EPA RMP

Ammonia Refrigeration & PSM Contractor Qualification, Training Edition

Most companies will go to some degree of lengths in selecting “qualified” contractors to include things such as job examples, a list of qualifications, require subscription to the ISN network, etc. Even then, though, sometimes bad apples slip through the cracks if the company needing a “qualified” contractor doesn’t develop a scope or set of

EPA RMP & EPCRA Citations @ Food Plant (NH3 & $210K

Respondent operated a facility that utilizes anhydrous ammonia to provide cooling capabilities to processing, shipping, cooler areas, silos, and chillers for its beef and meat products. On March 30, 2022, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, EPCRA Sections 304-312,

EPA RMP Citations @ Food Facility (NH3 & $152K)

Respondent operated a facility (the “Facility”) to process, store, and distribute prepackaged salads, fresh-cut vegetables, and other food products. At all times relevant to this CAFO, Respondent produced, used or stored more than 10,000 pounds of ammonia (anhydrous) at the Facility and was subject to the requirements of CAA § 112(r)(7). At all times relevant

EPA RMP citations @ Agriculture Supply business (NH3 & $33K)

Respondent owns and operates a facility that wholesales animal feeds, fertilizers, agricultural chemicals, pesticides, seeds, and farm supplies, including agricultural anhydrous ammonia. On or about August 9, 2023, EPA inspected the Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that

Temporary SOP or a Car-Seal or Both?

The arrangement below is very common in processes/systems. This simple yet common arrangement causes havoc in hazard analyses. As the title states, is this arrangement managed with a Temporary SOP, a Car-Seal, or Both? The issue is that the motorized valve is tied to a Hi-Hi level alarm and interlock. When the vessel archives its

When will the ammonia refrigeration industry finally embrace LOTO? (Part II)

Victor Dearman Jr. CIRO, CRST One of the challenges to my post was “What if the flagging tape was to indicate that the valve was in an abnormal position?” This was followed up with a challenge as to whether or not anything forbids such a method. Operating procedures should be designed to meet the requirements

When will the ammonia refrigeration industry finally embrace LOTO? (Part I)

By: Victor Dearman Jr. CIRO, CRST Flagging tape is not LOTO! And never has been. I would bet good money the operating procedure for this compressor has LOTO covered, but those are just documents to look good in a binder sitting on a shelf collecting dust because they are viewed as a necessary evil to

Scroll to Top