OSHA Inspection: INSITUFORM TECHNOLOGIES LLC

Issued

Apr 22, 2014

Abate by

Dec 6, 2016

Penalty

Initial $4,250 · Current $2,700 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D) Information concerning the technology of the process did not include safe upper and lower limits for such items as temperatures, pressures, flows or compositions:    a) Resin mixing system, control room, and wetout process; Information concerning the technology of the process did not contain the safe upper limit for the pressure within the vessels, metallic piping and flexible hoses, on or about December 11, 2013.    b) Resin mixing system, control room, and wetout process; Information concerning the technology of the process did not contain the safe upper limit for the temperature of the resin within the vessels, metallic piping and flexible hoses, on or about December 11, 2013.    ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 22, 2014

Abate by

Dec 6, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(A) Information pertaining to the equipment in the process did not include materials of construction:    a) Resin mixing system, control room, and wetout process; Information pertaining to equipment in the process did not include the materials of construction for non-metallic hoses in resin service, on or about, December 11, 2013.    b) Resin mixing system; Information pertaining to equipment in the process did not include the materials of construction for the resin pump seals, on or about, December 11, 2013.    ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 22, 2014

Abate by

Dec 6, 2016

Penalty

Initial $0 · Current $0

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:    a) Piping and instrumentation diagrams did not contain one of two stationary resin tanks, on or about December 11, 2013.    b) Piping and instrumentation diagrams did not contain the truck chassis mounted resin tank, on or about December 11, 2013.    c) Piping and instrumentation diagrams did not contain the resin heating and cooling units, on or about December 11, 2013.    d) Piping and instrumentation diagrams did not contain the stinger line , on or about December 11, 2013.    e) Piping and instrumentation diagrams did not contain instruments and displays present on the control panels within the control room, on or about December 11, 2013.    ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 22, 2014

Abate by

Dec 6, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(C) Information pertaining to the equipment in the process did not  include electrical classification:    a) Control room; Information pertaining to the equipment in the process did not  include the electrical classification of the interior of the control room, which contained electrical switch panels and breaker panels, on or about December 11, 2013.    b) Wetout process; Information pertaining to the equipment in the process did not document electrical classification of the interior of the wetout process area which contained switch panels, lighting fixtures, calendar controls, and breaker panels, on or about December 11, 2013.    c) Wetout process; Information pertaining to the equipment in the process did not document electrical classification of the adjacent rooms tot he wetout process which contained the vacuum pump, stand-by electrical generator and switchgear, on or about December 11, 2013.    ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 22, 2014

Abate by

Dec 6, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D) Information pertaining to the equipment in the process did not include relief system design and design basis:     a) Resin mixing system; Information pertaining to the equipment in the process did not include information on the liquid and gas pressure relief valves, noted as 8 inch emergency vents, located on top of the resin tanks, on or about December 11, 2013.    b) Resin mixing system; Information pertaining to the equipment in the process did not include information on the liquid and gas pressure relief valves, noted as a spring loaded emergency vent, located on top of the truck resin tank, on or about December 11, 2013.    ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 22, 2014

Abate by

Dec 6, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(H): Process safety information pertaining to the equipment in the process did not include the safety systems (e.g., interlocks, detection or suppression systems):    a) Control room and wetout process; Information pertaining to the equipment in the process did not include information on the fire protection system, on or about December 11, 2013.    b) Control room and wetout process; Information pertaining to the equipment in the process did not include information on the resin line pressure sensor and pump shut off system, on or about December 11, 2013.    c) Control room and wetout process; information pertaining to the equipment in the process did not include information on the resin tank agitator motor overload shutoff system, on or about December 11, 2013.    ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 22, 2014

Abate by

Dec 6, 2016

Penalty

Initial $4,250 · Current $2,700 Reduced

General-duty citation text

29 CFR 1910.119(e)(1) The employer did not conduct initial process hazard analyses:     a) A process hazard analysis was not developed for the hazard of over-filling the resin tanks, on or about December 11, 2013.     b) A process hazard analysis was not developed for the hazard of the resin heater malfunction, on or about December 11, 2013.     c) A process hazard analysis was not developed for the hazard of the resin tank agitator malfunction, on or about December 11, 2013.     d)  A process hazard analysis was not developed for the hazard of over-filling the tubes on the roller table, on or about December 11, 2013.     e) A process hazard analysis was not developed for the hazard of corrosion under insulation of the external resin recirculating piping, on or about December 11, 2013.     f) A process hazard analysis was not developed for the hazard of corrosion under insulation of the resin tanks, on or about December 11, 2013.      g) A process hazard analysis was not developed for the hazard of vibration on exterior resin lines, on or about December 11, 2013.      h) A process hazard analysis was not developed for the hazard of stinger connection failure during tube filling, on or about December 11, 2013.      i) A process hazard analysis was not developed for the hazard of resin leaking from a tube from shear by the calendar, tear, or patch failure in the roller table area, on or about December 11, 2013     j) A process hazard analysis was not developed for the hazard of roller table collapse in the roller table area,  on or about December 11, 2013     k) A process hazard analysis was not developed for the hazard of the vacuum system pulling in styrene vapor or liquid while performing wetout tasks, on or about December 11, 2013.        l) A process hazard analysis was not developed for the hazard of tank leakage, on or about December 11, 2013.     m) A process hazard analysis was not developed for the hazard of a failure of the resin line pressure sensor and the potential to over-pressurize the system, on or about December 11, 2013.        ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 22, 2014

Abate by

Dec 6, 2016

Penalty

Initial $4,250 · Current $2,700 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(B) The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information which addressed normal operations:    a) Normal operating procedures were not developed for the wetout process, on or about December 11, 2013.    ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 22, 2014

Abate by

Dec 6, 2016

Penalty

Initial $4,250 · Current $2,700 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment:     a) Written procedures to maintain the ongoing integrity of process equipment such as vessels, piping, pumps, hoses, sensors for critical parameters, and relief devices, were not available, on or about December 11, 2013.     ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 22, 2014

Abate by

Dec 6, 2016

Penalty

Initial $4,250 · Current $2,700 Reduced

General-duty citation text

29 CFR 1910.119(l)(1) The employer did not  establish and implement written procedures to manage changes  of process chemicals, technology, equipment, and procedures; and, changes to facilities that affected a covered process:    a) Wetout process; Management of change was not written and implemented for the resin roller table that was extended into a new addition of the building complex,  on or about December 11, 2013.    b) Resin mixing system; Management of change was not written and implemented for the chassis mounted resin storage tank that was positioned in the immediate proximity of the diked area, on or about December 11, 2013.    c) Resin mixing system; Management of change was not written and implemented for the condenser and compressor components of an HVAC system that was located outside of the exterior wall of the control room, on or about December 11, 2013.    ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 22, 2014

Abate by

Dec 6, 2016

Penalty

Initial $2,550 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.119(m)(5) The employer did not establish a system to promptly address and resolve the incident report findings and recommendations, and document the resolutions and corrective actions:    a) Resin mixing system, a tank overfill on or about May 28, 2012 resulted in actuation of, and release of liquid through a pressure relief device.  The resolution of the findings and corrective actions were not documented, on or about December 6, 2013.    ABATEMENT CERTIFICATION REQUIRED