OSHA Inspection: ZOTOS INTERNATIONAL, INC.

Issued

May 24, 2012

Penalty

Initial $5,000 · Current $2,750 Reduced

General-duty citation text

29 CFR 1910.110(b)(6)(vi): Readily ignitable materials were not removed from within ten feet of any LP Gas container:        a) On or about 2/14/2012, Aerosol Area:   Wooden dunnage was stored underneath tank #5 which was labeled as a LPG tank.      Abatement certification is required for this item.

Issued

May 24, 2012

Penalty

Initial $5,000 · Current $2,750 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i)(A): Information pertaining to the equipment in the process did not include a Block Flow Diagram of the process:    a) On or about 2/13/2012, Alcohol Area:   There was no Block Flow Diagram for the Alcohol unit.

Issued

May 24, 2012

Abate by

Jun 23, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Information pertaining to the equipment in the process did not include accurate Piping and Instrument Diagrams and did not represent equipment that was existing and was part of the process.    a) On or about 2/13/2012, Alcohol Area:  The existing P&ID's had discrepancies between the drawings and what was actually in place, such as, but not limited to:       1) The plans, drawing G-4, show that there should be three High capacity emergency vents, while there are only two on the tank.       2) There were two level indicators located on the tank, and they were not shown or addressed on the drawing G-4.       3) None of the valving for the filling and dispensing of alcohol on the main tank was shown on the drawing G-4 nor any other drawing.       4) None of the process valving or relief valving was shown on drawing M-1, depicting the batching room.       5) Two tanks in room 5a had been removed (T90 and T95), but were still on drawing M-1, while one tank was moved (T93) and one tank was added (HC5), which was not added to drawing M-1.     b) On or about 2/14/2012, Aerosol Area:  The existing P&ID's had discrepancies between the drawings and what was actually in place, such as, but not limited to:         1) On piping associated with tank numbers 1, 2, and 3, there was a valve and nipple with a plug that was located after PI-0-400, which did not appear on the drawings.    Abatement certification is required for this item.

Issued

May 24, 2012

Abate by

Jun 23, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): Information pertaining to the equipment in the process did not include relief system design and design basis:    a) On or about 2/13/2012, Alcohol Area:  There were no design plans, or basis for the Alcohol room relief system.     Abatement certification is required for this item.

Issued

May 24, 2012

Abate by

Sep 13, 2013

Penalty

Initial $5,000 · Current $2,750 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices.    a) On or about 2/13/2012, Alcohol Area:  The employer did not ensure that all equipment complied with recognized and generally accepted good engineering practices such as not limited to the following consensus standards:         1) The tank venting system in use located after tank flame arrestors, was constructed with PVC piping that showed signs of heat exposure and failure.  Reference NFPA 30, Flammable and Combustible Liquids Code, section 27.4.4.1           2) The exterior Ethanol storage tank had emergency venting that was located below the roof line and vents of three surrounding buildings.  Reference NFPA 90A Installation of Air Conditioning and Ventilating Systems, section 2-2.1.1 and NFPA 69 Explosion Prevention Systems, section 3-3.3.1.         3) The room venting from building 5a was located in line with intake vents for building 2.  Reference NFPA 90A Installation of Air Conditioning and Ventilating Systems, section 2-2.1.1 and NFPA 69 Explosion Prevention Systems, section 3-3.3.1.         4) The spill containment area was provided with an unsecured valve to the waste water treatment plant.  Reference NFPA 30 Flammable and Combustible Liquids Code, section 5-4.1.2 and section 5-4.2.    Abatement certification is required for this item.

Issued

May 24, 2012

Abate by

Jun 23, 2012

Penalty

Initial $5,000 · Current $2,750 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the consequences of failure of engineering and administrative controls:     a) On or about 2/14/2012, Aerosol Area:  The PHA did not consider the consequences of failure of the engineering and administrative controls, such as, but not limited to the failure of the interlocks on the doors to the gas houses.    Abatement certification is required for this item.

Issued

May 24, 2012

Abate by

Jun 23, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not develop a written schedule of actions to resolve Process Hazard Analysis (PHA) recommendations.    a) On or about 2/13/2012, Alcohol Area:    There was no written schedule to address items identified in the August 2011 PHA.    Abatement certification is required for this item.

Issued

May 24, 2012

Abate by

Jun 23, 2012

Penalty

Initial $5,000 · Current $2,750 Reduced

General-duty citation text

29 CFR 1910.119(e)(4): The team performing the process hazard analyses did not include at least one employee who had experience and knowledge specific to the process being evaluated.    a) On or about 2/13/2012, Alcohol Area:  Employees were not included in the Process Hazard Analysis (PHA)  process.       Abatement certification is required for this item.

Issued

May 24, 2012

Abate by

Jun 23, 2012

Penalty

Initial $5,000 · Current $2,750 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(d): The employer had not developed and implemented written operating procedures that provided clear instructions for safely conducting activities involved in the covered process:    a) On or about 2/13/2012, Alcohol Area:   There were no written procedures for the start up, operation, shutdown and emergency shutdown of the Ethanol unit.    Abatement certification is required for this item.

Issued

May 24, 2012

Abate by

Jun 23, 2012

Penalty

Initial $5,000 · Current $2,750 Reduced

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that was outside acceptable limits (defined by the process safety information on paragraph (d) of this section) before use or in a safe and timely manner:    a) On or about 2/13/2012 and 3/14/2012, Alcohol Area:  In the Ethanol unit the following deficiencies were noted:         1) Tank 77 had a valve control arm that was being held closed with a large rubber band.         2) A bottom low pressure thermo couple and conduit, was not supported.         3) The main pump control had been pulled free from a column and was solely supported by its own conduit.         4) The bracket holding one of two LEL meters was broken, and the meter was suspended by conduit.          5) The second LEL meter was not secured, and suspended on the end of a piece of conduit.         6) A section of the PVC vent system was missing a support strap.           7)  None of the valving (shut off, emergency or bypass) was identified and labeled.         8) An emergency stop for the main alcohol pump, located outside of room 5a,  was lacking the entire stop button.    b) On or about 2/14/2012, Propellant Unit:  In the Propellant Unit the following deficiencies were noted:         1) A grounding strap leading from the flammable gas bulkhead to a tanker truck was not attached to bare metal of the tanker truck.          2) A product inlet valve for tank number 3 had a manufacturers flow direction opposite of what direction the product was flowing.    Abatement certification is required for this item.

Issued

May 24, 2012

Abate by

Jun 15, 2012

Penalty

Initial $5,000 · Current $2,750 Reduced

General-duty citation text

29 CFR 1910.119(o)(1):  The employer did not certify that they have evaluated compliance with the provisions of this section at least every three years:    a) On or about 2/13/2012, Alcohol Area:   No Compliance Audits had been performed for the Alcohol Unit.    Abatement certification is required for this item.