Details

Parent Category: Safety Info Posts

Category: PSM and RMP Citations/Analysis

Published: 06 September 2019

So this week we all got a chuckle when I posted this picture to my Social Media groups:

But in all seriousness, this is NO laughing matter!  Well, we can at least surmise that EPA inspectors do not find the humor in it, as is evident in the nine (9) labeling issues they noted in this RMP inspection!  From NFPA 704 Diamonds with differing degrees of hazards for the same chemical to faded labels such that the color-coding is no longer identifiable, to piping not being labeled per ASME A13.1, to the Ammonia storage tanks not being labeled per CGA 2.1-2014.

Respondent operates a "stationary source" and has submitted and registered an RMPlan. The respondent has developed an RMProgram accidental release prevention program for the stationary source. At its stationary source, Respondent manufactures explosives and has on-site for use, approximately 609,000 pounds of anhydrous ammonia, 2,730,000 pounds of nitric acid, and 100,000 pounds of oleum. At its stationary source, Respondent has six RMProgram level 3 covered processes, which store or otherwise use anhydrous ammonia, nitric acid, and oleum in amounts exceeding their applicable threshold of 10,000 pounds, 15,000 pounds, and 10,000 pounds, respectively. On May 8-9, 2017, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing Respondent's compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered processes at its stationary source. At the time of the inspection, Respondent had the following deficiencies:

Membership Content