PSM and RMP Citations/Analysis

OSHA has cited the propane facility with 21 serious violations following a November 2012 fire that required three workers to be hospitalized and four workers to be treated and released. The plant inspection was expanded to include the national emphasis program on Process Safety Management Covered Chemical Facilities. Proposed penalties total $105,000.  The serious violations…...

EPA inspected a food distribution warehouse in October 2012 that contained an ammonia refrigeration process.  The inspection found the following issues:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

OSHA has cited dairy food company with 10 serious, two repeat and two other-than-serious violations. OSHA began an inspection in November 2012 under its Site Specific Targeting Program that directs enforcement resources to high-hazard workplaces, where high injury and illness rates occur, and the National Emphasis Program on facilities, covered under the Process Safety Management…...

On May 31, 2012 EPA conducted a compliance inspection to determine its compliance with the Risk Management Plan (“RMP”) regulations promulgated pursuant to Section 112(r) of the Act, and set forth at 40 C.F.R. Part 68. Based on the May 31, 2012 inspection and documents submitted by Respondent, EPA has determined that the respondent violated…...

On August 16, 2012, EPA conducted a compliance inspection of the 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) of the CAA. The EPA found that the Respondent had violated regulations implementing Section 112(r) of the CAA by failing to comply with…...

On January 24, 2012, EPA conducted a compliance inspection to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the CAA. The EPA found that the Respondent had violated regulations implementing Section 112(r) of the CAA by failing to comply with the regulations as noted…...

Anhydrous ammonia (CAS# 7664-41-7) and a flammable mixture (butane and pentane) (CAS # 00-ll-ll) are regulated substances and are present at the Facility in amounts greater than the threshold quantities.  The inspection found the following:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

The process at the Facility involves the separation of propane, butane, ethane and isobutane from the incoming natural gas using compressors and a process skid. The separated gases are stored together in a 10,000-gallon storage tank, which when full weighs 67,000 pounds, for transportation off-site.  The National Fire Protection Administration’s Code 58, Liquefied Petroleum Gas Code,…...

A large food manufacturer has received one of the largest, if not the largest, settlement agreement with EPA regarding their Risk Management Plans at 23 facilties in four (4) states. The total fines in the agreement consist of $3.9 million in civil and over $300,000 in supplemental environmental projects (SEP) that involves buying emergency response…...

This was a Program 2 Inspection and the facility had toluene 2,4 diisocyanate and toluene 2,6 diisocyanate in quantities exceeding 10,000 pounds during calendar years 1999 through 2010. Respondent thus maintained toxic substances in quantities exceeding the threshold quantities under the Chemical Accident Pollution Prevention rule. At and prior to the time of inspection the…...

On December 14,201 1, 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…...

On June 27, 2012, an authorized representative of the EPA conducted a compliance inspection of the Respondent’s facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.P.R. Part 68 under Section 112(r) of the CAA. The EPA found that the Respondent had violated regulations implementing Section 112(r) of the CAA…...