OSHA Inspection: NEW ENGLAND WOOD PELLET, LLC

Issued

Apr 18, 2012

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.22(a)(1) Places of employment were not kept clean and orderly:    A  Layers of combustible wood dust were allowed to accumulate to depths and over surface areas in quantities that exposed workers to fire &/or explosion hazards    1. Hammer Mill Room [which also contains other process equipment]:  excessive amounts of combustible wood dust had accumulated:  "	on top of overhead I-beams, which resulted in dust fires in 2 I-beam locations on October 20, 2011  "	inside the troughs of horizontal steel girts running along the building wall  "	inside the troughs of the ceiling joists  "	on the floor   "	on top of belt conveyor transporting combustible wood dust into the KD Hammer Mill    2. Dryer Room [which also contains other process equipment]: excessive amounts of combustible wood dust had accumulated:  "	on the process equipment  "	on overhead horizontal surfaces    3. Production Room [which also contains other process equipment]:  excessive amounts of combustible wood dust had accumulated:  "	on the process equipment, such as the exterior surface of the pellet cooler where the dust ignited  "	on overhead and wall horizontal surfaces, where in one location it ignited in a fireball    B.  When combustible wood dust was cleared from surfaces, the employer used cleaning methods that increased the potential for a combustible dust deflagration and/or explosion:  "	the employer used 30 psi compressed air to blowdown and clear combustible wood dust    Note:  See NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, 11.2.1.1, regarding Removal of Dust states in part:  Surfaces shall be cleaned in a manner that minimizes the generation of dust clouds.  Blowing down with steam or compressed air or even vigorous sweeping shall be permitted only if the following requirements are met:&(3) Only a low gauge pressure of 103kPa (15psi) steam or compressed air shall be used.

