OSHA Inspection: J. R. SIMPLOT COMPANY

Issued

May 3, 2011

Abate by

May 27, 2011

Penalty

Initial $5,500 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii):  The employer did not document that equipment
complied with
recognized and generally accepted good engineering practices (RAGAGEP).
a.Pipe Bridge Between 300 Sulfuric and Liquid Plant:  On or about January
5, 2011,
and at times prior thereto, the employer did not document that overhead
piping
containing anhydrous ammonia complied with RAGAGEP in that, the pipe was
observed to be shaking and swaying above a vehicle and pedestrian road.
b.Anhydrous Ammonia Atmospheric Tank:  On or about January 5, 2011, and at
times
prior thereto, the employer did not document that discharge piping
complied with
RAGAGEP in that, the height and position of the hydrostatic discharge
exposed
employees working under or in the vicinity of the discharge to anhydrous
ammonia.
c.Sulfuric Acid Plant #300:  On or about January 5, 2011, and at times
prior thereto,
the employer did not document that valve labeling complied with RAGAGEP in
that,
valve "V-021" marked on P&ID JRS-6733-F-134.2 was not labeled in the field.
d.Sulfuric Acid Plant #300:  On or about January 5, 2011, and at times
prior thereto,
the employer did not document that piping complied with RAGAGEP in that,
the
hydrostatic relief misplacement of PV-019 renders the pipe between V-015
and V-017
unprotected from over pressure.
Abatement Note:  Among other methods to comply with recognized and
generally acceptable
good engineering practices the employer may consider the following:
Ensure all piping is supported per ANSI K61.1, Requirement for the Storage
and Handling
of Anhydrous Ammonia, and ASME B31.1., Power Piping, to prevent sagging,
mechanical
injury and unusual service conditions.
Ensure discharge piping is positioned to discharge to a safe location per
API 2000, Venting
Atmospheric & Low Pressure Storage Tanks:  Nonrefrigerated & Refrigerated.
Ensure valves are labeled per ASME A13.1, Scheme for Identification of
Piping Systems.
Ensure piping is protected per ANSI K61.1, Requirements for the Storage
and Handling of
Anhydrous Ammonia.
Note:  Abatement certification and documentation are required for this
item.

Issued

May 3, 2011

Abate by

May 27, 2011

Penalty

Initial $5,500 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i):  The process hazard analysis did not address all
hazards
associated with the process:
a.Water Treatment Plant:  On or about January 5, 2011, and at times prior
thereto, the
process hazard analysis did not address equipment damage that may result
from
employees stepping over anhydrous ammonia piping to access the water
treatment
building.V
Note:  Abatement certification is required for this item.

