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 issues RMP citations @ food distribution warehouse (NH3 & $12K)

Respondent owns and operates an ammonia refrigeration system at its food distribution warehouse facility (the Facility). EPA inspectors completed an inspection at the Facility on September 27 through September 29, 2021, to evaluate Respondent’s compliance with CAA 112(r). The respondent’s process at the Facility is a covered process that is subject to the requirements of…...

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EPA issues RMP GDC citations @ refrigeration facility (NH3 & $169K)

Respondent owns, operates, and maintains a refrigeration system that contains approximately 14,000 pounds of anhydrous ammonia. The refrigeration system, consisting of piping, valves, and equipment, cycles ammonia through various physical states (high-pressure liquid, low-pressure liquid, low-pressure vapor, high-pressure vapor, and then back to high-pressure liquid) and provides refrigeration for the processing, production, and storage of…...

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EPA issues RMP GDC citations @ coal gasification manufacturing plant (H2S & $62K w/ $64K SEP)

Respondent is the owner and/or operator of the Facility, which operates a coal gasification manufacturing plant. At this plant, Respondent uses a coal gasification process to produce industrial chemicals from coal. The reaction takes place at high temperatures and pressures in a series of process vessels and piping called process trains. The facility operates two…...

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EPA issues RMP GDC citations @ coal gasification manufacturing plant (H2S & $62K w/ $64K SEP) Read More »

EPA issues RMP citations @ frozen fruit and vegetable production facility (NH3 & $131K)

Respondent owns and operates a frozen fruit and vegetable production facility. On September 27, 2021, EPA performed an inspection of the Facility to evaluate the Respondent’s implementation of and compliance with the requirements of Section 112(r) of the CAA, Sections 304-12 of the Emergency Planning and Community Right­ to-Know Act, and Section 103 of the…...

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EPA issues RMP citations @ cold storage facility (NH3 & $71K)

Respondent is the owner and/or operator of the Facility, which has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility: a. Respondent operates an ammonia refrigeration facility. b. Respondent has on-site for use, 14,300 pounds of anhydrous ammonia. c. Respondent…...

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EPA issues RMP citations @ chemical manufacturing facility (Cl2 & $127K)

The respondent is the owner of a chemical manufacturing facility. On September 10, 2020, Complainant issued an information request under Section 114 of the Clean Air Act (“CAA”) and Section 104(e) of the Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”), 42 U.S.C. § 9603, regarding the Facility to Respondent. Respondent responded to the information…...

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EPA issues RMP citations @ juice facility (NH3 & $127K w/ $67K SEP)

Respondent owns and operates a facility which is used to produce, bottle, and chill apple juice and cider prior to distribution.  Respondent owns and operates a second facility (“West Facility” ), which is also used to produce, bottle, and chill apple juice and cider prior to distribution. The East Facility and West Facility are sometimes…...

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EPA issues RMP citations @ WWTP (Cl2 & $12K, w/ $55K SEP)

Respondent owns and operates a water treatment plant in MN that has an inventory of chlorine gas at the water treatment plant, which is 360,000 pounds. The threshold quantity of chlorine is 2,500 pounds. Respondent’s RMP registration states that the maximum inventory of anhydrous ammonia at the water treatment plant is 87,583 pounds. The threshold…...

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EPA issues RMP GDC citations @ cold storage warehouse and distribution facility (NH3 & $122K w/ SEP)

Respondent operated a cold storage warehouse and distribution facility located in RI (the “Facility”). The Facility is located immediately adjacent to a Bay, approximately one-third of a mile from several marinas, just under 1 mile from a few homes, and less than 1.5 miles from an elementary school, a residential neighborhood, and a small airport…....

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EPA issues RMP citations @ metal parts heat treatment operation (NH3 & $13K w/ $61K SEP)

Respondent owns and operates a metal parts heat treatment operation in Michigan (the Facility) that maintains a maximum inventory of 60,000 pounds of the regulated toxic substance, anhydrous ammonia, which exceeds the threshold quantity of 10,000 pounds of anhydrous ammonia as set forth in Table 1 at 40 C.F.R. § 68.130. Respondent uses anhydrous ammonia…...

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EPA issues RMP citations @ chemical repackaging, distributing, and manufacturing chemicals (NH3, Cl2, SO2 & $205K)

Respondent is a private family-owned company that owns and/or operates facilities located in California and Arizona. Respondent specializes in repackaging and distributing chemicals and manufacturing chemicals onsite. The Facilities are located within populated residential, commercial, and industrial areas. The CA Facility receives and repackages anhydrous ammonia and manufactures aqueous ammonia in a reactor by mixing…...

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EPA issues RMP citations @ chemical repackaging, distributing, and manufacturing chemicals (NH3, Cl2, SO2 & $205K) Read More »

EPA issues RMP citations @ cold storage facility (NH3 & $173K; MOC, ER, WCS))

Respondent owns and operates an anhydrous ammonia refrigeration system facility in Altoona, Iowa (Respondent’s Facility). On or about September 21, 2022, 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…...

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EPA issues RMP citations @ cold storage facility (NH3 & $173K; MOC, ER, WCS)) Read More »