OSHA Inspection: QUEST SPECIALTY COATINGS, LLC

Issued

Dec 10, 2012

Abate by

Jul 1, 2013

Penalty

Initial $6,300 · Current $3,150 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i):     The employer did not compile information pertaining to the equipment in the process.    (a) Information regarding ventilation design for process covered areas and associated processes was not compiled and available for review.    (b) Information regarding electrical classification of covered process equipment and associated electrical rooms was not available. Specifically noted, was the electrical classification of electrical rooms associated with areas classified as Class 1 Division 1 areas and Class 1 Division 2 areas.    (c) Piping and Instrument Diagrams (P&ID's) did not identify relief valves, gauges and pipe monitoring equipment for propellant storage tanks, solvent storage tanks, propellant charging house equipment and other covered process equipment.    (d) Relief valves on propellant storage tanks and flammable materials storage tanks did not have available the relief system design and design basis outlining relieving capacity required for the equipment.

Issued

Dec 10, 2012

Abate by

Apr 1, 2013

Penalty

Initial $0 · Current $0

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) Propellant Storage Tanks: The U-1 Form, Manufacturer's Certificate of Compliance Covering Pressure Vessels was not maintained to document that the DME Propellant Tank (Tank 14), P-70 Propellant Tank (13) and P-85 Propellant Tank (Tank 15) complied with recognized and generally accepted good engineering practices (RAGAGEP).    (b) Relief valves on propellant storage tanks and flammable materials storage tanks did not have information compiled showing the relief valves complied with recognized and generally accepted good engineering practices.

Issued

Dec 10, 2012

Abate by

Apr 5, 2013

Penalty

Initial $6,300 · Current $3,150 Reduced

General-duty citation text

29 CFR 1910.119(e)(5):     The employer did not assure that PHA recommendations were resolved in a timely manner.    (a) Process Hazard Analysis (PHA) recommendations identified during the 2009 PHA were not resolved in a timely manner. Recommendations 8, 12, 51, 64, 65 and 68 were not resolved as of July 11, 2012, twenty seven months after being identified.

Issued

Dec 10, 2012

Abate by

Jan 29, 2013

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.119(f)(1):     The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process.     (a) Pipe Rack Run from Propellant Tank Farm to Propellant Charge House: A procedure was not developed for managing propellant phase changes from liquid to gaseous form within in piping during elevated temperatures. A garden hose sprinkler was installed along the pipe rack run to provide supplemental cooling to the supply piping into the propellant charging house and return piping to the storage vessels, to maintain propellant in a liquid phase.

Issued

Dec 10, 2012

Abate by

Jan 29, 2013

Penalty

Initial $4,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(l)(5):     When a change covered by this paragraph resulted in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices were not updated accordingly.    (a) Propellant Charging Room (Fill House): Bacharach Combustible Gas Monitoring System has monitoring sensors that are no longer functional and have not been replaced. No Management of Change (MOC) has been accomplished to assess the impact of monitoring the propellant charge house LEL levels.     (b) Pipe Rack Run from Propellant Tank Farm to Propellant Charge House: A Management of Change (MOC) for installation of garden hose sprinkler along pipe rack run was not accomplished. The garden hose sprinkler was installed to provide supplemental cooling to the supply piping into the propellant charging house and return piping to the storage vessels, to maintain propellant in a liquid phase.    (c) Emergency Fire Shut off Valves:  Emergency fire valves were converted from nitrogen gas pressure to regular compressed air pressure supplied by facility air compressor. A Management of Change (MOC) was not accomplished to evaluate the change from nitrogen supplied pressure to regular compressed air pressure.    (d) Emergency Fire Shut off Valve Installation 2010: New emergency fire shut-off valves were installed on propane storage tanks and connected into the emergency shut-down station. The installation also modified piping and required the installation of backflow check valves. A Management of Change (MOC) was not accomplished to evaluate the compatibility of new equipment installation and piping changes.

Issued

Dec 10, 2012

Abate by

Sep 30, 2013

Penalty

Initial $4,500 · Current $6,300

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) The written Mechanical Integrity Plan did not outline inspection, testing and replacement requirements beyond monthly and annual visual inspections for piping, pumps, motors, relief valves, emergency shut off valves,  safety instrumented systems and other auxiliary controls and equipment.

Issued

Dec 10, 2012

Abate by

Jul 1, 2013

Penalty

Initial $6,300 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i):     The employer did not perform inspection and tests on process equipment.     (a) Charging Room (Fill House): Bacharach Combustible Gas Monitoring System has not been calibrated and tested to ensure that LEL sensors alarm at 20% LEL and that the propellant charging process shuts down automatically at 40% LEL set point.

Issued

Dec 10, 2012

Abate by

Jul 1, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(ii):     Inspection and testing procedures did not follow recognized and generally accepted good engineering practices:    Inspection of Process Safety Management (PSM) covered process equipment has not been accomplished for, but is not limited to the following equipment:    (a) Piping: Inspection of process piping did not include non-destructive inspection methods every five years to determine thickness of wall piping, corrosion and erosion rates, and retirement thickness of piping and associated piping components.

Issued

Dec 10, 2012

Abate by

Jul 1, 2013

Penalty

Initial $4,500 · Current $0 Reduced

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) in a safe and timely manner when necessary means where taken to assure safe operation.    (a) Propellant Charging Room (Fill House): The employer did not correct identified mechanical integrity deficiencies in a timely manner. Bacharach Combustible Gas Monitoring System has monitoring sensors that are no longer functional and have not been replaced. The sensors determined to be no longer functional have not been replaced as of July 11, 2012.

Issued

Dec 10, 2012

Abate by

Mar 1, 2013

Penalty

Initial $4,500 · Current $2,250 Reduced

General-duty citation text

29 CFR 1910.132(d)(1)(i):     The employer did not select, and have each affected employee use, the types of PPE that would protect the affected employee from the hazards identified in the hazard assessment:    (a) Employees working in areas classified as class 1 division 1 and class 1 division 2 flammable environments were not protected from the potential burn hazards associated with these work environments. Employees were not required to wear flame retardant clothing when working or passing through in these classified work areas.    (b) Employees working in areas classified as class 1 division 1 and class 1 division 2 flammable environments wore tyvek coveralls not designed for use in a flammable and explosive environment.