OSHA Inspection: CITY BREWING COMPANY LLC

Issued

Sep 14, 2011

Abate by

Nov 15, 2011

Penalty

Initial $7,000 · Current $4,900 Reduced

General-duty citation text

29 CFR 1910.119(c)(2):   The employer did not consult with employees and
their representatives
on the conduct and development of process hazards analyses and on the
development of the other
elements of process safety management in this standard:
The employer did not consult with Ammonia Refrigeration Mechanics and
Power Plant
Operators on the development of the elements of process safety management.
ABATEMENT DOCUMENTATION REQUIRED PER 29 CFR 1903.19(d)ION

Issued

Sep 14, 2011

Abate by

Jan 31, 2012

Penalty

Initial $7,000 · Current $4,900 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B):  Process safety information pertaining to the
equipment in the
process did not include the piping and instrument diagrams (P&ID'S):
The P&IDs for the ammonia refrigeration system were not accurate to the as
built condition of
the system, including but not limited to:
a) Frick #1 compressor, 1 1/2" LIOC line;
b) Frick #1 compressor, 1/2" PO line;
c) Frick #1 compressor, pressure relief valve on shell and tube oil cooler;

Issued

Sep 14, 2011

Abate by

Oct 31, 2013

Penalty

Initial $7,000 · Current $4,900 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii):  The employer did not document that the
equipment in the process
complied with recognized and generally accepted good engineering practices:
The employer did not document that the equipment in process complied with
recognized and
generally accepted good engineering practices.
a) Nameplates or labels were not affixed to the Vilter compressors.
b) No provisions were provided for irrigation facilities for eyes near the
rooftop condensers.
c) Compressors and boilers are located in vicinity of each other.
ABATEMENT DOCUMENTATION REQUIRED PER 29 CFR 1903.19(d)ION

Issued

Sep 14, 2011

Abate by

Sep 19, 2011

Penalty

Initial $7,000 · Current $4,900 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly
address the team's
findings and recommendations; assure that the recommendations are resolved
in a timely manner
and that the resolution is documented; document what actions are to be
taken; complete actions
as soon as possible; develop a written schedule of when these actions are
to be completed;
communicate the actions to operating, maintenance and other employees
whose work assignment
are in the process and who may be affected by the recommendations or
actions:
The employer did not establish a system to promptly address the process
hazard
analysis team's
findings and recommendations; assure that the recommendations were
resolved in a timely
manner and that the resolution was documented; document what actions were
taken; complete
actions as soon as possible; developed a written schedule of when these
actions were to be
completed; communicated the actions to operating, maintenance and other
employees whose
work assignment are in the process and who may be affected by the
recommendations or actions.
a) 2006 Process Hazard Analysis Recommendations
b) 2008 Process Hazard Analysis Recommendations
ABATEMENT DOCUMENTATION REQUIRED PER 29 CFR 1903.19(d)ION

Issued

Sep 14, 2011

Abate by

Sep 27, 2011

Penalty

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

General-duty citation text

29 CFR 1910.119(h)(2)(i):  The employer, when selecting a contractor, did
not obtain and
evaluate information regarding the contract employer's safety performance
and programs:
The employer did not obtain and evaluate information regarding Modern
Mechanical,
LLC, safety performance.

Issued

Sep 14, 2011

Abate by

Oct 15, 2011

Penalty

Initial $7,000 · Current $4,900 Reduced

General-duty citation text

29 CFR 1910.119(i)(1):  The employer did not perform a pre-startup safety
review for modified
facilities when the modification was significant enough to require a
change in the process safety
information:
The employer did not perform a pre-startup safety review for modifications
to the ammonia
refrigeration system facilities that require a change to the process
safety information.
a) Installation of new flooded air handlers in government cellars
b) Recirculation package and evaporator installed in #74 Cellar
c) Installation of Condensers #5 and #6.
d) Glycol Chiller - Loop A - The replacement of the control group, float
sensor replaced,
backflow preventer installed, PLC installed, oil pot installed, new
pressure relief valve installed.
ABATEMENT DOCUMENTATION REQUIRED PER 29 CFR 1903.19(d)ION

Issued

Sep 14, 2011

Abate by

Nov 30, 2012

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(j)(5):  The employer did not correct deficiencies in
equipment that were
outside acceptable limits (as defined by process information in 29 CFR
1910.119(d) before
further use or in a safe and timely manner:
The employer did not correct deficiencies in the ammonia refrigeration
equipment that were
outside acceptable limits before further use or in a safe and timely
manner.
a) Rusted, pitted and corroded piping were in use in various areas
including, but not limited to,
Loop A Chiller, Loop B Chiller, Loop C Chiller, oil knock out pots for
Vilter compressors,
liquid ammonia line to the Keg Room.
b) Pressure relief valves were not replaced at least every 5 years in
various areas, including but
not limited to, Beer Cooler 7 oil pot, Loop B Chiller oil pot, Loop C
Chiller oil pot, Cooler 6
oil pot.
ABATEMENT DOCUMENTATION REQUIRED PER 29 CFR 1903.19(d)ION

Issued

Sep 14, 2011

Abate by

Sep 27, 2011

Penalty

Initial $7,000 · Current $4,900 Reduced

General-duty citation text

29 CFR 1910.119(l)(1):  The employer did not establish and implement
written procedures to
manage changes to process chemicals, technology, equipment, and
procedures; and, changes to
facilities that affect a covered process:
The employer did not conduct a management of change to manage changes to
the ammonia
refrigeration system.
a) 8A Header removal
b) Removal of Condenser #11
c) Removal of two air handling units in Cellar 69
d) Removal of Condenser #7, #8, #9 and #10
e) Throughput changes for the system.
ABATEMENT DOCUMENTATION REQUIRED PER 29 CFR 1903.19(d)ION