Issued

Apr 18, 2012

Abate by

Jun 1, 2013

Penalty

Initial $70,000 · Current $50,000 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 in that employees were exposed to wood dust explosions, deflagrations, and fire hazards due to deficient design and/or implementation of preventive and/or protective measures in its wood pellet processing system and related equipment, such as the following:      Instance A - Pellet Mills to the Pellet Cooler:     The transport system that carried newly-made, still-hot wood pellets (and residual dust) from each of the 4 Pellet Mills over to the Pellet Cooler had no spark detection, fire suppression, and fire isolation devices, and no other effective methods, to prevent any sparks, embers or fires in the wood pellets (or their residual dust) from spreading to the Pellet Cooler and endangering workers.   On October 20, 2011, these deficiencies initiated a series of fires and explosions when a problem in Pellet Mill #3 caused a spark or ember to travel from Pellet Mill #3 along a collection conveyor, up a bucket elevator, then along a second conveyor and into the Pellet Cooler, where wood pellets ignited and caused a major fire.      Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:   Performance of a hazard determination as set forth in 8.2.1 and implementation of the resulting recommendations.    and    8.2.4.1 which provides that conveying systems with fire hazards shall be isolated to prevent propagation of fire both upstream and downstream.  [OSHA Note: Isolation in this context means both effective spark detection and suppression]   and   "5.2.5.1  Prevention of Fire Extension.  When limitation of fire spread is to be achieved, the following criteria shall be demonstrated  (4) Particulate processing systems shall be designed, constructed, equipped, and maintained to prevent fire or deflagration from propagating from one process system to an adjacent process system."      Instance B - Pellet Cooler to Silo #5 (pellet storage silo):     The conveyor and bucket elevator transport system that carried wood pellets from the Pellet Cooler into the storage silo (Silo #5) had no spark detection, fire suppression, and fire isolation devices, and no other effective methods, to prevent any sparks, embers or fires in the wood pellets (or their residual dust) from spreading to Silo #5 and exposing workers to fire/explosion hazards.     Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:   Performance of a hazard determination as set forth in 8.2.1 and implementation of the resulting recommendations.   and    8.2.4.1 which provides that conveying systems with fire hazards shall be isolated to prevent propagation of fire both upstream and downstream.  [OSHA Note: Isolation in this context means both effective spark detection and suppression]   and   "5.2.5.1  Prevention of Fire Extension.  When limitation of fire spread is to be achieved, the following criteria shall be demonstrated  (4) Particulate processing systems shall be designed, constructed, equipped, and maintained to prevent fire or deflagration from propagating from one process system to an adjacent process system."       Instance C - Pellet Cooler to Pellet Cooler Dust Collector:    The dust collection duct that carried wood pellet dust from the Pellet Cooler to the Pellet Cooler Dust Collector (which received combustible wood pellet dust and recycled it back into the process as material for new pellets) had no spark detection and no fire suppression devices, and no other effective methods to prevent any sparks, embers or fires in the combustible wood pellet dust from spreading to the indoor Pellet Cooler Dust Collector, where a fire or explosion would endanger workers.   On October 20, 2011, the absence of any spark detection or fire suppression etc. devices in the duct enabled a fire in the Pellet Cooler to travel and spread through the ductwork to the indoor Pellet Cooler Dust Collector, which exploded.    Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:   Performance of a hazard determination as set forth in 8.2.1 and implementation of the resulting recommendations.   and    "8.2.2.2.2 - Ducts with a Fire Hazard.  Ducts conveying dry material released by equipment having a high frequency of generated sparks [or embers etc.] shall be designed and constructed in accordance with one of the following:   (1) Equipped with a listed spark detection and extinguishing system installed downstream from the last material entry point and upstream of any collection equipment.   (2) Equipped with a listed spark detection system actuating a high-speed abort gate, provided the abort gate can operate fast enough to intercept and divert burning embers to atmosphere before they can enter any collection or storage equipment."        Instance D - Pellet Cooler to Pellet Cooler Dust Collector:     On the dust collection duct that carried wood pellet dust from the Pellet Cooler to the Pellet Cooler Dust Collector, the portion of ductwork running between the Rembe explosion isolation device and the Pellet Cooler Dust Collector was not constructed with sufficient strength to maintain its integrity in the event of an explosion of the combustible wood pellet dust it was designed to transport; and it had no other effective means (such as explosion suppression or explosion relief vents) to protect workers from fire/explosion hazards in the event that an explosion occurred.   On October 20, 2011, when an explosion of wood pellet dust in the Pellet Cooler Dust Collector blew back into the ductwork, the duct burst open and released the pressure of the explosion/deflagration inside the building, near the firefighters who were responding to the multi-alarm fire call at the establishment.      Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:      Performance of a hazard determination as set forth in 8.2.1 and implementation of the resulting recommendations.     and    8.2.2.2.3, which sets forth alternative safety criteria for ducts with a deflagration (i.e. explosion) hazard, to ensure that the ducts are built with sufficient strength and with appropriately sized/placed protective devices  (e.g. explosion pressure relief vents, listed explosion suppression systems, flame-quenching devices) to handle the maximum expected pressure generated by a dust explosion.           Instance E - Pellet Cooler Dust Collector:    The Pellet Cooler Dust Collector, which was located indoors and was designed to collect combustible wood pellet dust, was constructed without effective protection for workers from the risks of fire, explosion, and fireball temperature and pressure, in that it was constructed:   1.	without sufficient strength to maintain withstand the maximum unvented pressure of a combustible wood pellet dust explosion;    2.	without an explosion suppression system; and    3.	with an explosion relief vent that was improperly designed, inadequately sized, and located so as to vent onto and involve adjacent structures (Silo # 4, containing combustible wood pellet dust, and Silo #5, containing wood pellets).    On October 20, 2011, when fire traveled through ductwork from the Pellet Cooler and initiated a wood pellet dust fire/explosion in the indoor-located Pellet Cooler Dust Collector:   	The explosion blew the Dust Collector's door off its hinges, making it a missile hazard.   	The explosion blew backwards into the duct, which burst open.   	The explosion blew out to the adjacent muffler and roof stack, causing the muffler to burst open and release the pressure of the explosion/deflagration inside the building, near responding firefighters.   	The explosion also blew out through the Dust Collector's undersized, unsafely positioned explosion relief vent and onto Silo #4 (containing combustible wood pellet dust) and Silo #5 (containing wood pellets), igniting fires in both of these Silos.      Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities and in NFPA 69 (2008) Explosion Prevention Systems, such as:   Performance of a hazard determination as set forth in NFPA 664, 8.2.1 and implementation of the resulting recommendations.    