PSM and RMP Citations/Analysis

The Respondent owns or operates a chemical distribution facility where the respondent has used or stored more than 15,000 pounds of formaldehyde. 40 C.F.R. § 68.25(a)(2)(i) requires the owner or operator of a stationary source to analyze and report in a Risk Management Plan (“RMP”) the worse-case release scenario that is estimated to create the…...

Respondent is the owner and operator of an olefins facility which had two (2) incidents that occurred on December 20, 2021, and May 3, 2022, that resulted in accidental releases. Respondent has an olefins unit process at the Facility, meeting the definition of ” process”, as defined by 40 C.F.R. § 68.3. EPA Findings of…...

Respondent is the owner and operator of five (5) facilities as that term is defined in section 112(a)(9) of the CAA, and within the meaning of section 112(r) of the CAA and section 313 of EPCRA.  EPA conducted inspections of the facilities on the following dates to determine Respondent’s compliance with section 112(r) of the…...

Respondent is the owner and/or operator of a facility that uses, handles, and/or stores more than a threshold quantity of ammonia (anhydrous), ammonia (concentration 20% or greater), and chlorine, which are regulated substances, as specified at 40 C.F.R. §§ 68.115 and 68.130. During the inspection, the EPA representative observed alleged violations of section 112(r) of…...

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…...