OSHA Inspection: NORTEX MIDSTREAM PARTNERS, LLC

Issued

2013-08-28 00:00:00

Abate by

2013-09-19 00:00:00

Penalty

Initial $4900.00 · Current $2940.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii):  The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices.     The employer does not ensure it documented that equipment in the process complied with recognized and generally accepted good engineering practices.    The violation occurred in the Worsham Steed Storage and Gas Plant on or about April 4, 2013 and times prior to where the employer failed to ensure administrative controls were in place to manage intervening block valve(s) to/from relief devices to ensure they were open during operation in accordance with ASME Boiler and Pressure Vessel Code, Division 1, Section VIII.  Identified relief devices include but are not limited to:   a.     PSV-1192  b.     PSV-1101  c.     PSV-1102  d.     PSV-1200  e.     PSV-4005  f.      PSV-8101      This condition exposed employees to fire and explosion hazards.      Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure administrative controls were in place to manage intervening block valve(s) to/from relief devices to ensure they were open during operation in accordance with recognized and generally accepted good engineering practices.

Issued

2013-08-28 00:00:00

Abate by

2013-09-19 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1):  The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information:     The employer does not ensure written operating procedures are developed and implemented that provided clear instructions for safely conducting activities involved in each process.   The violation occurred in the Worsham Steed Storage and Gas Plant on or about April 4, 2013 where the employer failed to ensure written operating procedures were developed and implemented to provide instructions for the use of chains, locks, or car-seals to ensure the intervening block to/from relief devices were open during operation following a shutdown/turn around and/or other activities that could result in the block valve being closed. Identified relief devices include but not limited to:  a.     PSV-1192  b.     PSV-1101  c.     PSV-1102  d.     PSV-1200  e.     PSV-4005  f.      PSV-8101    These conditions exposed employees to fire and explosion hazards.    Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure written operating procedures are implemented that provide clear instructions for safely conducting activities in each process.

Issued

2013-08-28 00:00:00

Abate by

2013-09-19 00:00:00

Penalty

Initial $4900.00 · Current $2940.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(iii):  The process hazard analysis did not address the engineering and administrative controls applicable to the hazards and their interrelationship, such as, appropriate detection methodologies to provide early warning of releases.    The employer does not ensure that the process hazard analysis addressed the engineering and administrative controls applicable to the hazards and their interrelationship including appropriate methodologies to provide early warning of releases.      The violation occurred in the Worsham Steed Storage and Gas Plant on or about April 4, 2013 and times prior to where the employer failed to ensure that the 2010 process hazard analysis addressed engineering and administrative controls such as but not limited to the Lower Explosive Limit (LEL) detectors.  This condition exposed employees to fire and explosion hazards.      Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking ensure that the process hazard analysis addressed the engineering and administrative controls applicable to the hazards and their interrelationship including appropriate methodologies to provide early warning of releases.

Issued

2013-08-28 00:00:00

Abate by

2013-09-19 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(e)(3)(v):  The process hazard analysis did not address facility siting.    The employer does not ensure the process hazard analysis addressed facility siting.    The violation occurred in the Worsham Steed Storage and Gas Plant on or about April 4, 2013 and times prior to where the employer failed to ensure the 2006 initial process hazards analysis of the Amine and CRYO Units and the 2010 initial process hazards analysis of the Gas Storage Unit addressed the siting of the control room and maintenance facilities within gas plant.  This condition exposed employees to fire and explosion hazards.    Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure the process hazard analysis addressed facility siting.

Issued

2013-08-28 00:00:00

Abate by

2013-09-19 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(e)(6):  The employer did not ensure after the initial process hazard analysis that the process hazard analysis was updated and revalidated at least every five (5) years by a team meeting the requirements 29 CFR 1910.119(e)(4) to assure that the process hazard analysis was consistent with the current process.    The employer does not ensure the initial process hazard analysis is updated and revalidated at least every five (5) years.    The violation occurred in the Worsham Steed Storage and Gas Plant on or about April 4, 2013 and times prior to where the employer failed to ensure the initial process hazards analysis conducted in 2006 for the Amine and Gas Plant (CRYO Unit) was updated every five (5) years. This condition exposed employees to fire and explosion hazards.    Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure the process hazard analysis is updated and revalidated at least every five (5) years.

