OSHA Inspection: COPANO ENERGY LLC

Issued

Feb 6, 2013

Abate by

Jun 26, 2013

Penalty

Initial $4,200 · Current $4,200

Hazardous substances 0420102519902150K105

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E):     Information pertaining to the equipment in the process did not include the ventilation system design;    On or about 18 September 2012, and at time prior thereto, the employer did not have any information regarding the ventilation system design or testing for the control room located within the hydrocarbon plant's processing area, exposing the employees working within the building to the hazard of a flash fire from ignition of flammable vapors. Some of the various process flammable mixture chemicals at the Houston Central Gas Plant include Butane, Ethane, Propane, Isobutane [Propane, 2-methyl], Isopentane [Butane, 2-methyl], and Pentane.    Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure ventilation system designs and testing are available, up to date, and relevant in regards to the flammable chemicals at the processing plant.

Issued

Feb 6, 2013

Abate by

Apr 15, 2013

Penalty

Initial $4,200 · Current $4,200

Hazardous substances 0420102519902150K105

General-duty citation text

29 CFR 1910.119(d)(3)(i)(G):     Information pertaining to the equipment in the process did not include the material and energy balances for processes built after May 26, 1992.    On or about 18 September 2012, and at times prior thereto, the employer did not have any process safety information regarding the material and energy balances for the hydrocarbon plant's processing system, exposing the employees working within the area to the hazard of an explosion. Some modifications have been made to the Fractionator unit since original install in 1965, with the most recent being a second de-ethanizer being installed approximately 10 years ago. Material and energy balances are very important, and the chemical balances are fundamental to the control of processing, particularly in the control of yields of the products generated.     Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure the material and energy balances for the various processes are maintained and kept current with regards to any changes to the equipment and process.

Issued

Feb 6, 2013

Abate by

Apr 15, 2013

Penalty

Initial $4,200 · Current $4,200

Hazardous substances 0420102519902150K105

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.    On or about 18 September 2012, and at times prior thereto, the employer had an open PHA recommendation that was not resolved in a timely manner.  For the PHA revalidation completed on 7/17/07, the PHA team noted from the last company Compliance Audit that not all recommendations had been resolved; one of which being material balances. Without knowing the material and energy balances of the processes, a potential hazard would be a runaway reaction that would lead to a release or an explosion.    Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure open PHA recommendations are addressed in a timely manner before the next review or revalidation.

Issued

Feb 6, 2013

Abate by

Jun 26, 2013

Penalty

Initial $4,200 · Current $4,200

Hazardous substances 0420102519902150K105

General-duty citation text

29 CFR 1910.119(j)(4)(i):     The employer did not perform inspection and tests on process equipment.    On or about 18 September 2012, and at times prior thereto, the employer did not test or inspect the ventilation system for the Control Room located within the hydrocarbon plant's processing area, exposing the employees working within the building to the hazard of a flash fire from ignition of flammable vapors. Some of the various process flammable mixture chemicals at the Houston Central Gas Plant include Butane, Ethane, Propane, Isobutane [Propane, 2-methyl], Isopentane [Butane, 2-methyl], and Pentane.    Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure the ventilation system for the Control Room meets design specifications, and was installed properly and is consistent with the manufacturer's instructions.

Issued

Feb 6, 2013

Abate by

Mar 26, 2013

Penalty

Initial $4,900 · Current $4,900

Hazardous substances 0420102519902150K105

General-duty citation text

29 CFR 1910.119(j)(5):     Equipment deficiencies. The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means were taken to assure safe operation.    On or about 18 September 2012, and at times prior thereto, the employer did not correct deficiencies noted on a mechanical integrity report in a safe and timely manner before further use of such equipment. Under file# 1113V6D on the NVI Summary of 2011 Recommendations & Tracking Matrix, dated 9/8/11, stated that RT-9 (pipe) has "a projected short term retirement of .55 years" with remarks as "need to replace pipe at RT-9 due to structural integrity", but with status as "In Progress", and designated as "0" for high priority.    Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure the recommendations from a Mechanical Integrity report are corrected or addressed in a safe and timely manner to assure safe operation prior to further use.

Issued

Feb 6, 2013

Abate by

Apr 15, 2013

Penalty

Initial $4,900 · Current $4,900

Hazardous substances 0420102519902150K105

General-duty citation text

29 CFR 1910.119(o)(4):     Compliance Audits. The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.    On or about 18 September 2012, and at times prior thereto, the employer did not address and correct deficiencies noted from the Compliance Audit conducted on 4/16/2009 in a timely manner, and did not document that deficiencies have been corrected.  a) Section 2.6 of the Compliance Audit conducted on 4/16/09, stated "need to get Material and Energy balances for the entire facility". This same item (section 2.6) was also noted for the Compliance Audit conducted about 3 years prior on 3/14/06.  b) Section 8.2 of the Compliance Audit conducted on 4/16/09, stated "maintenance procedures are still required for mechanical integrity tasks, both internally performed tasks and third party performed tasks". This same item (section 8.2) was also noted for the Compliance Audit conducted about 3 years prior on 3/14/06.    Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure findings on compliance audits are addressed in a timely manner, and document that deficiences have been corrected.