Issued

Sep 14, 2011

Abate by

Sep 27, 2011

Penalty

Initial $7,000 · Current $4,900 Reduced

General-duty citation text

29 CFR 1910.119(o)(1):  The employer did not certify that they had
evaluated compliance with
the provisions of 29 CFR 1910.119 at least every three years to verify
that
the procedures and
practices developed under this standard were adequate and are being
followed:
The employer had not conducted a compliance audit on the ammonia
refrigeration
system.
ABATEMENT DOCUMENTATION REQUIRED PER 29 CFR 1903.19(d)ION

Issued

Sep 14, 2011

Abate by

Aug 31, 2014

Penalty

Initial $7,000 · Current $4,900 Reduced

General-duty citation text

29 CFR 1910.120(q)(1): An emergency response plan was not developed and
implemented to
handle anticipated emergencies prior to the commencement of emergency
response operations.
An emergency response plan was not implemented to handle anticipated
emergencies
involving the release of anhydrous ammonia.
ABATEMENT DOCUMENTATION REQUIRED PER 29 CFR 1903.19(d)ION

Issued

Sep 14, 2011

Abate by

Jan 13, 2014

Penalty

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

General-duty citation text

29 CFR 1910.147(c)(4)(i): Procedures were not developed, documented and
utilized for the
control of potentially hazardous energy when employees were engaged in
activities covered by
this section:
The employer did not develop machine specific lockout/tagout procedures
for the
ammonia refrigeration evaporators/cooling units.
ABATEMENT CERTIFICATION REQUIRED PER 29 CFR 1903.19(c)ION

Issued

Sep 14, 2011

Abate by

Jan 13, 2014

Penalty

Current $4,900

Issued

Sep 14, 2011

Abate by

Apr 30, 2014

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(j)(4)(i):  Inspections and tests were not performed on
process equipment to
maintain its mechanical integrity:
Inspections and tests were not performed on the ammonia refrigeration
process equipment to
maintain its mechanical integrity.
a) Vilter reciprocating compressor, high pressure safety cut outs
b) Vilter reciprocating compressor, low suction safety cut out
c) Inspection of external conditions including vent lines for pressure
relief devices
d) Testing of all solenoid valves
e) Inspection of seals on normally open valves
f) Inspection and cleaning of filters and strainers
g) York vertical compressor inspection, per manufacturer's service manual
ABATEMENT DOCUMENTATION REQUIRED PER 29 CFR 1903.19(d)ION

Issued

Sep 14, 2011

Abate by

Sep 27, 2011

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(j)(5):  The employer did not correct deficiencies in
equipment that were
outside acceptable limits (as defined by process information in 29 CFR
1910.119(d) before
further use or in a safe and timely manner:
The employer did not correct deficiencies in the ammonia refrigeration
equipment that were
outside acceptable limits before further use or in a safe and timely
manner.
a) Rusted, pitted and corroded piping were in use in various areas
including, but not limited to,
Loop A Chiller, Loop B Chiller, Loop C Chiller, oil knock out pots for
Vilter compressors,
liquid ammonia line to the Keg Room.
b) Pressure relief valves were not replaced at least every 5 years in
various areas, including but
not limited to, Beer Cooler 7 oil pot, Loop B Chiller oil pot, Loop C
Chiller oil pot, Cooler 6
oil pot.
ABATEMENT DOCUMENTATION REQUIRED PER 29 CFR 1903.19(d)ION

Issued

Sep 14, 2011

Abate by

Apr 30, 2014

Penalty

Initial $7,000

Issued

Sep 14, 2011

Abate by

Oct 15, 2012

Penalty

Initial $7,000 · Current $4,900 Reduced

Issued

Sep 14, 2011

Abate by

Oct 15, 2012

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.120(q)(6)(iii)(A): Employees who participated or were expected
to participate, as
hazardous material technicians had not received at least 24 hours of
training equal to the first
responder operations level and/or had not been certified as having such
training and/or in
addition did not have competency to know how to implement the employer's
emergency response
plan:
Employees who were expected to respond in an emergency response as
hazardous
material technicians had not received training nor could demonstrate
competency.
ABATEMENT DOCUMENTATION REQUIRED PER 29 CFR 1903.19(d)ION

Issued

Sep 14, 2011

Abate by

Oct 31, 2011

General-duty citation text

29 CFR 1910.1001(j)(3)(v): At the entrance to mechanical rooms/areas in
which employees
reasonably can be expected to enter and which contain ACM and/or PACM, the
building owner
did not post signs which identify the material which is present, its
location, and appropriate work
practices which, if followed, will ensure that ACM and/or PACM will not be
disturbed:
The employer did not post signage at the entrance of mechanical
rooms/areas which contain
ACM and/or PACM.
a) Glycol chiller Room/area
b) Compressor Room/area
ABATEMENT CERTIFICATION REQUIRED PER 29 CFR 1903.19(c)ION

Issued

Sep 14, 2011

Abate by

Mar 31, 2013

General-duty citation text

29 CFR 1910.119(f)(3):  The employer did not certify annually that the
operating procedures
are current and accurate:
The employer failed to certify on an annual basis that the Ammonia
Refrigeration
Operating Procedures are current and accurate.
ABATEMENT CERTIFICATION REQUIRED PER 29 CFR 1903.19(c)ION