OSHA Inspection: UNITED ETHANOL LLC

Issued

Oct 16, 2013

Abate by

Nov 6, 2013

Penalty

Initial $5,000 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Information pertaining to the equipment in the process did not include piping and instrument diagrams (P&ID's):     On or about May 14, 2013, the employer's process safety information did not include piping and instrument diagrams that accurately represented equipment in the covered, including but not limited to, the following:     a) A gate valve tagged V31729 on the 24" line from the Beer Column to the Beer Column reboiler pump(s) #1 and #2 is not depicted on the P&IDs.     b) The valve on the 6" line from the beer booster pump to the beer column feed heater is tagged V41129, but the P&IDs indicate the tag number is V41113.     c) The valve on the 6" line to the CIP return from the Beer Booster Pump is tagged V41187, but the P&IDs indicate the tag number is V41114.     d) The valve on the 3" line from the Rectifier Column to the Stripper Column is tagged V46165, but the P&ID indicates the tag number is V42127.     e) The valve on the 3" line from the Stripper Column to the Stripper Column Reboiler and/or Process Condensate Tank is tagged V42127, but the P&IDs indicate the tag number is V46165.     f) The pipe run from the Rectifier Column to the Beer Column has been capped and the pipe run removed, but is still depicted on the P&IDs.     g) A piping run, inclusive of control valves, was installed for draining the Beer Column Reboiler and not depicted on the P&IDs.     h) A valve installed on the 8" line outlet from the Rectifier Column was not depicted on the P&IDs.     i) A strainer installed on the 8" line outlet from the Rectifier Column was not depicted on the P&IDs.     j) A valve from the Rectifier Column to the Stripper Column is labeled V51122, but the P&IDs indicate the tag number is V42123.

Issued

Oct 16, 2013

Abate by

Nov 6, 2013

Penalty

Initial $5,000 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting.    On or about August 16, 2013, the employer's Process Hazard Analysis did not address facility siting, including but not limited to, the proximity of the ignition source created by the corn delivery traffic in relation to the Class I, Division 2 locations at dispensing and filling of the tanker trucks, dispensing and filling of the railcars, and the bulk storage of ethanol and denaturant.

Issued

Oct 16, 2013

Abate by

Nov 6, 2013

Penalty

Initial $5,000 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D): The employer did not develop and implement written operating procedures that provide clear instructions for emergency shutdown, including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.    On or about May 14, 2013, the employer did not develop written operating procedures that provided clear instructions for emergency shutdown, including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibilities for the covered process.

Issued

Oct 16, 2013

Abate by

Nov 6, 2013

Penalty

Initial $5,000 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not annually certify that operating procedures were current and accurate.    On or about May 14, 2013, the employer did not annually certify that the Distillation operating procedures were current and accurate, including but not limited to, the Distillation operating procedures.

Issued

Oct 16, 2013

Abate by

Nov 6, 2013

Penalty

Initial $5,000 · Current $4,000 Reduced

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 August 16, 2013, the employer failed to perform inspections and tests on the controls, including alarms and interlocks, for the covered process.     a) The beer column's high pressure alarm.     b) The beer column's high pressure interlock, changing the process from auto mode to manual mode when any two pressure indicators alarm.     c) The rectifier column's high pressure alarm.     d) The rectifier column's high pressure interlock, changing the process from auto mode to manual mode when any two pressure indicators alarm.     e) The stripper column's high level interlock, shutting down the rectifier bottoms pump and the steam control valve to the stripper column, when the level inside the stripper column exceeds 90%.

Issued

Oct 16, 2013

Abate by

Nov 6, 2013

Penalty

Initial $5,000 · 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 have been corrected:     On or about May 14, 2013, the employer did not determine and document an appropriate response to each of the compliance audit findings from the PSM Audit performed on June 15, 16 & 17, 2010 of the ethanol plant, including but not limited to the following findings:     a) No consultation with employees on the content and frequency of refresher training (item #4).     b) Not conducting refresher training for operators on at least a three year interval (Item #12).     c) Lack of employee participation in the review and revision of standard operating procedures (Item #4).     d) Failure to develop emergency shutdown procedures, including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner (Item #8).     e) Lack of an annual certification that the standard operating procedures are current an accurate (Item #9).

Issued

Oct 16, 2013

Abate by

Nov 6, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(c)(2): The employer did not consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard.  On or about May 14, 2013, the employer did not consult with employees on the conduct and development of the elements of the process safety management program for the ethanol process, including but not limited to, the following elements:  a) The employer did not consult with employees on the content and frequency of refresher training.  b) The employer did not include employees in the participation in the review and revision of the standard operating procedures for the distillation process.

Issued

Oct 16, 2013

Abate by

Nov 6, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(g)(2): Refresher training was not provided at least every three years to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process:  On or about May 14, 2013, the employer did not provide refresher training to the ethanol plant operators at least every three years.