OSHA Inspection: VEOLIA WATER NORTH AMERICA CENTRAL LLC

Issued

Feb 28, 2012

Abate by

Jul 31, 2012

Penalty

Initial $4,000 · Current $2,800 Reduced

General-duty citation text

29 CFR 1910.119(d):   The employer did not develop a written compilation
of process safety
information on hazardous chemicals in the process, the technology of the
process, and the
equipment in the process before conducting the process hazard analysis:
Employee(s) working in the water treatment plant were exposed to
asphyxiation hazards due to
the process safety information for the following equipment not being
available:
(a)no written process safety information for the chlorine ton cylinders.
(b)no written process safety information for the clear tubing being used
for chlorine gas
(c)no written process safety information for the chlorine metal piping.
(d)no written process safety information for the chlorine pvc plastic
piping (vent line).
(e)no written process safety information for the chlorine globe valves.
(f)no written process safety information for the black flexible tubing
attached to the vacuum
regulators.
(g)no written process safety information for the clear tubing being used
for the chlorine vent
line.
(h)no written process safety information for the flexible connector.
(i)no written process safety information for the lead washers.
Employee(s) were exposed to release of chlorine compounds to the
atmosphere that can lead to
death or injury to persons working in the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

Feb 28, 2012

Abate by

Mar 2, 2012

Penalty

Initial $4,000 · Current $2,800 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):
At the water treatment building, the employer had not verified that the
P&ID's
were up to date
and accurate for use by Veolia water employee(s) and contractors for line
breaks, equipment /
piping replace or repairs, and etc.  Piping circuits were evaluated and
the following was noted:
Chlorine Storage Room
(a)Yoke valves between two gate valves for each cylinder were drawn on the
p&id, but
were not observed during the walk around.
(b)A pressure gauge down stream from the ton cylinders were drawn on the
p&id, but not
observed during the walk around.
(c)A globe valve was observed above the drip leg cap(#6), but was not
drawn on the p&id.
(d)A Jamesbury ball valve was observed downstream of drip leg (#6), but
was not drawn
on the p&id.
(e)A flange coupling with a lead washer was observed between the pressure
reducer and the
Jamesbury ball valve, but not drawn on the p&id.
(f)A metal to plastic coupling was observed on the chlorine vent line that
was exiting the
Fisher Porter pressure reducer during the walk around, but not drawn on
the p&id.
(g)The vent line exiting the Fisher Porter pressure reducer was observed
during the walk
around, but not drawn on the p&id.
(h)A coupling flange downstream of the pressure reducer was observed
during the walk
around, but not drawn on the p&id.
(i)a second Jamesbury ball valve was observed during the walk around, but
not drawn on
the p&id.
(j)A second Jamesbury ball valve was observed downstream of the coupling
flange, but not
drawn on the p&id.
(k)A second drip leg downstream of the Fisher Porter pressure reducer was
observed during
the walk around, but not drawn on the p&id.
(l)A globe valve on the second drip leg downstream of the Fisher Porter
pressure reducer
was observed during the walk around, but not drawn on the p&id.
Chlorine Feed Room
(m)A flange was observed between the strainer and the drip leg upstream of
chlorinator #1,
but was not drawn on the p&id.
(n)A pressure gage upstream of chlorinator #1 was observed during the walk
around, but
not drawn on the p&id.
(o)A globe valve between the pressure gauge and drip leg (#11) for
chlorinator 1 was
observed during the walk around, but not drawn on the p&id.
(p)A heater attached to drip leg (#11) for chlorinator 1 was observed
during the walk
around, but not drawn on the p&id.
(q)A globe valve between drip leg (#11) and the vacuum regulator for
chlorinator 1 was
observed during the walk around, but not drawn on the p&id.
(r)A flange was observed between the strainer and the drip leg upstream of
chlorinator #2,
but was not drawn on the p&id.
(s)A pressure gauge upstream of chlorinator #2 was observed during the
walk around, but
not drawn on the p&id.
(t)A globe valve between the pressure gauge and drip leg (#11) for
chlorinator 2 was
observed during the walk around, but not drawn on the p&id.
(u)A heater attached to drip leg (#11) for chlorinator 2 was observed
during the walk
around, but not drawn on the p&id.
(v)A globe valve between drip leg (#11) and the vacuum regulator for
chlorinator 2 was
observed during the walk around, but not drawn on the p&id.
(w)A vent line from vacuum regulator for chlorinator 1 was observed during
the walk
around, but not drawn on the p&id.
(x)A vent line from vacuum regulator for chlorinator 2 was observed during
the walk
around, but not drawn on the p&id.
(y)A rotameter for chlorinator #1 was observed during the walk around, but
not drawn on
the p&id.
Employee(s) were exposed to release of chlorine compounds to the
atmosphere that can lead to
death or injury to persons working in the facility.
29 CFR 1903.19(c)(2) abatement of the above violation was verified at the
time of
inspection.  No certification is required.tion

