OSHA Inspection: NATURE'S PATH USA 2, LLC

Issued

Oct 8, 2013

Abate by

Jan 10, 2014

Penalty

Initial $7,000 · Current $4,200 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the teams findings and recommendations; did not assure that the recommendations were resolved in a timely manner and that the resolution was documented; did not document what actions were to be taken; did not complete actions as soon as possible; did not develop a written schedule of when these actions were to be completed; did not communicate the actions to operating, maintenance and other employees whose work assignments were in the process and who may have been affected by the recommendations or actions:    (a) The company did not address recommendations that were identifed during the 2010 process hazard analysis (PHA).    (b) The company did not address recommendations that were identifed during the January 2012 process hazard analysis (PHA) completed for the HX-06 water chiller addition.

Issued

Oct 8, 2013

Abate by

Nov 26, 2013

Penalty

Initial $5,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(C): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting temporary operations.    Written operating procedures did not contain specifications for transition from normal operations to temporary/emergency operations for the following procedures (but not limited to):    (a) High Stage TS Cooled Screw Compressors: The procedure did not specify actions to be taken by the operator(s) when the Operating Limit Discharge Pressure, Suction Pressure and Discharge Temperature exceed normal operating range.    (b) High Stage LI Cooled Screw Compressors: The procedure did not specify actions to be taken by the operator(s) when the Operating Limit Discharge Pressure, Suction Pressure, Discharge Temperature and lubrication oil temperature exceed normal operating range.    (c) High Stage Reciprocating Compressors: The procedure did not specify actions to be taken by the operator(s) when the Operating Limit Discharge Pressure, Suction Pressure, Discharge Temperature and Lubrication Oil Temperature exceed normal operating range.    (d) Evaporative Condensers: The procedure did not specify actions to be taken by the operator(s) when the Evaporative Condensers condensing pressure Operating Limit exceed normal operating range.    (e) Thermosyphon Receiver: The procedure did not specify actions to be taken by the operator(s) when the Operating Limit Pressure and Operating Limit Level exceed normal operating range.    (f) High Pressure Receiver: The procedure did not specify actions to be taken by the operator(s) when the Operating Limit Pressure and Operating Limit level exceed normal operating range.    (g) High Temp Accumulator/Intercooler: The procedure did not specify actions to be taken by the operator(s) when the Operating Limit Pressure and Operating Level exceed normal operating range.    (h) Low Temperature Recirculator: The procedure did not specify actions to be taken by the operator(s) when the Operating Limit Pressure and Operating Limit Level exceed normal operating range.    (i) Flooded S&T Water Chiller with Oil Pot: The procedure did not specify actions to be taken by the operator(s) when the Operating Limit Pressure and Surge Drum Level Operating Limit exceed normal operating range.

Issued

Oct 8, 2013

Abate by

Nov 26, 2013

Penalty

Initial $5,000 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(i): 29 CFR 1910.119(h)(2)(i): The employer, when selecting a contractor , did not obtain and evaluate information regarding the contract employer's safety performance and program:    (a) The company, prior to selecting an ammonia refrigeration contractor to maintain the facility ammonia refrigeration system, did not request and review information regarding the contractors injury and illness rates, safety program and other safety performance criteria.

Issued

Oct 8, 2013

Abate by

Jan 10, 2014

Penalty

Initial $5,000 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that was performed on process equipment:     (a) Annual pipe inspection of the anyhdrous ammonia refrigeration system was not documented as being performed in 2011 and 2012.

Issued

Oct 8, 2013

Abate by

Jan 10, 2014

Penalty

Initial $7,000 · Current $4,200 Reduced

General-duty citation text

29 CFR 1910.119(j)(6)(ii): Appropriate checks and inspections were not performed to assure that equipment was installed properly and consistent with design specifications and the manufacturer's instructions.    (a) Vilter Compressor RC-03: On or about April 30th 2013, a nipple pipe end connection that connected into a relief valve was schedule 40 pipe, that did not meet required recognized and generally accepted good engineering practices of schedule 80 pipe. Replacement relief valve and piping on RC-03 reciprocating compressor, installed in 2010, were not inspected and verified to ensure that piping was consistent with process safety design specifications.

Issued

Oct 8, 2013

Abate by

Jan 10, 2014

Penalty

Initial $5,000 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(n): The emergency action plan did not include procedures for handling small releases.    (a) The emergency action plan did not address how anhydrous ammonia refrigeration system leaks are characterized and are responded to.

Issued

Oct 8, 2013

Abate by

Jan 10, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.120(q)(2)(ii): The emergency response plan did not address, to the extent not addressed elsewhere, personnel roles, lines of authority, and communication:  (a) The emergency response plan did not outline the responsibilities of the maintenance manager and maintenance employees during an anhydrous ammonia release event, who has the authority to shut down the process during an emergency, and how the emergency is communicated to other maintenance and facility employees.

