OSHA Inspection: PUNA GEOTHERMAL VENTURE

Issued

Dec 12, 2013

Abate by

Dec 27, 2013

Penalty

Initial $7,000 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D):  Process safety information pertaining to the equipment in the process did not include the relief system design and design basis.        The employer does not ensure process safety information pertaining equipment in the process included the relief system design and design basis.      The violation occurred in the Geothermal Combined Cycle Unit (GCCU) on or about August 19, 2013 and times prior thereto where the employer failed to ensure the design and design basis of the relief systems for the pressure vessels was included in the process safety information. Identified relief systems include but are not limited to:    a.      Relief Valve(s) on Discharge of turbine to the condensers   b.      Relief Valve(s) on Vaporizer Separators       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 process safety information pertaining equipment in the process included the relief system design and design basis.

Issued

Dec 12, 2013

Abate by

Dec 27, 2013

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(5):  The employer did not establish a system to assure that the process hazard analysis team's recommendations are resolved in a timely manner and that the resolutions are documented:         The employer does not ensure a system is established to assure that the process hazard analysis team's recommendations are resolved in a timely manner and resolutions are documented.      The violation occurred in the Geothermal Combined Cycle Unit (GCCU) on or about August 19, 2013 and times prior thereto where the employer failed to ensure a system was established to assure that the 2008 process hazard analysis (PHA) team's recommendations were resolved in a timely manner and the resolutions documented. Recommendations include but not limited to:      a.     PGV.PHA.2009.01.03.01.03 - Consider determining if the existing Central Station Control (CSC) HVAC System draws fresh air through a vent, and if the vent is in a location designed to minimize the potential for toxic exposure to CSC personnel      b.     PGV.PHA.2009.01.03.03.01 - Consider installing remotely-operated isolation valves upstream and downstream of the Feed Pumps (30-PFXXX-11/25) and between the Level II Turbine (30-T-XXX-11/25) and Air-Cooled Condenser 30-HE -XXX-11/25)       c.     PGV.PHA.2009.10.01.06.02 - The 2009 HAZOP Study Team noted that the Administration Trailers may be subject to Potential process hazards at their current location. Consider replacing the Administration Trailers or relocating them as Part of the current Puna Geothermal Venture expansion project     d.     PGV.PHA.2009.05.07.01.02 - The 2009 HAZOP Study Team noted that the Coalescer relief valve discharge point was at a fairly low elevation, increasing the potential or a release contacting an ignition source or resulting in an exposure hazard. Consider elevating the Coalescer PSV discharge point.      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 a system is established to assure that the process hazard analysis team's recommendations are resolved in a timely manner and resolutions are documented.

Issued

Dec 12, 2013

Abate by

Dec 27, 2013

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(ii):  The employer's written operating procedures did not address the following requirements for the operating limits:           (A) Consequences of deviation      (B) Steps required correcting or avoiding deviation.      The employer does not ensure written operating procedures address the consequences of deviation and steps required for correcting or avoiding deviations from the safe upper and lower limits of the process.      The violation occurred in the Geothermal Combined Cycle Unit (GCCU) on or about August 19, 2013 and times prior thereto where the employer failed to ensure written operating procedures addressed the consequences of deviation and steps required for correcting or avoiding deviations from the safe upper and lower limits of the process. Identified operating limits include but not limited to:   a.       Vaporizer High Pressure   b.      Condenser High Pressure   c.       Steam Turbine Inlet Pressure   d.      Organic Turbine Bearing High Temperature   e.       Mechanical Seal Oil System High Pressure      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 written operating procedures address the consequences of deviation and steps required for correcting or avoiding deviations from the safe upper and lower limits of the process.

Issued

Dec 12, 2013

Abate by

Dec 27, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(3):  The employer did not certify annually that the operating procedures are current and accurate.        The employer does not ensure standard operating procedures are certified annually as being current and accurate.      The employer does not ensure operating procedures are current and accurate and are certified annually.      A. The violation occurred in Geothermal Combined Cycle Unit (GCCU) on or about August 19, 2013 and times prior where the employer failed to ensure written operating procedures were current and accurate. This condition exposed employees to explosion/fire hazards.    B.  The violation occurred in Geothermal Combined Cycle Unit (GCCU) on or about August 19, 2013 and times prior where the employer failed to ensure written operating procedures were certified as being correct and accurate annually.  This condition exposed employees to explosion/fire 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 operating procedures are current and accurate and are certified annually.

Issued

Dec 12, 2013

Abate by

Dec 27, 2013

Penalty

Initial $7,000 · Current $5,000 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 the process equipment.      A.  The violation occurred in the Geothermal Combined Cycle Unit (GCCU) on or about August 19, 2013 and times prior thereto where the employer failed to ensure that written procedures were established and implemented for the inspection and testing of process pressure such as but not limited to:    a.      Pentane Vaporizer     b.      Pentane Condensate Tank    c.      Pentane Preheater    d.      Pentane Separator    e.      Pentane Storage Vessels      B.  The violation occurred in the Geothermal Combined Cycle Unit (GCCU) on or about August 19, 2013 and times prior thereto where the employer failed to ensure that written procedures were established and implemented for the inspection and testing of pentane process piping such as but not limited to:    a.      Pentane Lines from Turbine to the Condenser (GCCU)    b.      Pentane Lines from the condenser to Preheater    c.      Pentane Lines from Preheater to the Vaporizer    d.      Pentane Lines from the Separator to the Turbine      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 written procedures are established and implemented to maintain the on-going mechanical integrity of the process equipment.

Issued

Dec 12, 2013

Abate by

Dec 27, 2013

Penalty

Initial $0 · Current $0

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 performed on process equipment to maintain its on-going mechanical integrity followed recognized and generally accepted good engineering practices (RAGAGEP).    A.  The violation occurred in the Geothermal Combined Cycle Unit (GCCU) on or about August 19, 2013 and times prior thereto where the employer failed to ensure testing and inspections of process piping and vessels followed generally accepted good engineering practices such as but not limited to API 510. Identified equipment includes but not limited to:   a.     Pentane Vaporizer    b.     Pentane Condensate Tank   c.     Pentane Preheater   d.     Pentane Separator   e.     Pentane Storage Vessels    B.  The violation occurred in the Geothermal Combined Cycle Unit (GCCU) on or about August 19, 2013 and times prior thereto where the employer failed to ensure testing and inspections of process piping and vessels followed generally accepted good engineering practices such as but not limited to API 570. Identified equipment includes but not limited to:   a.    Pentane Lines from Turbine to the Condenser (GCCU)   b.    Pentane Lines from the condenser to Preheater   c.    Pentane Lines from Preheater to the Vaporizer   d.    Pentane Lines from the Separator to the Turbine    This condition exposed employees to inhalation 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 performed on process equipment to maintain its on-going mechanical integrity followed recognized and generally accepted good engineering practices.