Issued

Feb 28, 2012

Abate by

Jul 31, 2012

Penalty

Initial $3,000 · Current $2,100 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F):  Process safety information pertaining to the
equipment did not
include the design codes and standards employed:
At the facility, the employer did not include design codes and standards
employed in the process
safety information pertaining to equipment, including, but not limited to
the following:
(a) steel piping
(b) pvc piping
(c) black flexible tubing
(d) valves
(e) fittings
Employee(s) were exposed to release of chlorine compounds to the
atmosphere that can lead to
death or injury to persons working in the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

Feb 28, 2012

Abate by

Jul 31, 2012

General-duty citation text

29 CFR 1910.119(d)(3)(i)(C):  Process safety information pertaining to the
equipment in the
process did not include the electrical classification:
An electrical classification of the chlorine process was not provided for
the water treatment plant
where electrical equipment was being used.   The operators working inside
the chlorine storage
/ feed rooms were to fire / electrical hazards due to no evaluation being
performed to determine
if the electrical equipment operating in the chlorine process that could
possibly react with the
inadvertent release of chlorine gas.
Employee(s) were exposed to release of chlorine compounds to the
atmosphere that can lead to
death or injury to persons working in the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

Feb 28, 2012

Abate by

Jul 31, 2012

Penalty

Initial $4,000 · Current $2,800 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:
At the facility, the employer did not document that the equipment in the
process complied with
recognized and generally acceptable good engineering practices for the
following:
(a)Employee(s) working in the chlorine process were potentially exposed to
health
hazards of chlorine gas.  The chlorine gas monitors in the chlorine
storage and
feed rooms had their alarm set point at 2 parts per million, this setting
is above
the OSHA ceiling level of 1 part per million.
(b)Employee(s) working in the chlorine process were potentially exposed to
chlorine
gas health hazards due to the chlorine gas monitors in the storage and
feed room
being approximately 28 inches from the ground floor.  Industry practice is
to
locate chlorine gas monitors approximately 12 inches from the ground floor
due
to chlorine being heavier than air and if there was a leak, the chlorine
will
accumulate on the floor.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

Feb 28, 2012

Abate by

May 31, 2013

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(f)(1):  The employer did not develop and implement written
operating
procedures that provided clear instructions for safety conducting
activities in each covered
process consistent with the process safety information and which addressed
the elements listed
in 29 CFR 1910.119(f)(1)(i) through (f)(1)(iv):
(a)Employee(s) disconnecting and replacing flexible connector or black
flexible tubing for
the chlorine process were exposed to chlorine gas health hazards due to no
standard
operating procedures being developed or implemented to address cleaning
the inside of
new process piping, prior to installation in the chlorine process.
(b)At the water treatment plant a written standard operating procedure for
shutting down the
chlorine process in the event of a long term power outage were exposing
employee(s) to
potential chlorine gas health hazards due to no backup power source being
provided.  For
employee(s) required enter the chlorine storage and feed rooms to shut
down the chlorine
process, there would be no power to turn on the ventilation system prior
to entry nor
would the operators have access to the chlorine gas detection monitors.
(c)At the water treatment plant a written standard operating procedure for
changing one ton
chlorine cylinders was inadequate due to the facility manager or the
site/project safety
coordinator not being present during a ton cylinder change out at all
times according to
the ton cylinder change out procedure.
Employee(s) were exposed to release of chlorine compounds to the
atmosphere that can lead to
death or injury to persons working in the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