Issued

Oct 8, 2013

Abate by

Feb 28, 2014

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.120(q)(6): Training was not based on the duties and function to be performed by each responder of an emergency response organization:    (a) On or about April 30th 2013, the maintenance manager and other maintenance employee(s) were not trained to enter into a hazardous spill area to evaluate, control and mitigate the release of ammonia anhydrous refrigerant. The maintenance manager entered into the ammonia refrigeration compressor room to assist the ammonia refrigeration contractor isolate the leak.    (b) On or about April 30th 2013, A maintenance technician responded to an initial notification of an ammonia leak by opening the main entrance door to the compressor/machine room to make a visual observation of the room, and to determine potential cause of ammonia detector activation. The maintenance technician was not trained to respond to ammonia leaks and enter into hazardous atmospheres.

Issued

Oct 8, 2013

Abate by

Feb 28, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.120(q)(6)(ii): First responders at the operational level did not receive at least eight hours of training or did not have sufficient experience to objectively demonstrate competency in the areas required by 29 CFR 1910.120(q)(6)(ii)(A) through (q)(6)(ii)(F) and/or the employer did not so certify:   (a) On or about April 30th 2013, a maintenance technician who responded to an initial notification of an ammonia leak alarm, opened the main entrance door to the ammonia refrigeration compressor/machine room to make a visual observation of the room, and to determine a potential cause of ammonia detector activation, was not trained to a first responder operations level.

Issued

Oct 8, 2013

Abate by

Feb 28, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.120(q)(6)(iii): Employees who participated as hazardous materials technicians, or were expected to participate as hazardous materials technicians, had not received at least 24 hours of training equal to the first responder operations level, and in addition have competency in the areas outlined in 29 CFR 1910.120(q)(6)(iii)(A) through (q)(6)(iii)(I) and/or the employer did not so certify:  (a) On or about April 30th 2013, the Maintenance Manager responded to and entered the ammonia refrigeration system compressor room to determine the ammonia leak source within the compressor room and to stabilize the pressure within the refrigeration system that had caused the main header relief valve to open. The maintenance manager had not received training to the level of a hazardous materials technician.

Issued

Oct 8, 2013

Abate by

Jan 10, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams did not include information that provided specific identification of equipment that is part of the process.  (a) RC-03 Reciprocating compressor did not have safety pressure relief valves identifed on the P&ID.  (b) RC-01 Reciprocating compressor did not have safety pressure relief valves identified on the P&ID.  (c) RC-04 Reciprocating compressor did not have safety pressure relief valves identified on the P&ID.  (d) Oil Pot Drain Valves: Oil pot drain valves as reflected on P&IDs were noted as "not dead man valves". The drain valves installed on the oil pots are dead-man drain valves. The P&IDs were not updated to reflect that new dead-man valves were installed on all the oil pots.

Issued

Oct 8, 2013

Abate by

Nov 26, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(3):   The employer did not annually certify that operating procedures were current and accurate.   Operating procedures for ammonia refrigeration system equipment and processes were not certified annually as being current and accurate for the following equipment, but not limited to:  (a) Overall Ammonia System Operations procedure was not certified annually as being current and accurate.  (b) Oil Draining procedure was not certified annually as being current and accurate.  (c) Ammonia Charging procedure was not certified annually as being current and accurate.  (d) High Stage TS Cooled Screw Compressors procedure was not certified annually as being current and accurate.  (e) High Stage Ll Cooled Screw Compressors procedure was not certified annually as being current and accurate.  (f) High Stage Reciprocating Compressors procedure was not certified annually as being current and accurate.  (g) Low Stage Screw Compressor was not certified annually as being current and accurate.  (h) Low Stage Reciprocating Compressor was not certified annually as being current and accurate.  (i) Evaporative Condensers procedure was not certified annually as being current and accurate.  (j) High Pressure Receiver procedure was not certified annually as being current and accurate.  (k) Flooded S&T Water Chiller with oil pot was not certified annually as being current and accurate.  (l) Flooded S&T Glycol Chiller without oil pot was not certified annually as being current and accurate.  (m) Blast Freezer Units procedure was not certified annually as being current and accurate.  (n) Evapco Makeup Air Units procedure was not certified annually as being current and accurate.  (o) Krack Makeup Air Unit procedure was not certified annually as being current and accurate.

Issued

Oct 8, 2013

Abate by

Jan 10, 2014

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) Motors and drivers associated with anhydrous ammonia refrigeration process equipment did not have procedures developed for lubricating motors and drivers.

Issued

Oct 8, 2013

Abate by

Jan 10, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(l)(2): Management of change procedures did not assure that the considerations required by (l)(2)(1) through (l)(2)(v) were addressed prior to any change.  (a) Management of change (MOC) was not accomplished for change out of drain valves on oil pots. Existing drain valves on all ammonia refrigeration system oil pots were removed and replaced with a dead man drain valve.