OSHA Inspection: DCP MIDSTREAM, LP

Issued

Oct 5, 2012

Penalty

Initial $2,168 · Current $1,084 Reduced

General-duty citation text

29 CFR 1910.67(c)(2)(v): A body belt was not worn and a lanyard attached to the boom or basket when working from an aerial lift:    a)  On or about May 23, 2012, employees were not protected from injury while operating and working from a Genie aerial lift as follows:    1.  An employee was not utilizing a fall restraint system while traveling in the aerial lift.    2.  An employee was not tied off correctly while working from the basket of the lift in that, he had his lanyard connected to the guardrail of the basket and not the designated anchor point installed by the manufacturer.

Issued

Oct 5, 2012

Abate by

Oct 31, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.67(c)(2)(ii): An employee(s) operating an aerial lift(s) was not properly trained:    a)  On or about May 23, 2012, the employer had not provided employees operating an aerial lift with adequate training on how to utilize fall restraint systems when traveling in and working from the lift.    Abatement Note:  Abatement certification and documentation is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Oct 5, 2012

Abate by

Jul 1, 2013

Penalty

Initial $4,250 · Current $4,000 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 assignments are in the process and who may be affected by the recommendations or actions:    a)  On or about May 14, 2012 and times prior, recommendations from a PHA revalidation which was completed in 2009, were not addressed and resolved in a timely manner.  All recommendations contained in the HAZOP Final Report had a target completion date of 10/31/2009, however, many of these had not been completed.  The majority of these recommendations were to replace or modify pressure safety valves and were based on a relief valve study conducted at the facility. The employer also had a document entitled "Ladder Creek 2008 PHA Revalidation Action Items" which contained additional items to be addressed from the PHA revalidation.  Many of the entries were left blank and did not contain any indication of completion date or any documentation of a resolution for the items.    Abatement Note:  Abatement certification and documentation is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Oct 5, 2012

Abate by

Jul 1, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) before further use:    a) On or about May 14, 2012 and at times prior, several of the pressure relief valves installed at the facility were deficient in that, many of these valves were undersized, or had other deficiencies such as high back-pressure, potential vessel failure, high inlet losses or did not meet criteria for fire scenarios.  These deficiencies were identified by a third party study of the relief system in 2008, many of which have not been corrected to date.    b)  On or about May 14, 2012 and times prior, employees were exposed to a potential unintended release of high pressure NGL from improperly supported lines which resulted in excessive vibration at the following locations:    1. PSV 865 discharge line located outside of the compressor building on the southwest corner.  This was a vertical discharge line where the mounts at the base had come loose.    2. Product discharge line east of the NGL product pumps.  There was excessive vibration in this line due to the line not being effectively supported.    3.  Overhead and vertical NGL product lines near the NGL product pumps.  These lines were vibrating excessively due to the lack of adequate supports.    Abatement Note:  Abatement certification and documentation is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Oct 5, 2012

Abate by

Jul 1, 2013

Penalty

Initial $4,250 · Current $4,250

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 (P&ID's):    a)  On or about May 14, 2012 and times prior, the employer's piping and instrument diagrams (P&ID's) were not accurate and did not reflect equipment that was existing in the actual process including, but not limited to, the following:    1.  P&ID FS-105A showed a valve upstream of PSV 511A where there was no actual valve in the process.    2.  P&ID FS-105A did not show two (2) drain valves and two (2) flanges on the waste gas stream line which are in place in the actual process.    3.  P&ID FS-106 showed two (2) 4 inch valves on an inlet line and discharge line to S-101 in the "locked open" position where these were operational valves and were not locked open in the actual process.    4.  P&ID FS-106 did not show a second ball valve and piping connected to a 3/4 inch gate valve on the NGL discharge line upstream of FE-615 that was in place in the actual process.    5.  P&ID FS-106A showed a PSV 639 when the PSV was labeled as PSV 646 in the actual process.    6.  P&ID FS-110 showed F-102 with a discharge line going from PSV 1039 venting to atmosphere where the actual process had the discharge line going from PSV 1039 to a "rich amine line" and not to atmosphere.    7.  The symbol for pressure safety valve in the P&ID legend did not accurately reflect the symbol for PSV used throughouth all the P&IDs.  The symbol for a regular angle valve was used in many cases as the symbol for a PSV.    Abatement Note:  Abatement certification and documentation is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Oct 5, 2012

Abate by

Nov 20, 2012

Penalty

Initial $4,250 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(4): The employer did not develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel:    a)  On or about May 15, 2012 and times prior, effective safe work practices had not been developed and implemented for maintenance operations to address the re-installation of plugs into drain valve lines after the equipment was placed back into service.  A plug was missing on a 1 inch valve on the waste gas stream line shown on FS-105A.    b)  On or about May 25, 2012 and times prior, effective safe work practices had not been developed and implemented for maintenance operations to address the re-installation of plugs into drain valve lines after the equipment was placed back into service.  A plug was missing on a drain valve on piping coming out of the amine flash tank (PV-111).    Abatement Note:  Abatement certification and documentation is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Oct 5, 2012

Abate by

Dec 31, 2012

Penalty

Initial $4,250 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies had been corrected:    a) On or about May 14, 2012 and time prior the employer did not correct findings identified during the compliance audit conducted in 2009 in a timely manner.  These include the presence of block valves upstream of PSV's which were not car sealed open and not updating two procedures identified in the audit as needing improvement.    Abatement Note:  Abatement certification and documentation is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Oct 5, 2012

Penalty

Initial $2,168 · Current $2,000 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, or approved for the hazardous (classified) location, or safe for the hazardous (classified) location:    a) On or about May 14, 2012 and times prior, employees were exposed to injuries that could result from explosion/fires where two 24-volt conductors located in the amine unit, which had been classified by the employer as a Class I Division 2 area, were not intrinsically safe or approved for the location in that covers and caps were missing from fittings.

Issued

Oct 5, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.106(h)(6): Approved portable fire extinguishers of appropriate size, type, and number were not provided:    a) On or about May 25, 2012 and times prior, the employer did not provide appropriate fire extinguishers in the amine unit during start up of the unit.

Issued

Oct 5, 2012

Abate by

Nov 20, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment:    a)  On or about May 14, 2012 and times prior, the employer had not developed and implemented effective procedures to address coating of newly installed piping, valves and other process equipment or an inspection process to identify equipment that has not been coated.  Several sections of piping and valves were observed during the inspection where piping had been replaced or new sections of pipe had been installed and had not been coated.  Several of these sections of pipe contained surface corrosion.    Abatement Note:  Abatement certification and documentation is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Oct 5, 2012

Abate by

Oct 11, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(f)(3)(i): A procedure was not utilized to afford the employees a level of protection equivalent to that provided by the implementation of a personal lockout or tagout device when servicing and/or maintenance was performed by a crew, craft:    a)  On or about May 23, 2012 and times prior, DCP Midstream, LP as controlling/creating/correcting employer, did not ensure that employees of Conner Industries (subcontractor) were protected from injury in that, an effective group lockout/tagout procedure was not utilized for work on the slug catcher.  The contractor had placed their personal locks on the handle of a plastic case that afforded no effective control over the process locks.  The case could be opened and keys removed without each employee removing their personal locks.    Abatement Note:  Abatement certification and documentation is required for this item (see enclosed "Certification of Corrective Action Worksheet").