Feb 28, 2012

Abate by

May 31, 2013

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(j)(2):  The employer did not establish and implement
written procedures to
maintain the on-going mechanical integrity of process equipment:
(a)The employer did not develop and implement a procedure for evaluating
flexible
connectors that were to be changed out annually to determine if the annual
replacement policy was adequate.
(b)The employer did not develop and implement a procedure for evaluating
valves
in the chlorine process.
(c)The employer did not develop and implement a procedure for conducting
non-
destructive testing on pressurized metal piping.
(d)The employer did not develop and implement a procedure for evaluating
metal
pipe supported by ceiling hangars for metal to metal corrosion.
(e)The employer did not develop and implement a procedure for evaluating
the black
flexible tubings that processes chlorine from the rotameter to the
ejectors.
Employee(s) were exposed to release of chlorine compounds to the
atmosphere that can lead to
death or injury to persons working in the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

Feb 28, 2012

Abate by

May 31, 2013

Penalty

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

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:
Employee(s) working in the water treatment plant were exposed to health
hazards due to the
following equipment not receiving mechanical integrity inspections:
(a)there were no mechanical integrity inspection records for the metal
piping in the
chlorine storage room.
(b)there were no mechanical integrity inspection records for the metal
piping in the
chlorine feed room.
(c)there were no mechanical integrity inspection records for the chlorine
manifold
system in the storage room.
(d)there were no mechanical integrity inspection records for the pvc vent
piping in
the chlorine storage and chemical feed rooms.
(e)there were no mechanical integrity inspection records for the black
flexible
tubings that are attached to the vacuum regulators, rotameters, and the
ejectors.
Employee(s) were exposed to release of chlorine compounds to the
atmosphere that can lead to
death or injury to persons working in the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement
of the
above violation is completed.

Issued

Feb 28, 2012

Abate by

Jul 31, 2012

Penalty

Initial $4,000 · Current $2,800 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:
(a)At the water treatment plant, a written management of change program
had not been
developed and implemented to inform all employee(s) working in the
chlorine process
when changes to the process chemicals, technology, equipment, or
procedures have
occurred.
(b)the employer had not developed nor implemented a written management of
change
program to address changes to the chlorine process; there has been several
changes to
the program where no management of change was conducted such as the
following:
(1)No management of change for the removal of the pressure regulator #7.
(2)No management of change for the removal of the yoke valves.
(3)No management of change for the removal of the pressure gauge #8
(4)No management of change for attaching a clear plastic tubing to the
second pvc
plastic vent line entering the chlorine feed room.
Employee(s) were exposed to release of chlorine compounds to the
atmosphere that can lead to
death or injury to persons working in the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

Feb 28, 2012

Abate by

Jul 31, 2012

Penalty

Initial $3,000 · Current $2,100 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:
(a)  In the 2010 compliance audit the employer did not address the
following:
(1)Process Hazard Analysis item number 11
(2)Contractors item number 22
(3)Contractors item number 23
(4)Contractors item number 24
(b) The employer did not complete a compliance audit every 3 years to
determine if the
procedures and practices established for the processes covered by the
process safety management
standard were being followed.  There was no compliance audit conducted
prior to 2010.
Employee(s) were exposed to release of chlorine compounds to the
atmosphere that can lead to
death or injury to persons working in the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

Feb 28, 2012

Abate by

May 31, 2013

General-duty citation text

29 CFR 1910.119(o)(4):  The employer did not determine and document an
appropriate response
to each of the findings of the compliance audit required by 29 CFR
1910.119(o)(1),
and
document that the deficiencies had been corrected:
Employee(s) working in the water treatment building were exposed to health
hazards associated
with chlorine vapors in that the employer had not documented corrective
actions pending or
taken in relation to each of the deficiencies documented in the 2010
compliance audit such as
but not limited to the following:
(a)an evaluation of the consequences of deviations for the technology of
the process
(b)the PHA did not address previous incidents with likely potential for
catastrophic
consequences
(c)written procedures to maintain the on-going integrity of process
equipment and
documentation that indicate the procedures have been implemented.
(d)documented each inspection and test has been performed on process
equipment.
(e)developing a report of the findings for each compliance audit
(f)has the employer promptly determined and documented an appropriate
response
to each of the compliant audit findings
(g)documented that deficiencies noted in 2010 compliance audit has been
corrected
Employee(s) were exposed to release of chlorine compounds to the
atmosphere that can lead to
death or injury to persons working in the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.