Issued

2013-08-28 00:00:00

Abate by

2013-09-19 00:00:00

Penalty

Initial $4900.00 · Current $2940.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(1): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and which addressed the elements listed in 29 CFR 1910.119(f)(1) (i) through (f)(1)(iv).       The employer does not ensure that written operating procedures are developed and implemented to provide clear instructions for safely conducting activities in the covered process.       The violation occurred in the Worsham Steed Storage and Gas Plant on or about April 4, 2013 and times prior to where the employer failed to ensure standard operating procedures were developed and implemented that provide clear instructions for safely conducting activities in the process. Processes include but are not limited to:   a.     The Amine Area   b.     The CRYO unit   c.     The Compressor Area.      This condition exposed employees to fire and explosion hazards.      Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing that it is in compliance with the standard, including describing the steps it is taking to ensure standard operating procedures are developed and implemented that provide clear instructions for safely conducting activities in the process.

Issued

2013-08-28 00:00:00

Abate by

2013-09-19 00:00:00

Penalty

Initial $4900.00 · Current $2940.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(2):  The employer did not establish and implement written procedures to maintain the on-going mechanical integrity of process equipment.       The employer does not ensure written procedures are established and implemented to maintain the on-going mechanical integrity of process equipment.      A: The violation occurred in the Worsham Steed Storage and Gas Plant on or about April 4, 2013 and times prior to where the employer failed to ensure written procedures were established and implemented for testing of systems identified as safeguards in the process hazards analysis. Identified safeguards include but are not limited to:   a.     TAHH 4007   b.     PAHH 141   c.     TOTAL PLANT- Emergency Shut Down (ESD)   d.     PAHH 1501   e.     FALL 141A   f.      TALL 501F   g.     LEL/Infrared Detectors In Compressor Building.       B: The violation occurred in the Worsham Steed Storage and Gas Plant on or about April 4, 2013 and times prior to where the employer failed to ensure written procedures were established and implemented for testing and inspection of pressure vessels. Identified vessels include but are not limited to:   a.     MBD-1103   b.     MAK-3260   c.     MAK-2250   d.     MBD-1200   e.     ABJ-8101   f.      E-204   g.     T-501.     C: The violation occurred in the Worsham Steed Storage and Gas Plant on or about April 4, 2013 and times prior to where the employer failed to ensure written procedures were established and implemented for testing and inspection of process piping. Identified piping circuits include but are not limited to:    a.     203-B1-CS-6   b.     171-B0-304SS-2   c.     212-B1-CS-6   d.     168-D1-CS-8    These conditions exposed employees to fire and explosion hazards.      Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure written procedures are established and implemented to maintain the on-going mechanical integrity of process equipment.

Issued

2013-08-28 00:00:00

Abate by

2013-09-19 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(j)(4)(ii):  Inspections and testing procedures performed on process equipment to maintain its mechanical integrity, did not follow recognized and generally accepted good engineering practices.     The employer does not ensure inspections and tests are performed to maintain the on-going mechanical integrity of process equipment followed recognized and generally accepted good engineering practices (RAGAGEP).    A: The violation occurred in the Worsham Steed Storage and Gas Plant on or about April 4, 2013 and times prior to where the employer failed to ensure inspections and tests were performed on pressure vessels in accordance with RAGAGEP such as API 510. Identified vessels include but are not limited to:  a.     MBD-1103  b.     MAK-3260  c.     MAK-2250  d.     MBD-1200  e.     ABJ-8101  f.      E-204  g.     T-501.   B: The violation occurred in the Worsham Steed Storage and Gas Plant on or about April 4, 2013 and times prior to where the employer failed to ensure inspections and tests were performed on process piping in accordance with RAGAGEP such as API 570. Identified piping circuits include but are not limited to:  a.     203-B1-CS-6  b.     171-B0-304SS-2  c.     212-B1-CS-6  d.     168-D1-CS-8.  These conditions exposed employees to fire and explosion hazards.    Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure inspections and tests are performed to maintain the on-going mechanical integrity of process equipment followed recognized and generally accepted good engineering practices (RAGAGEP).

Issued

2013-08-28 00:00:00

Abate by

2013-09-19 00:00:00

Penalty

Initial $4900.00 · Current $2940.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i):  Inspections and tests were not performed on process equipment to maintain its mechanical integrity.       The employer does not ensure inspections and tests are performed to maintain the on-going mechanical integrity of process equipment.      The violation occurred in the Worsham Steed Storage and Gas Plant on or about April 4, 2013 and times prior to where the employer failed to ensure inspections and tests were performed on systems identified as safeguards in the process hazards analysis. Identified safeguards include but are not limited to:   a.     TAHH 4007   b.     PAHH 141   c.     TOTAL PLANT- Emergency Shut Down (ESD)   d.     PAHH 1501FALL 141A   e.     TALL 501F.    This condition exposed employees to fire and explosion hazards.      Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure inspections and tests are performed to maintain the on-going mechanical integrity of process equipment.