PSM and RMP Citations/Analysis

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…...

On March 7, 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…...

An aerosol paint manufacturer has been cited for multiple safety violations following an explosion and fire that resulted in serious injuries to three employees on March 6, 2013. OSHA cited the company for 26 safety violations, including two willful violations where locked doors impeded exit routes and snow blocked exits, slowing employees from exiting the plant…...

Respondent is the owner and operator of the natural gas compressor stations. The Facilities receive natural gas from well sites, separate out liquids from the natural gas and route the natural gas liquids to aboveground storage tanks at the Facilities. The natural gas is compressed and then sent via pipeline to gas plants for further…...