Details

Parent Category: Safety Info Posts

Category: PSM and RMP Citations/Analysis

Published: 04 April 2017

Respondent owns and operates a food oil products manufacturing and distribution facility which is engaged in packaging margarine, liquid oil and shortenings. Respondent operates a closed loop refrigeration system which utilizes or utilized anhydrous ammonia at the Facility. Respondent uses and stores 13,800 lbs. of anhydrous ammonia in the refrigeration system. The Facility is subject to the "Program 3" eligibility requirements because the process:

1. does not meet the requirements of 40 C.F .R. § 68.10
2. because the distance to a toxic or flammable endpoint for a worst-case release assessment conducted under 40 C.F.R. § 68.25 is greater than the distance to any public receptor; and
3. is subject to the OSHA process safety management standard set forth at 29 C.F.R. § 1910.119 and 40 C.F.R. § 68.10(d) because the process involves anhydrous ammonia above the threshold quantity of 10,000 pounds.

On August 11, 2011, U.S. EPA conducted an inspection to determine whether the Respondent was complying with Section 112(r) of the Act, 42 U.S.C. § 7412(r), and the regulations at 40 C.F.R. Part 68.  Based on the inspection conducted on August 11, 2011, and a review of additional information received by EPA subsequent to that date in response to the information request, EPA determined that the Facility failed to comply with the Risk Management Program regulations at 40 C.F.R. Part 68 for Program 3 requirements as set forth below:

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