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Parent Category: Safety Info Posts

Category: PSM and RMP Citations/Analysis

Published: 05 November 2013

NOTE: this is a GAME CHANGER for the cold storage business!  Now EPA is pulling in the business that is merely leasing space AND the real estate broker who is managing the lease agreement!!  Imagine the shock when a business who is just storing their goods in a cold storage facility receives a NOV from EPA for RMP just because the business operating the refrigeration process was not doing it correctly.  I am thinking that this direction in PSM/RMP may have HUGE BUSINESS ramifications to do PSM/RMP correctly, as if a cold storage business keeps getting its tenants cited there will be a mass exit of tenants!  This specific case will NOT make it to a court room as this was settled in an agreement with EPA; and keep in mind this was a GENERAL DUTY CLAUSE citation so the cold storage process was BELOW 10,000 pounds of NH3!!!

The Facility is a frozen food storage and distribution facility, which contains anhydrous ammonia refrigeration equipment. On September 15, 16 and 20, 2011 , EPA conducted inspections at the facility to determine compliance with Section 112(r) of the Act, 42 U.S.C. § 7412(r). The 2011 Inspections revealed a number of safety concerns regarding the physical state of the anhydrous ammonia refrigeration equipment, which created the potential for an accidental release of anhydrous ammonia and/or that could increase and/or exacerbate the harmful effects of such a release.

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