PSM and RMP Citations/Analysis

The Facility is a frozen food storage and distribution facility, which contains anhydrous ammonia refrigeration equipment. On September 15, 16 and 20, 2011 , EPA conducted inspections (“the 2011 Inspections”) at the Facility to determine compliance with Section 112(r) of the Act, 42 U.S.C. § 7412(r). The 2011 Inspections revealed a number of safety concerns…...

An ethanol business has been cited for 15 health and safety violations by OSHA after a worker was fatally engulfed in corn inside a grain storage bin on April 19 at the ethanol manufacturing facility. The worker entered the grain bin in an attempt to unclog the floor chute and became engulfed when corn began…...

Respondent is the owner and/or operator of two facilities, the “Saratoga Springs Facility” and the “Carthage Facility”. On or about May 22, 2009, Respondent submitted an RMP to EPA for the Saratoga Springs Facility; which identified the process chemical as chlorine, specified a quantity of 24,000 pounds, and identified this process as subject to Program…...

This case is significant as it involved a facility that used the detatched “transport trailer” as their storage tank.  The trailer was a 8-tube “tube trailer” which was parked at the site, the tractor detached, and connected to the “process”.  EPA conducted an inspection on December 17, 2012, to determine compliance with Section 112(r) of…...

The refinery has ten covered process units each utilizing a threshold amount of a regulated substance. It operated a boiler at the Facility, which combusted natural gas or refinery fuel gas as fuel. On September 28, 2012, natural gas was introduced into the boiler during an attempted start-up. During the attempted startup, the natural gas…...

Facility is the state’s largest distributor of fertilizers, industrial, and agricultural chemicals.  The facility manufactures sodium hypochlorite (bleach), using chlorine and sodium hydroxide as reagents. The facility also serves as a storage and distribution center for bulk and bagged industrial chemicals including anhydrous ammonia, sulfur dioxide, and sulfuric acid. The facility produced, used, or stored…...

A chemical company in Ohio has agreed to correct deficiencies in its risk management plan as part of a settlement with Ohio EPA.  The company produces detergent-grade sulfonic acid, synthetic detergents, surfactants and emulsifiers. As part of its process, it uses sulfur dioxide and sulfur trioxide.  During an October 2004 inspection, Ohio EPA determined that…...

A Cincinnati foods plant has agreed to correct repeated deficiencies in its risk management plan as part of a settlement with Ohio EPA.  The company cooks, packages and sells chicken parts. The facility keeps approximately 46,000 pounds of anhydrous ammonia onsite to be used in the refrigeration process.  A 2004 Ohio EPA inspection found 10…...

A cold storage business has been cited for 14 safety violations and fined $132,800 by OSHA for exposing workers to anhydrous ammonia at its facility. The company has been placed in OSHA’s Severe Violator Enforcement Program.  The March inspection was initially conducted under OSHA’s high-hazard local emphasis program. It expanded to include all items within…...

The Respondent produces, processes, handles and/or stores hydrogen cyanide as part of its Adiponitrile (ADN) Unit. Adiponitrile is manufactured by reacting butadiene with hydrogen cyanide to form Pentenenitrile, which is reacted with additional hydrogen cyanide to produce the Adiponitrile. The hydrogen cyanide is processed at the facility via reaction of natural gas, ammonia and air…...

On March 27,2013, EPA conducted a compliance inspection of 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)(7) of the Act. The EPA found that the Respondent had violated regulations implementing section 112(r)(7) of the Act by failing to comply with the specific…...

On December 14,2010, through December 16, 2010 EPA conducted a partial compliance evaluation inspection of the refinery pursuant to Section 112 of the Clean Air Act, 42 U.S.C. §7414 to evaluate the Facility’s compliance with the requirements of 40 CFR Part 68.  Respondent uses a standard procedure for inspection of process piping systems titled Mechanical…...