Issued

May 3, 2011

Abate by

May 27, 2011

Penalty

Initial $38,500 · Current $20,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B):  Information pertaining to the equipment in
the process does
not include piping and instrument diagrams (P&IDs).
a.Outside Ammonia High Pressure Storage Tanks:  On or about January 5,
2011, and at
times prior thereto, the P&ID marked as JRS-6822-F-120.1, was not accurate
since
the P&ID indicated a pipe reduction from one inch to one-half inch and
one-quarter
inch at V-547.  The pipe reduction did not exist in the field.
b.Outside Ammonia High Pressure Storage Tanks:  On or about January 5,
2011, and at
times prior thereto, the P&ID marked as JRS-6822-F-120.1, was not accurate
since a
pipe reduction from a three inch pipe near V-574 that was observed in the
field,
was
not included on the P&ID.
c.Outside Ammonia High Pressure Storage Tanks:  On or about January 5,
2011, and at
times prior thereto, the P&ID marked as JRS-6822-F-120.1, was not accurate
since
the PV-042 on the P&ID was actually tagged as V-456 in the field.
d.Outside Ammonia High Pressure Storage Tanks:  On or about January 5,
2011, and at
times prior thereto, the P&ID marked as JRS-6822-F-120.1, was not accurate
since
the P&ID did not contain a label for a gate valve which was tagged as
V-589 in the
field.
e.Outside Ammonia High Pressure Storage Tanks:  On or about January 5,
2011, and at
times prior thereto, the P&ID marked as JRS-6822-F-120.1, was not accurate
since
the valves labeled as V-515 and V-514 on the P&ID, did not correspond to
the
identification tags observed in the field.
f.Ammonia Low Pressure Storage:  On or about January 5, 2011, and at times
prior
thereto, the P&ID marked as JRS-6825-F-161.1, was not accurate since a
pressure
valve (PV) actuator located near V-067 on the P&ID did not exist in the
field.
g.Ammonia Low Pressure Storage:  On or about January 5, 2011, and at times
prior
thereto, the P&ID marked as JRS-6825-F-161.1, was not accurate since V-067
on the
P&ID was not located in the same location in the field.
h.Ammonia Low Pressure Storage:  On or about January 5, 2011 and at times
prior
thereto, the P&ID marked as JRS-6825-F-161.8, was not accurate since a
gate valve
shown on the Unloading Line, "3" AL-901-SLA-903" did not exist in the
field.
i.Ammonia Low Pressure Storage:  On or about January 5, 2011 and at times
prior
thereto, the P&ID marked as JRS-6825-F-161.8, was not accurate since a
threaded
cap shown on the Unloading Line, "3" AL-901-SLA-903" did not exist in the
field.
j.Ammonia Low Pressure Storage:  On or about January 5, 2011 and at times
prior
thereto, the P&ID marked as JRS-6825-F-161.8, was not accurate since the
temperature indicator (TI) 6800-7349 was actually located downstream of
thetemperature element (TE) 6800-7350 on "4" AL-901-SLA-903".
k.Ammonia Low Pressure Storage:  On or about January 5, 2011 and at times
prior
thereto, the P&ID marked as JRS-6825-F-161.8, was not accurate since a pipe
reduction from three inches to one-quarter inch shown between V-056 and
V-055 did
not exist in the field.
l.Ammonia Low Pressure Storage:  On or about January 5, 2011 and at times
prior
thereto, the P&ID marked as JRS-6825-F-161.8, was not accurate since a
temperature point (TP) shown at "AMMONIA XFER PUMP"  "JRS-6825-F-161.1"
was not labeled on the P&ID.
m.Ammonia Low Pressure Storage:  On or about January 5, 2011 and at times
prior
thereto, the P&ID marked as JRS-6825-F-161.8, was not accurate since a
temperature point (TP) shown at "RELIEF HEADER"  "JRS-6825-F-161.7" was not
labeled on either side of the P&ID.
n.Ammonium Phosphate Plant #100-Granualtion:  On or about January 5, 2011,
and at
times prior thereto, the P&ID marked as JRS-7011-F-122, was not accurate
since
valves labeled V-763 and V-764 on the P&ID, did not correspond to the
identification
tags observed in the field.
o.Ammonium Phosphate Plant #100-Granualtion:  On or about January 5, 2011,
and at
times prior thereto, the P&ID marked as JRS-7011-F-122, was not accurate
since the
P&ID did not indicate a pipe containing a gate valve and check valve which
were
located between V-763 and V-764 in the field.
p.Ammonium Phosphate Plant #100-Granualtion:  On or about January 5, 2011,
and at
times prior thereto, the P&ID marked as JRS-7011-F-122, was not accurate
since the
valve labeled as VR-053 on the P&ID, did not correspond to the
identification tag of
VR-052 observed in the field.
q.Ammonium Phosphate Plant #100-Granualtion:  On or about January 5, 2011,
and at
times prior thereto, the P&ID marked as JRS-7011-F-122, was not accurate
since the
P&ID did not contain V-768 which was observed in the field.
r.Ammonium Phosphate Plant #100-Granualtion:  On or about January 5, 2011,
and at
times prior thereto, the P&ID marked as JRS-7011-F-122, was not accurate
since V-
768 was actually located downstream from the location indicated on the
P&ID.
s.Ammonium Phosphate Plant #100-Granualtion:  On or about January 5, 2011,
and
at
times prior thereto, the P&ID marked as JRS-7011-F-122, was not accurate
since the
P&ID did not contain complete pipe labeling or size indications.  Several
pipe labels
on the P&ID contained notes such as:  "1/2 " AL-066-P??-??-?" or "?"
??-079-P???-
??-?".
t.Ammonium Phosphate Plant #100-Granulation Building:  On or about January
5,
2011, and at times prior thereto, the P&ID marked as JRS-7015-F-128.1, was
not
accurate since the valves labeled 773, 774, 783 and 784 on the P&ID, did
not
correspond to the identification tags observed in the plant.
u.Ammonia Loading Dock:  On or about January 5, 2011, and at times prior
thereto,
the P&ID marked as JRS-8555-F-100.1, was not accurate since piping labeled
as "3"
AL-SLA-904" on the P&ID was observed to be a four-inch line in the field.
The J.R. Simplot Company, was previously cited for a violation of this
occupational safety
and health standard, which was contained in inspection number 314172024,
citation 1, item
2A and was affirmed as a final order on November 8, 2010, with respect to
a workplace
located at 3630 Gateway Drive, Grand Forks, North Dakota.
Note:  Abatement certification and documentation are required for this
item.

Issued

May 3, 2011

Abate by

May 27, 2011

Penalty

Initial $15,000 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.151(c):  Where employees were exposed to injurious corrosive
materials,
suitable facilities for quick drenching or flushing of the eyes and body
were not provided
within the work area for immediate emergency use:
a.Ammonia Compressor Room.  On or about January 3, 2011 and at times prior
thereto, the emergency eyewash and shower inside the compressor room was
frozen.
Employees were changing the compressor oil and were exposed to the
anhydrous
ammonia.
b.Ammonia Railcar Unloading:  On or about January 3, 2011 and at times
prior
thereto, the emergency eyewash and shower were frozen, exposing the
employees to
anhydrous ammonia.
The J.R. Simplot Company, was previously cited for a violation of this
occupational safety
and health standard, which was contained in inspection number 311577605,
citation 2, item 2
and was affirmed as a final order on October 27, 2008, with respect to a
workplace located
at 1150 W. Highway 30, Pocatello, Idaho.
Note:  Abatement certification is required for this item.