OSHA Inspection: TRANS TEXAS GAS CORPORATION RIG #32

Issued

Apr 26, 1996

Abate by

Apr 30, 1996

Penalty

Initial $7,000 · Current $5,250 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized hazards that
were causing or likely to cause death or serious physical harm to
employees in that employees
were exposed to fire and explosion:
Employees were exposed to the hazards of fire and explosion resulting from
a
well blowout which occurred on November 3, 1995, at the Hinojosa #1 on FM
2360, Starr County, eleven and one-half (11-1/2) miles east on Hwy. 83, Rio
Grande City, TX on Trans Texas Gas Corporation Rig #32.  The employer
failed
to implement well control procedures and practices as identified by API
RP54-92,
Page 11, Section 5, Sub-Section 5.4, Paragraph 5.4.7 and "Statewide Rules
for
Oil and Gas and Geothermal Operations", Railroad Commission of Texas: 3.13,
Rule (c)(2)(b).
a.The employees did not have an adequate understanding of and were not
able to operate the blowout preventer system on November 3, 1995, in
that no one activated the blowout preventer system as required by API
RP54-92, Page 11, Section 5, Sub-Section 5.4, Paragraph 5.4.7 during the
well blowout.
b.The employer did not test the blowout preventers with the frequency
required by "Statewide Rules for Oil and Gas and Geothermal
Operations", Railroad Commission of Texas: 3.13, Rule (c)(2)(b).
One feasible and acceptable method of abatement to assure well control at
all
times is to have:
1.Designated regular personnel have an understanding of and be able to
operate the blowout preventer equipment.
2.Conducting testing of blowout preventer equipment to assure the
equipment is functioning properly by frequent tests during drilling and
well completion operations of at least once each trip for Ram-Type
preventers and Annular-Type preventers tested by closing on drill pipe
once each week.

Issued

Apr 26, 1996

Abate by

Apr 30, 1996

Penalty

Initial $7,000 · Current $4,250 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized
hazards that
were causing or likely to cause death or serious physical harm to
employees in that employees
were exposed to hazard of being struck by:
Employees were exposed to the hazard of being struck by:
a.Derrick/mast resulting from derrick collapse in that derrick/mast legs on
the north side of the rig floor did not have keeper to prevent pins from
vibrating out.  The employer failed to maintain the derrick/mast and their
auxiliary parts in safe condition as specified by API RP54-92, Page 16,
Section 8, Sub-Section 8.2, Paragraph 8.2.1 "Derricks, masts, and their
auxiliary parts shall be substantially constructed to conform to good
engineering practice and maintained in safe condition."
b.Rotary hose with the hammer connection union falling from the rotary
hose swivel.  The rotary swivel did not have a chain securing it to the lug
on the body of the swivel where the rotary hose hammer connection union
threads into the gooseneck; nor was there a chain secured to the upper
part of the rotary hose with the hammer connection union where it
connects with the standpipe, i.e. steel chain had not been secured to the
padeye which had been manufactured into the hose to prevent the rotary
hose and hammer connection union from falling.  The employer failed to
maintain the integrity and the safe operating condition of the rotary hose
swivel and the rotary hose in accord with API Specification 8A and 8C.
API Spec 8A, Eleventh Edition, May 1, 1985, Page 8, Section 5,
SubSection
5.4, Paragraph 5.4.1. Swivels having gooseneck connections of
two (2) inches and larger shall be provided with a suitable lug containing
a 1-1/8 inch hole to accommodate the clevis of a chain having a breaking
strength of 16,000 pounds.  The location of the lug is at the choice of the
manufacturer.
API Specification 8C (Spec 8C), First Edition, January 1, 1990,
Supplement 1 (January 1, 1992), Page 26, Section 7, Sub-Section 7.9,
Paragraph 7.9.6 Gooseneck Connections shall be provided with a suitable
lug containing an 1-1/2 inch (28mm) diameter hole to accommodate the
clevis of a chain having a breaking strength of 16,000 pounds (7250 kg).
The location of the lug is at choice of the manufacturer. Paragraph 7.10.5
Rotary hose safety chain attachments shall meet the requirements of
Section 7.9.6.
c.Fragmented parts of the Oteco Safety relief valve rupturing, i.e. Oteco
safety relief valve had not been maintained or inspected to determine its
operability and integrity in accord with the requirement of API RP54-92.
API RP54-92, Page 20, Section 8, Sub-Section 8.13, Paragraph 8.13.3,
"In normal operations, pumps, piping, hoses, valves, and other fittings
shall not be operated at pressures greater than their rated working
pressure
and shall be maintained in good operating condition.  Test pressures shall
not exceed the design test pressure.  Pumps, piping, hoses and safety
relief devices shall be of a design that meets requirements of the
operating
conditions to be encountered."
API RP54-92, Page 20, Section 8, Sub-Section 8.13, Paragraph 8.13.4
"Safety relief devices shall be set to discharge at a pressure equal to or
less than the rated working pressure of any pump, piping, hose or fitting
that the devices protect."
Among other methods, one feasible and acceptable abatement method to
correct
this hazard is to implement a maintenance and inspection program as
addressed
in:
API RP54-92, Section 8, Sub-Section 8.2, Paragraph 8.2.1, Page 16;
Section 8, Sub-Section 8.13, Paragraph 8.13.3 and Paragraph 8.13.4,
Page 20;  API Specification 7, Thirty-seventh Edition, August 1, 1990,
Section 17, Paragraph 17.7, Page 56;  API Spec 8A, Eleventh Edition,
May 1, 1985, Page 8, Section 5, Sub-Section 5.4;  API RP 8B, Fourth
Edition, April 1979, Page 8-10, Figure 4.11, Page C-10;  API
Specification 8C (Spec 8C), First Edition, January 1, 1990, Supplement
1 (January 1, 1992), Page 26, Section 7, Sub-Section 7.9, Paragraph 7.9.6
and Paragraph 7.10.5.
The International Association of Drilling Contractors (IADC) Drilling
Manual, Section H4, Page 1, ROTARY HOSE AND SWIVELS
INSPECTION which states, "All hoisting tools on the rotary drill rig must
have daily inspections followed by monthly and quarterly (more frequent
if severe operating conditions or loading is imposed) shutdown
inspections." and "in normal operations, pumps, piping, hoses, valves and
other fittings shall not be operated at pressures greater than their rated
working pressure and shall be maintained in good operating condition.
Test pressures shall not exceed the design test pressure.  Pumps, piping,
hoses and safety relief devices shall be of a design that meets
requirements
of the operating conditions to be encountered, such as specified by API
RP54-92, Page 20, Paragraph 8.13.3."  This alleged condition occurred
on or about November 3, 1995.ber

