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 cites Ammonia Ag Distributor $2,800

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…...

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EPA cites Ammonia Ag Distributor $2,800 Read More »

EPA RMP citations @ (Ethanol Plant w/Ammonia & $46K)

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...

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EPA RMP citations @ Natural Gas Processing Plant (Flammables & $42K)

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,…...

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Major RMP Settlement agreement (NH3 refrigeration; $3.9M & $300K to FDs)

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…...

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Major RMP Settlement agreement (NH3 refrigeration; $3.9M & $300K to FDs) Read More »

EPA RMP citations @ Motor Vehicle Parts and Accessories Plant ($119K toluene 2,4 diisocyanate and toluene 2,6 diisocyanate)

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…...

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EPA RMP citations @ Motor Vehicle Parts and Accessories Plant ($119K toluene 2,4 diisocyanate and toluene 2,6 diisocyanate) Read More »

EPA RMP citations @ Food Plant (NH3 & $4K)

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…...

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EPA RMP citations @ Food Plant (NH3 & $4K) Read More »

EPA RMP citations @ Ethanol Plant (NH3 and $4K)

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…...

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OSHA has cited a refinery with repeat, serious and o-t-s violations (PSM $281K)

OSHA has cited a refinery with repeat, serious and other-than-serious violations following the death of two workers at the crude oil refinery. OSHA began its investigation 9/12/2012 following the explosion of a boiler, which killed the employees. The inspection was expanded to include associated contractors and ongoing maintenance activities during a turnaround operation. We need…...

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OSHA has cited a refinery with repeat, serious and o-t-s violations (PSM $281K) Read More »

EPA RMP Program 2 Citations $5,400 (NH3 Plant)

On April 18, 2012, EPA conducted a compliance inspection of an Ammonia plant 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…...

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EPA RMP Program 2 Citations $5,400 (NH3 Plant) Read More »

EPA RMP General Duty Clause citations $35,000 (release of H2 from a improperly installed gasket by the manufacturer of vessel – NOT the facility)

This is a very interesting case, as it involved an error by the manufacturer of a new vessel and not the facility; however, it was the facility that was cited the $35K!  On March 26, 2012, there was an incident at the facility involving the release of hydrogen gas to ambient air from a newly…...

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EPA RMP General Duty Clause citations $35,000 (release of H2 from a improperly installed gasket by the manufacturer of vessel – NOT the facility) Read More »

OSHA has cited a chemical facility with 14 safety violations (PSM NEP $63K)

OSHA has cited a chemical facility with 14 safety violations, including chemical hazards found at the company’s facility. OSHA’s September 2012 inspection was initiated as part of the agency’s National Emphasis Program on process safety management for covered chemical facilities. The inspection resulted in $64,665 in proposed penalties. The serious violations, with a $63,000 penalty,…...

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OSHA has cited a chemical facility with 14 safety violations (PSM NEP $63K) Read More »

Anyone who thinks EPA will not issue citations (NOVs) for not documenting WCS and ARS is WRONG… here is proof

Several times year we upset a client who has hired us to do a “wall-to-wall” compliance audit with their PSM/RMP programs. These audits are our most intense audits in which we leave no rock unturned. One of the items we audit in this level of auditing is the RMP submittal and all of the supporting…...

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Anyone who thinks EPA will not issue citations (NOVs) for not documenting WCS and ARS is WRONG… here is proof Read More »