Category Archives: EPA

OSHA replaces the ChemNEP inspection protocol

Since 2011, Ammonia Refrigeration facilities with 10,000lbs. or more of Anhydrous Ammonia have been subject to ChemNEP inspections under CPL 03-00-14. OSHA has replaced this program with a new program that makes some changes: Merges the Petroleum and Chemical NEPs … Continue reading

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Trump Regulatory Freeze likely to delay EPA RMP Updates

According to a memo from Reince Priebus ( Regulatory Freeze Memo 012017 ) the EPA RMP updates are likely to be delayed: With respect to regulations that have been published in the OFR but have not taken effect, as permitted by applicable law, … Continue reading

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Merry Christmas from the EPA!

Yesterday the EPA released their long-awaited changes to the RMP rule which will take effect in roughly 60 days. (Don’t worry too much – the earliest actual compliance date for the new requirements is an additional year away and many … Continue reading

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Who is Certified / Qualified to Train Process Operators?

Variations of this question are a favorite of OSHA/EPA inspectors and generally the question is infuriating. It reminds me of the stories of medieval monks arguing over how many angels can dance on the head of a pin – it’s … Continue reading

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Region 7 Ammonia Safety Day

If you are within a couple hundred miles of Kansas City, Kansas it’s worth attending the 7th annual Region 7 Ammonia Safety Day which is held at the Kansas City Community College on May 28th, 2014. More information including the schedule and enrollment … Continue reading

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EPA RMP Executive Summary

As part of GCAP’s PSM course, we pull the publically available RMP from RTKnet.org for each facility in the class. We’ve seem some strange things in the Executive Summary and wanted to share some guidance on what exactly should and should not … Continue reading

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$205,000 fine for dumping 40 pounds of ammonia

Kodiak fish processor North Pacific Seafoods pleaded guilty Tuesday in federal court to illegally dumping ammonia into the Kodiak city sewer, while the processor’s chief engineer faces charges of his own. District Court Judge Ralph Beistline imposed $205,000 in criminal … Continue reading

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EPA goes after a cold storage, the real estate agent AND the customer leasing the space!

Complainant issued a Compliance Order to Respondent, and also to Quirch Foods Caribbean, Corp., and Caparra Realty Associates, LLC ( “the Order”) pursuant to Section 1 13 of the Act regarding the Facility. The Order required these parties to perform … Continue reading

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NRC Call – When is it necessary? When is it a good idea?

Most people involved with Ammonia Refrigeration understand that if we have an unintentional release of ammonia in excess of 100 pounds over a 24hr period, we have to report it to the National Response Center (among others) immediately or face … Continue reading

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The three levels of PSM Compliance…

I’ve always taught that there are three levels of PSM compliance. In my travels throughout the Ammonia Refrigeration Community I’ve seen facilities at every level. I’ve also found that you can fairly quickly figure out what their situation is by … Continue reading

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