and   NFPA 664, 8.2.2.5.1.4, which requires an outdoor location for dust collectors with fire or deflagration hazards, unless they are equipped with e.g. one of the following:   "(4)listed deflagration suppression system   (5)deflagration relief vents with relief pipes extending to safe areas outside the building and the collector meets the strength requirement of this standard [i.e. built with sufficient strength to withstand the maximum expected explosion pressure]    (6)deflagration relief vents exhausting through listed flamed-quenching devices and the collector  meets the strength requirement of this standard [i.e. built with sufficient strength to maintain withstand the maximum expected explosion pressure ]"   and    NFPA 664, 8.2.2.5.3, which requires that dust collectors with deflagration (explosion) hazards be equipped with an appropriate-sized explosion suppression system &/or explosion relief vent system designed as per NFPA 68 (Explosion Protection by Deflagration Venting) and NFPA 69 (Explosion Prevention Systems), and also that the such dust collectors  be built to a design strength that exceeds the maximum expected explosion pressure of the material being collected (with appropriate adjustments for the effects of explosion suppression or relief vent systems).    and    NFPA 69, 12.1.2, which requires that "Piping, ducts and enclosures protected by an isolation system shall be designed to withstand estimated pressures as provided by the isolation system manufacturer;"     and     NFPA 69, 12.2.2.2, "Float Design Criteria", which sets forth the design criteria for float valves in devices to control deflagration by passive isolation means.    and     NFPA 69, 12.2.2.3, "System Verification", which requires that "The float valve system shall be of a design that has been verified by appropriate testing under deflagration conditions to demonstrate performance."        Instance F  Hammer Mills:     In the Hammer Mill Room, Hammer Mills with deflagration (explosion) hazards were not equipped with either explosion suppression or explosion venting, were not constructed to withstand expected explosion pressure, and they were located indoors in a room with other equipment and an office, exposing workers to fire and explosion hazards:   1.	The KD (kiln dried wood) Hammer Mill    2.	The Dried Green Material Hammer Mill    3.	The Burner Fuel Hammer Mill     Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:     "8.4.2.1 Hazard Analysis.  The fire and deflagration potential of each piece of particulate size reduction machinery shall be determined by a hazard analysis as outlined in 8.4.1", which details the physical properties to be included in the hazard analysis and design criteria.     and   "8.4.2.4.1 Size reduction equipment shall be located outdoors. Exception: Size reduction equipment shall be permitted indoors if located in a detached building or separated from other production areas by damage-limiting construction."   and   "8.4.2.4.2 Size reduction equipment shall be constructed in accordance with one of the following:    (1)  An enclosure shall be constructed of welded steel or other noncombustible material of sufficient strength to withstand the maximum unvented explosion pressure of the processed material.   (2)  An enclosure shall be constructed of noncombustible material, protected by a listed explosion suppression system with a design strength exceeding the maximum reduced explosion pressure of the processed material.   (3)  An enclosure constructed of noncombustible material, equipped with adequate deflagration relief vents having relief pipes extending outdoors or discharged through listed flame-quenching devices, shall have a design strength exceeding the maximum reduced explosion pressure of the processed material."        Instance G Dust Collectors:      Dust collectors with explosion hazards were located indoors, had no explosion suppression systems and were equipped with improperly designed, inadequately sized and/or unsafely located explosion relief vents.   1.	KD (kiln dried wood) Dust Collector located in Covered Green Area Building, and the ductwork associated with it   2.	KD (kiln dried wood) Dust Collector located in Hammer Mill Room   3.	Cyclone #1 located in Dryer Room   4.	Cyclone #2 located in Dryer Room   5.	Cyclone #3 located in Dryer Room   6.	Cyclone #4 located in Dryer Room   7.	Cyclone #5 located in Dryer Room   8.	Cyclone #6 located in Dryer Room   9.	Dried Green Dust Collector located in Hammer Mill Room   [Instance E already notes these deficiencies as to the Pellet Cooler Dust Collector]      Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:   Performance of a hazard determination as set forth in 8.2.1 and implementation of the resulting recommendations.    and     8.2.2.5.1.4, which requires an outdoor location for these dust collectors with fire or deflagration hazards, unless they are equipped with one of the following:   "(4)... listed deflagration suppression system;   (5)... deflagration relief vents with relief pipes extending to safe areas outside the building and the collector meets the strength requirement of this standard   (6) deflagration relief vents exhausting through listed flamed-quenching devices and the collector meets the strength requirement of this standard [i.e. built with sufficient strength to maintain withstand the maximum expected explosion pressure] "   and   8.2.2.5.3, which requires that dust collectors with deflagration (explosion) hazards be equipped with an appropriate-sized explosion suppression system &/or explosion relief vent system designed as per NFPA 68 (Explosion Protection by Deflagration Venting) and NFPA 69 (Explosion Prevention Systems).        Instance H  Conveyor Systems:      Conveyor systems with fire and deflagration hazards had no effective isolation methods to prevent the spread of fire and explosion to other equipment and occupied areas, where employees would be exposed to serious injury or death:   1.	Covered Green Area Building- Conveyor to the KD Storage Bin, which holds kiln-dried wood chips and dust   2.	Covered Green Area Building and Hammer Mill Room - Conveyor from KD (kiln dried wood) Storage Bin carrying wood chips and dust to the KD (kiln dried wood) Hammer Mill and KD (kiln dried wood) Dust Collector (located in the Hammer Mill Room)     3.	Hammer Mill Room to the outside  Conveyor from KD (kiln dried wood) Hammer Mill and its Dust Collector carrying reduced wood particles and dust to Silos # 1, 2 and 3 (for storage and transit to Production Room)    4.	Hammer Mill Room to the outside  Conveyor from Dried Green Hammer Mill and its Dust Collector to the Burner Fuel Bin (for  fuel to heat the Rotary Dryer that dries wet green wood chips) and to Silo #4  (for storage and transit to Production Room).   5.   Covered Green Area Building - Cyclones to KD (kiln dried wood) storage bin and/or dried green hammermill/dust collector Conveyor     Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:      Performance of a hazard determination as set forth in 8.2.1 and implementation of the resulting recommendations.    and    8.2.4.1 which provides that conveying systems with fire hazards shall be isolated to prevent propagation of fire both upstream and downstream.  [OSHA Note: Isolation in this context means effective spark detection and suppression]         Instance I - Rotary Dryer Ineffective Inspections:    The employer provided no means to make effective inspections on a regular basis of its three-pass rotary dryer, which inspections would show whether cleaning was necessary to keep combustible dust and resin deposits to a minimum, in order to prevent potential fire and explosion.    Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:   "8.6.2.3. The interior of the dryer shall be regularly inspected and cleaned, if necessary, to keep combustible deposits to a minimum."        Instance J - Rotary Dryer Location:      The Rotary Dryer which had deflagration hazards was located in the Dryer Room where there were no effective methods to prevent employees from being exposed to serious injury or death from explosion and fire.    Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:   "8.6.2.1 Rotary dryers having a deflagration hazard shall be located in one of the following places:   	(1) Outdoors  	(2) In a separate detached building  	(3) In a separate cutoff room with damage-limiting construction."          Instance K - Covered Green Area Building, vicinity of Kiln Dried Wood Hopper Bin and Dust Collector         The diesel-powered New Holland Construction Skid Steer Loader Model L180 was used near the Kiln Dried Hopper Bin, Belt Conveyor, and Dust Collector, presenting a potential fire/deflagration/explosion ignition or initiating source

