PSM and RMP Citations/Analysis

Respondent is an owner and operator of a petroleum refinery. Refining operations at the Facility are currently idled. EPA conducted an inspection of the Facility on September 20 – 26, 2022, to assess compliance with Section 112(r) of the CAA (the “Inspection”). During the Inspection, and in a letter dated October 13, 2022, EPA informed…...

The Respondent operates plastics material and resin manufacturing processes at the Facility that produces polymers used in various applications and products, meeting the definition of “process “, as defined by 40 C.F.R. § 68.3. The Respondent produces, processes, handles, and stores 1,3-Butadiene, Chlorine, Propylene oxide, and Acrylonitrile at the Facility. On February 2, 2022, an…...

The Respondent owns an alkoxylation process at the Facility. Respondent manufactures a range of specialty surfactants for use predominantly in the oil and gas industry. The process of ethoxylation involves reacting ethylene oxide with various common chemicals , such as fatty alcohols and phenols, to produce a variety of products. The plant can also use…...

Respondent is the owner and operator of a facility that produces olefins, ethylene oxide, propylene oxide, Methyl tertiary-butyl ether (MTBE), ethylene glycols, propylene glycols, ethanolamines, morpholine/Diglycolamine (DGA) surfactants. The facility is divided into nine process areas. The first area contains the propylene glycol unit G2. The second area contains the morpholine/DGA unit E7. The third…...

NOTE:  I usually do not post RMP citations with this small of an amount, but this was a rare Program 1 citation, so I felt there was some learning to this. Respondent operates a polyurethane manufacturing facility with over 10,000 pounds of methyl formate in a process at the Facility. Methyl formate is a “regulated…...

SAFTENG NOTES:  Interesting citations… GDC on “Opening process equipment” and GDC on LEL detector(s) locations The Respondent operates plastics material and resin manufacturing processes at the Facility that produces polymers used in various applications and products, meeting the definition of “process “as defined by 40 C.F.R. § 68.3. The Respondent produces, processes, handles, and stores…...

Respondent has an “All Other Basic Organic Chemical Manufacturing” process at the Facility, meeting the definition of “process” as defined by 40 C.F.R. § 68.3. Respondent has greater than a threshold quantity of Vinyl Acetate, Ethylene oxide, Ammonia, Methane, Propylene, Acetaldehyde, and a Flammable Mixture (” the Regulated Substances”) in a process at the Facility,…...

Respondent is the owner and operator of the facility that produces anhydrous ammonia, urea fertilizer, and urea-ammonium nitrate which are loaded on trucks and railcars for distribution. The Respondent’s Facility chemical processes meet the definition of “process” and “covered process”, as defined by 40 C.F.R. § 68.3. The Respondent’s RMP program level 3 covered processes…...

Respondent is the owner and operator of the facility that produces, processes, stores, or handles more than 10,000 pounds of ethylene and more than 15,000 pounds of vinyl acetate monomer (Acetic acid ethenyl ester). The EPA inspected the Facility from January 16, 2020 to January 17, 2020, to determine the Respondent’s compliance with 40 C.F…...

Respondent is the owner and/or operator of a gas processing plant that has on-site for use/storage 55,126 pounds of sulfur dioxide, 8,240 pounds of anhydrous ammonia, 130,000 pounds of butane, and over 10,000 pounds of hydrogen.  Respondent has three RMProgram level 3 covered processes, which store or otherwise use sulfur dioxide, butane, and hydrogen. Sulfur…...

The Respondent is a wholesale gas supplier. Operations include the filling, storing, and transfer of industrial gases. The facility receives bulk gases in tanker trailers and then transfers them to storage tanks before transferring them to smaller containers or back into tanker trailers for wholesale. Additionally, the facility receives nearly empty bulk trailers and containers…...

Respondent owns and operates an ice manufacturing facility that typically operates 24 hours a day, seven days a week. On June 26, 2019, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Sections 304-312 of the Emergency Planning and Community Right-to-Know Act (“EPCRA”), and Section 103 of the Comprehensive Environmental…...