse, they dare to…...

Respondent is the owner and/or operator of a facility that operates an ammonia refrigeration plant with 39,000 pounds of anhydrous ammonia. Respondent has one RMProgram level 3 covered process, which stores or otherwise uses anhydrous ammonia in an amount exceeding its applicable threshold of 10,000 pounds. On July 18, 2023, the EPA conducted an on-site…...

Respondent operated a facility that refines petroleum products using a hydrofluoric acid alkylation process. Hydrofluoric Acid is a “regulated toxic substance” listed under CAA Section 112(r)(3), 42 U.S.C. § 7412(r)(3), with a TQ of 1,000 lbs. See 40 C.F.R. § 68.130, Tables 1 and 2. On June 2-3, 2022, EPA performed an inspection of the…...