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 @ resin manufacturing plant (NH3 & Formaldehyde & $14K with $52K SEP

Respondent is the owner and/or operator of a resin manufacturing plant. Respondent has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At all times relevant to the violations, Respondent had on-site for use 1,886,000 pounds of formaldehyde (solution) and 52,000 pounds of…...

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EPA RMP/EPCRA citations @ Ethanol Manufacturing Facility (Flammables & 169K)

Respondent owns and operates an ethanol manufacturing facility. A mixture of hydrocarbon liquids butane, isopentane, and pentane is a “regulated substance” pursuant to 40 C.F.R. § 68.3. Pursuant to 40 C.F.R. § 68.115(b)(2)(i), the entire weight of the mixture shall be treated as the regulated substance when the concentration of each of the regulated substances…...

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EPA RMP Citations @ chemical manufacturing plant (Oleum, SO2, H2SO4, ATS & $174K)

Respondent owns and operates a chemical manufacturing plant that produces oleum, anhydrous sulfur dioxide, sulfuric acid, and ammonium thiosulfate. Respondent re-submitted an RMP for the Facility on February 11, 2022 (2022 RMP) that identifies the following three covered processes that are subject to the Program 3 requirements of the CAPP:a. Oleum Process, which contains the…...

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EPA RMP Citations @ Cold Storage facility (NH3 & $85K)

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…...

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EPA RMP Citations @ aerosol propelled adhesive facility (LPG/Butane & $100K)

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…...

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EPA RMP Citations @ NH3 Storage facility (NH3 & $460K)

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…...

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350 pound NH3 release @ potatoe processing plant leads to $65K in EPCRA citations

Respondent produced, used, or stored ammonia at the Facility and released a reportable quantity of an EHS, ammonia. On or about August 31, 2022, a “release” of ammonia in excess of 100 pounds occurred at the Facility (the release). As a result of the information obtained by the EPA and subsequent investigation, the Complainant has…...

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EPA RMP Citations @ prepared foods processing plant (NH3 & $68K w/ $48K SEP)

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”)…....

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EPA RMP Citations @ chemical manufacturing facility (Anhy NH3/>20% NH3 & $40K w/ $157K SEP)

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…...

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EPA RMP Citations @ Gas Plant (Flammables & $196K w/ $111K SEP)

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…...

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EPA RMP Citations (NH3 & $105K)

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…...

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EPA RMP citations @ Water Treatment Plant (Cl2 & $2K)

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…...

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