OSHA Inspection: HIGH FALLS OPERATING COMPANY, LLC

Issued

Sep 26, 2014

Abate by

Oct 29, 2014

Penalty

Initial $4,500 · 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 and did not address normal operations.    a) On or about throughout the ammonia refrigeration system; employer failed to develop specific written oil draining procedures for ammonia containing equipment such as, but not limited, Draft Center receiver, Draft Center accumulator, Draft Center humidifier air handling unit, Draft Center Kathabar, Swing Chiller, Primary Chiller.      ABATEMENT CERTIFICATION REQUIRED

Issued

Sep 26, 2014

Abate by

Oct 29, 2014

Penalty

Initial $4,500 · Current $2,700 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(A): The employer did not develop and implement written operating procedures that addressed the consequences of deviations from the operating limits in the covered process ;      a) On or about 05/06/14 in the Engine Room; employer failed to include in the written operating procedures for the following equipment; 1851 Accumulator Draining procedures, Draining Oil Via the Used Oil Receiver, Oil Draining Using An Open Pail, Liquid Ammonia Addition to the Main Receiver, the consequences of, such as but not limited to, trapping ammonia between two closed valves.      b) On or about 05/06/14 in the Engine Room; employer failed to include in the written operating procedures for the following equipment; 1851 Vilter VSS Ammonia Compressors, #2 Frick Compressor, #1 Frick Compressor, #10 Vilter Twin NH3 Compressor, the consequences of, such as but not limited to, having liquid ammonia enter the compressors from the accumulators, having the suction valves open and the discharge valves closed.      c) On or about 05/06/14 in the Engine Room; employer failed to include in the written operating procedures for the following equipment; #3 Ammonia Accumulator, #2 Ammonia Accumulator, #1 Ammonia Accumulator, Vilter 1851 Accumulator, the consequences of, such as but not limited to, having a high level and sending liquid ammonia to the compressors.      d) On or about 05/06/14 at the liquid ammonia filling connection; employer failed to include in the writing operating procedure, Liquid Ammonia Addition to Main Receiver, the consequences of, such as but not limited to, having the inlet valve closed, check valve in manual, and pumping against a dead head.      ABATEMENT CERTIFICATION REQUIRED

Issued

Sep 26, 2014

Abate by

Oct 29, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(B): The employer did not develop and implement written operating procedures that provide clear instructions for steps required to correct or avoid deviation from the operating limits in the covered process.  a) On or about 05/06/14 in the Engine Room; employer failed to include in the written operating procedures for the following equipment; 1851 Accumulator Draining procedures, Draining Oil Via the Used Oil Receiver, Oil Draining Using An Open Pail, Liquid Ammonia Addition to the Main Receiver, the steps to correct the consequences of, such as but not limited to, trapping ammonia between two closed valves.    b) On or about 05/06/14 in the Engine Room; employer failed to include in the written operating procedures for the following equipment; 1851 Vilter VSS Ammonia Compressors, #2 Frick Compressor, #1 Frick Compressor, #10 Vilter Twin NH3 Compressor, the steps to correct the consequences of, such as but not limited to, having liquid ammonia enter the compressors from the accumulators, having the suction valves open and the discharge valves closed.    c) On or about 05/06/14 in the Engine Room; employer failed to include in the written operating procedures for the following equipment; #3 Ammonia Accumulator, #2 Ammonia Accumulator, #1 Ammonia Accumulator, Vilter 1851 Accumulator, the steps to correct the consequences of, such as but not limited to, having a high level and sending liquid ammonia to the compressors.    d) On or about 05/06/14 at the liquid ammonia filling connection; employer failed to include in the writing operating procedure for the Liquid Ammonia Addition to Main Receiver, the steps to correct the consequences of, such as but not limited to, having the inlet valve closed, check valve in manual, and pumping against a dead head.    ABATEMENT CERTIFICATION REQUIRED

Issued

Sep 26, 2014

Abate by

Oct 29, 2014

Penalty

Initial $4,500 · Current $2,700 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish a written procedures to maintain the on-going integrity of process equipment;     a) On or about 05/06/14 in the Engine Room; employer failed to write maintenance procedure(s) describing the inspection and testing method for the high level alarm safety system of ammonia equipment, such as but not limited to,#1 accumulator, #2 accumulator, #3 accumulator, 1851 compressor accumulator.      b) On or about 05/06/14 in the Engine Room; employer failed to write a maintenance procedure(s) describing the inspection, testing and actions to take when results indicate improper function of the safety systems ( e.g. safety cut outs) on ammonia compressors, such as but not limited to, #2 Frick, #4 Frick, #1 Frick, #10 Vilter, #8 Vilter, 1851 VSS.       c) On or about 05/06/14 in the Engine Room; employer failed to write a maintenance procedure(s) describing the actions to take when results of insulation inspection indicates integrity of insulation may be compromised, such as but not limited to, #1 accumulator, #2 accumulator, #3 accumulator.     ABATEMENT CERTIFICATION REQUIRED

Issued

Sep 26, 2014

Penalty

Initial $4,500 · Current $2,700 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment    a) On or about 05/07/14 in the Engine Room; since installation, employer failed to conduct testing of the high level alarm on accumulators, such as but not limited to #1, #2, #3, and 1851 compressor accumulator, required by Section 6.6.4 of the International Institute of Ammonia Refrigeration (IIAR) Bulletin 110, 3/93; which established annual testing.       NO ABATEMENT CERTIFICATION REQUIRED

Issued

Sep 26, 2014

Penalty

Initial $4,500 · Current $2,700 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.    a) On or about 05/07/14 in the Engine Room; employer last conducted non destructive testing of an ammonia refrigeration pressure vessel, Liquid Ammonia Transfer Tank (NH3-210-T05) on 03/09/09 when recommendations from sources, such as but not limited to, contract testing company ( QIS ) inspection report, Section 6.3.1 of American Petroleum  Institute (API ) - 510, Sixth Edition, 6/06, established the next testing to be conducted in five years.      b) On or about 05/07/14 in the Engine Room; employer last conducted non destructive testing of an ammonia refrigeration pressure vessel, Waste Oil Receiver ( NH3-210-001 ) on 03/06/09, when recommendations from sources, such as but not limited to, contract testing company ( QIS ), Section 6.3.1 of American Petroleum  Institute (API ) - 510, Sixth Edition, 6/06, established the next testing to be conducted in five years.     c) On or about 05/07/14 in the Engine Room; employer last conducted non destructive testing of an ammonia refrigeration pressure vessel, Liquid Ammonia Transfer Tank ( NH3-210-T06 ) on 03/09/09, when recommendations from sources, such as but not limited to, contract testing company ( QIS ), Section 6.3.1 of American Petroleum  Institute (API ) - 510, Sixth Edition, 6/06, established the next testing to be conducted in five years.      NO ABATEMENT CERTIFICATION REQUIRED

Issued

Sep 26, 2014

Penalty

Initial $4,500 · Current $2,700 Reduced

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) before use;     a) On or about 05/06/14 in the Engine Room; employer failed to repair or replace the differential pressure switch associated with the High Pressure Cutout and or blow out the discharge sensor line, on the north end of the #10 Vilter ammonia compressor as indicated on the Compressor Control Safety Test conducted on 01/07/14.        NO ABATEMENT CERTIFICATION REQUIRED