Issued

Apr 26, 1996

Abate by

Apr 30, 1996

Penalty

Initial $7,000 · Current $5,000 Reduced

Issued

Apr 26, 1996

Abate by

Apr 30, 1996

Penalty

Initial $7,000 · Current $5,000 Reduced

Issued

Apr 26, 1996

Abate by

Apr 30, 1996

Penalty

Initial $1,500 · Current $100 Reduced

Issued

Apr 26, 1996

Abate by

May 4, 1996

Penalty

Initial $7,000 · Current $3,000 Reduced

Issued

Apr 26, 1996

Abate by

Apr 30, 1996

Penalty

Initial $1,500 · Current $100 Reduced

Issued

Apr 26, 1996

Abate by

Apr 30, 1996

Issued

Apr 26, 1996

Abate by

May 4, 1996

Penalty

Initial $5,000 · Current $2,500 Reduced

Issued

Apr 26, 1996

Abate by

May 4, 1996

Penalty

Initial $2,500 · Current $1,000 Reduced

Issued

Apr 26, 1996

Abate by

May 4, 1996

Penalty

Initial $1,500 · Current $800 Reduced

Issued

Apr 26, 1996

Abate by

Apr 30, 1996

Penalty

Initial $70,000 · Current $6,000 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized
hazards that
were causing or likely to cause death or serious physical harm to
employees in that employees
were exposed to fire or explosion:
Employee was exposed to the hazard of fire or explosion due to the improper
rigging of the geronimo escape device:
a.Geronimo escape device being rigged on the outside of the south corner
of the pipe racking board 120 feet above ground level with no means of
safe access to the geronimo emergency escape device, i.e. employee
would have to go through unguarded opening in the outside guardrail on
the pipe racking board and climb up and across the exterior of the outside
guardrail 6 feet to the south corner of the pipe racking board in order to
use the geronimo escape line.
b.The geronimo escape line was installed improperly, i.e. in such a manner
which allowed for excessive slack which is greater than the manufacturer's
recommended 6 feet maximum.
c.The geronimo escape line was anchored improperly, i.e. geronimo escape
line was wrapped around the upper rear steel pipe support for a steel
platform 8 feet above ground level with several half hitches and the end
of the line secured to the live line with one Crosby clamp.
This occurred on or about November, 3, 1995 on Trans Texas Gas Corporation
Rig #32.  Among other methods, one feasible and acceptable abatement method
to correct this hazard would be installation of a properly rigged and
secured
emergency descent device or other satisfactory auxiliary means of egress,
such
as specified in Section 5, Sub-Section 5.7, Paragraph 5.7.1 of American
Petroleum Institute (API) RP54-92, Page 12.  Essential elements of this
procedure
would include:
1.Staking out a securely anchored one-half inch wire rope escape line
attached to the derrick or mast so as to provide a ready and convenient
means of escape from the derrickman's working platform.
2.The escape line route is to be kept clear of obstructions.
3.A safety device is to be provided to permit fast emergency exit from the
derrickman's working platform to a safe place.
4.The tension on the escape line is to be periodically checked and adjusted
to assure a safe landing and to allow the derrickman to stop 20 to 25 feet
from the anchor point.
5.The ground anchor point of the escape line is to be located a minimum
lateral distance from the derrick or mast equal to the height above ground
level to the point where the escape line is fastened to the derrick or
mast.

Issued

Apr 26, 1996

Abate by

May 4, 1996

Penalty

Initial $70,000 · Current $51,000 Reduced

Issued

Apr 26, 1996

Abate by

Apr 30, 1996

Penalty

Initial $70,000 · Current $51,000 Reduced

Issued

Apr 26, 1996

Abate by

May 4, 1996

Penalty

Initial $25,000 · Current $13,750 Reduced

Issued

Apr 26, 1996

Abate by

May 4, 1996

Penalty

Initial $35,000 · Current $26,250 Reduced