OSHA Inspection: CLOVERLEAF COLD STORAGE COMPANY

Issued

Jul 23, 2014

Abate by

Sep 15, 2014

Penalty

Initial $7,000 · Current $3,850 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process:    Cloverleaf Cold Storage Company, Napoleon, Ohio:  As of and prior to February 20, 2014, the employer did not ensure that their P&IDs were up-to-date and accurate.  Inaccuracies included but were not limited to:      a) The relief vent for relief header RV-638, P&ID 7W5-612, was not included on the diagram.      b) The relief vent for relief header RV-646, P&ID 7W5-612, was not included on the diagram.      c)  Piping system, RV-610 is no longer connected to RV-609 on P&ID 7W5-171.      d)  The pressure relief valve protecting vessel SD-302, P&ID 7W5 VB-320, was indicated as being a single relief valve but a dual relief valve was installed on the vessel.      e)  The pressure relief valve protecting vessel SD-303, P&ID 7W5 VB-321, was indicated as being a single relief valve but a dual relief valve was installed on the vessel.      f)  The pressure relief valve protecting vessel SD-304, P&ID 7W5 VB-322, was indicated as being a single relief valve but a dual relief valve was installed on the vessel.      g)  The pressure relief valve protecting vessel SD-305, P&ID 7W5 VB-323, was indicated as being a single relief valve but a dual relief valve was installed on the vessel.      h)  The pressure relief valve protecting vessel SD-306, P&ID 7W5 VB-324, was indicated as being a single relief valve but a dual relief valve was installed on the vessel.      i)  The pressure relief valve protecting vessel SD-307, P&ID 7W5 VB-325, was indicated as being a single relief valve but a dual relief valve was installed on the vessel.      j)  The pressure relief valve protecting vessel SD-308, P&ID 7W5 VB-326, was indicated as being a single relief valve but a dual relief valve was installed on the vessel.      k)  The pressure relief valve protecting vessel SD-309, P&ID 7W5 VB-327, was indicated as being a single relief valve but a dual relief valve was installed on the vessel.      l)  The pressure relief valve protecting vessel SD-310, P&ID 7W5 VB-328, was indicated as being a single relief valve but a dual relief valve was installed on the vessel.   m)  The pressure relief valve protecting vessel SD-311, P&ID 7W5 VB-329, was indicated as being a single relief valve but a dual relief valve was installed on the vessel.      n)  The pressure relief valve protecting vessel SD-3012, P&ID 7W5 VB-330, was indicated as being a single relief valve but a dual relief valve was installed on the vessel.      o)  The pressure relief valve protecting vessel SD-313, P&ID 7W5 VB-331, was indicated as being a single relief valve but a dual relief valve was installed on the vessel.      q)  The P&IDs did not reflect that twenty-two manual valves were capped or plugged to prevent ammonia release.  The valves included but were not limited to, valves L6, L7, and L8 on P&ID 7W5-1010, valves G9 and G10 on P&ID 7W5-855, and valves D1 on each of the evaporators.

Issued

Jul 23, 2014

Abate by

Sep 15, 2014

Penalty

Initial $7,000 · Current $3,850 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(f)(1)(i)(A):   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 for and did not address at least the following element: initial startup.    Cloverleaf Cold Storage Company, Napoleon, Ohio:  As of and prior to February 20, 2014, the employer did not develop and implement written operating procedures for normal operations that provide clear instructions for operating the ammonia refrigeration system including but not limited to:      a)  The procedure, SOP-LT-510, for operation of LT-510 ammonia compressor did not provide specific information on which valves to open and which valves to close when pumping out the compressor.      b)  The procedure, SOP-LT-511, for operation of LT-511 ammonia compressor did not provide specific information on which valves to open and which valves to close when pumping out the compressor.      c)  The procedure, SOP-LT-512, for operation of LT-512 ammonia compressor did not provide specific information on which valves to open and which valves to close when pumping out the compressor.      d)  The procedure, SOP-HT-610, for operation of HT-610 ammonia compressor did not provide specific information on which valves to open and which valves to close when pumping out the compressor.      e)  The procedure, SOP-HT-611, for operation of HT-611 ammonia compressor did not provide specific information on which valves to open and which valves to close when pumping out the compressor.      f)  The procedure, SOP-HT-612, for operation of HT-612 ammonia compressor did not provide specific information on which valves to open and which valves to close when pumping out the compressor.      g)  The procedure, SOP-HT-613, for operation of HT-613 ammonia compressor did not provide specific information on which valves to open and which valves to close when pumping out the compressor.      h)  The procedure, SOP-7W5-500, for operation of ammonia liquid accumulator, 7W5-500, and pumps, did not provide specific information on which valves to open and which valves to close during startup.      i)  The procedure, SOP-HE-920, for operation of ammonia heat exchanger, HE-920, did not provide specific information on which valves to open and which valves to close during startup.      j)  The procedure, SOP-HE-1010, for operation of ammonia heat exchanger, HE-1010, did not provide specific information on which valves to open and which valves to close during startup.      k)  The procedure, SOP-LT-511, for operation of LT-511 ammonia compressor incorrectly directs the person to ensure that valve L3 is closed.  There is no valve on compressor LT-511 designated as L3.      l)  The procedure, SOP-HT-611, for operation of HT-611 ammonia compressor incorrectly directs the person to open pump out valve G2.  There is no valve on compressor HT-611 designated as G2.      m)  The procedure, SOP-HE-920, for operation of ammonia heat exchanger, HE-920 on P&ID 7W5-920, incorrectly directs the person to open valve L5.  There is no valve on HE-920 designated as L5.

Issued

Jul 23, 2014

Abate by

Sep 15, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process:     Cloverleaf Cold Storage Company, Napoleon, Ohio:  As of and prior to May 20, 2014, the employer did not ensure that the management of change procedure was implemented for changes made to the ammonia system.  Changes that were made to the system include, but were not limited to:        a)  The emergency stop controls located inside the building near the mechanical room (engine room) were removed.