OSHA Inspection: PERFORMANCE MECHANICAL, INC.

Issued

Nov 18, 2008

Abate by

Dec 21, 2008

Penalty

Initial $4,000 · Current $4,000

General-duty citation text

5189(f)(1)(A).   Process Safety Management of Acutely Hazardous Materials.
Operating Procedures.
The employer shall develop and implement written procedures that provide
clear instructions
for safely conducting activities involved in each process consistent with
the process safety
information and shall address at least the following.
Steps for each operating phase:
1. Start-up;
2. Normal operation;
3. Temporary operations as the need arises;
4. Emergency operations, including emergency shutdowns, and who may
initiate these
procedures;
5. Normal shutdown; and,
6. Start-up following a turnaround, or after an emergency shutdown.
Instance 1: Unit 234 - The employer failed to establish written procedures
for
an electric
pump shutdown.
Instance 2: Unit 234 - The employer failed to establish written procedures
for a steam
pump shutdown.
Instance 3: Unit 234 - The employer failed to establish written procedures
for moyno
pump shutdown.
Instance 4: Unit 236 - The employer failed to establish written procedures
for F101
startup.
Instance 5: Unit 236 - The employer failed to establish written procedures
for F-10
startup.
Instance 6: Unit 236 - The employer failed to establish written procedures
for E-3201
startup
Instance 7: Unit 236 - The employer failed to establish written procedures
for E-3201
startup.
Instance 8: Unit 236 - The employer failed to establish written procedures
for F-506 &
F-507 startup.
Instance 9: Unit 238 - The employer failed to establish written procedures
for PLC/HMI
control system shutdown.
Instance 10: Unit 238 - The employer failed to establish written
procedures for E-104
fan startup.
Instance 11: Unit 240 - The employer failed to establish written
procedures for G-214
charge pump shutdown procedure.
Instance 12: Unit 240 - The employer failed to establish written
procedures for G-201
shutdown.
Instance 13: Unit 110 Hydrogen Plant NSOP-204-110 Revision 2 Air Freeing
the
Hydrogen Plant for Start UP - The employer's written procedures step 1.7
require
employees to use a gas detector to check for oxygen at the boundary vent.
The
boundary vent does not exist.
Instance 14: Unit 110 Hydrogen Plant NSOP-204-110 Revision 2 Air Freeing
the
Hydrogen Plant for Start UP - The employer's written procedures step 1.11,
step 2.7,
step 3.7.1, step 4.6, and step 5.8 require employees to check for oxygen
content after
purging with nitrogen.  The written procedures fail to provide warnings to
employees
that nitrogen is an asphyxiation hazard.
Instance 15 Unit 244 NSOP-901-244 Air Freeing 5F-527 D506 Overhead Liquid
Chlorine
Absorber.  The employer's written procedure step 5.0 requires employees to
check for
oxygen content after purging with nitrogen.  The written procedures fail
to
provide
warnings to employees that nitrogen is an asphyxiation hazard.
Instance 16: Unit 244 NSOP 201-244 5G-520 and 5SCR-501 Startup.  The
employer's
written procedures step 8.1 requires employees to set 5HIC508 to the
closed position.
The hand wheel for the HIC 508 actuator is labeled backwards (The
indicated open
direction closes the dampener and vice versa).
Instance 17: Unit 244 NSOP 201-244 5G-520 and 5SCR-501 Startup.  The
employer's
written procedures step 14.14 requires employees to close 5FIC101.
5FIC1010 is not
labelled.
Instance 18: Unit 244 NSOP 201-244 5G-520 and 5SCR-501 Startup.  The
employer's
written procedures step 18 requires employees to read the Magelis display.
The Magelis
display is not visible in daytime due to its low brightness.
Instance 19: Unit MP-30 ESOP-101-MP Emergency Shutdown on F-204 Dry End
High
Level.  The employers written procedures step 5.0 page 5 (Close LCV-308
and bring in
Uniflame) and steps 15.0 - 15.3 page 9 (Line-up Uniflame to G-400) fail to
provide clear
instructions to employees.  These steps can not be done by employees
because the
Uniflame no longer exists.
Instance 20:  Unit MP-30 ESOP-101-MP Emergency Shutdown on F-204 Dry End
HighLevel.  The employer's written procedures step 15.0 page 7 (When high
pressure natural
gas is lined up to F-305 Turn H.S. located on Unit 229 control board) and
step 22 page 10
(Line-Up high pressure natural gas to F-305) fail to provide clear
instructions to
employees.  This step can not be done by employees because F-305 is no
longer in use.