Issued

Apr 18, 2012

Abate by

Apr 19, 2012

Penalty

Initial $70,000 · Current $50,000 Reduced

General-duty citation text

29 CFR 1910.307(c): Equipment, wiring methods, and installations of equipment in hazardous (classified) locations were not intrinsically safe, approved for the hazardous (classified) location, or safe for the hazardous (classified) location:     a.            Employees used 3 ordinary shop-vac vacuums to collect fugitive combustible dust from the floor and machinery.  These machines were not rated for use with combustible dust.      NEW ENGLAND WOOD PELLET, LLC. WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD, 29 CFR 1910.307(c) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 311584213, CITATION NUMBER 3, ITEM NUMBER 1, ISSUED ON JULY 22, 2008, WITH RESPECT TO A WORKPLACE LOCATED AT 141 OLD SHARON ROAD, JAFFREY, NEW HAMPSHIRE, 03452.  THE FINAL ORDER DATE FOR THE CITATION WAS ON  OR ABOUT AUGUST 5, 2008.     NEW ENGLAND WOOD PELLET, LLC. WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD, 29 CFR 1910.307(b) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 306947094, CITATION NUMBER 1, ITEM NUMBER 5, ISSUED ON DECEMBER 20, 2004, WITH RESPECT TO A WORKPLACE LOCATED AT 141 OLD SHARON ROAD, JAFFREY, NEW HAMPSHIRE, 03452.  THE FINAL ORDER DATE FOR THE CITATION WAS ON  OR ABOUT FEBRUARY 24, 2005.    NEW ENGLAND WOOD PELLET, LLC. WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD, 29 CFR 1910.307(b) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 108774506, CITATION NUMBER 1, ITEM NUMBER 6, ISSUED ON FEBRUARY 9, 1996, WITH RESPECT TO A WORKPLACE LOCATED AT 141 OLD SHARON ROAD, JAFFREY, NEW HAMPSHIRE, 03452.   THE FINAL ORDER DATE FOR THE CITATION WAS ON OR BEFORE MARCH 10, 1996.