OSHA Inspection: JP LILLIS ENTERPRISES, INC.

Issued

2014-12-05 00:00:00

Abate by

2015-06-20 00:00:00

Penalty

Initial $4900.00 · Current $2533.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Process safety information pertaining to the equipment in the process did not include piping and instrumentation diagrams (P& ID's):    (a) Facility: The employer did not have an accurate and up-to-date set of piping and instrumentation diagrams (P & ID's) for the anhydrous ammonia refrigeration system, on or about 7-9-14.

Issued

2014-12-05 00:00:00

Abate by

2015-09-12 00:00:00

Penalty

Initial $0.00 · Current $0.00

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:  (a) Facility: The employer did not develop, document, and include the relief system design basis for relief valves used in the anhydrous ammonia refrigeration system in its process safety information, on or about 7-9-14.

Issued

2014-12-05 00:00:00

Abate by

2015-06-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E): Process safety information pertaining to the equipment in the process did not include the ventilation system design:  (a) Facility: The employer did not develop, document, and include the ventilation system design for the engine room ventilation system in its process safety information, on or about 7-9-14.

Issued

2014-12-05 00:00:00

Abate by

2015-06-20 00:00:00

Penalty

Initial $4900.00 · Current $2533.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices:    (a) Facility: The atmospheric discharge relief valve vent line located on the roof of the facility was not at least 15 feet above the roof level, as required by ANSI/IIAR 2-2008 "Equipment Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems", 11.3.6.4, on or about 7-9-14.    (b) Engine room: The Oxy-Acetylene Torch unit was being stored in the engine room on or about 7-9-14. ANSI/IIAR 2-2008 "Equipment Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems", 13.1.3.1 provides that "Flammable and combustible materials shall not be stored in machinery rooms".    (c) Outside Facility: The High Pressure Receiver and two Evaporative Condensers outside of the building did not have lighting to permit adequate nighttime inspection, as required by ANSI/IIAR 2-2008 "Equipment Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems", 13.1.11.2, on or about 7-9-14.    (d) Facility: A remote emergency shutdown control for refrigerant compressors, refrigerant pumps, and normally closed automatic refrigerant valves within the machinery room, was not provided as part of the emergency controls, as required by ANSI/IIAR 2-2008 "Equipment Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems", 13.1.13.2, on or about 7-9-14.    (e) Engine room: At least two refrigerant detectors were not provided and configured to operate at detection levels as required by ANSI/IIAR 2-2008 "Equipment Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems", 13.2, on or about 7-9-14.

Issued

2014-12-05 00:00:00

Abate by

2015-06-20 00:00:00

Penalty

Initial $4900.00 · Current $2533.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis did not address the elements of (i) through (vii) of this paragraph:    (a) Facility: An adequate, site specific process hazard analysis was not developed to address the elements of (i) through (vii) of this paragraph with respect to the anhydrous ammonia refrigeration system and associated equipment and safety controls, on or about 7-9-14.

Issued

2014-12-05 00:00:00

Abate by

2015-09-12 00:00:00

Penalty

Initial $4900.00 · Current $2533.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(1): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process:    (a) Facility: The employer did not develop and implement written operating procedures that provide clear instructions for normal shutdown and for startup after an emergency shutdown for the two evaporative condensers, on or about 7-9-14.    (b) Facility: The employer did not develop and implement written operating procedures that provide clear instructions for startup after an emergency shutdown for the +15 and -20 Accumulators, on or about 7-9-14.    (c)  Facility: The employer did not develop and implement written operating procedures that provide clear instructions for the steps of each operating phase as required by 29CFR 1910.119(f)(1)(i)(A) through (G) for the Air-Cooling Evaporators used throughout the system, on or about 7-9-14.    (d) facility: The employer did not develop and implement written operating procedures for the Main Ammonia Solenoid Valve safety switch located outside of the engine room emergency exit, on or about 7-9-14.

Issued

2014-12-05 00:00:00

Abate by

2015-06-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1)(iii): The employer failed to ensure that the Process Safety Management Standard Operating Procedures included safety and health considerations:  (a) Facility: The employer's operating procedures for draining oil from the anhydrous ammonia system did not contain adequate instructions regarding the safety and health considerations for this procedure, including but not limited to the use of proper personal protective equipment including eye, face and respiratory protection, and the use and availability of emergency equipment and first aid procedures that may be required.

Issued

2014-12-05 00:00:00

Abate by

2015-06-20 00:00:00

Penalty

Initial $4900.00 · Current $2533.00 Reduced

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) Facility: The employer did not establish written procedures for the inspection of the pressure vessels and piping systems for detecting corrosion under insulation, on or about 7-9-14.    (b) Facility: The employer's procedures for testing of the ammonia detection system is inadequate in that it is in conflict with the manufacturers written testing procedure, on or about 7-9-14.    (c) Facility: The employer did not establish written procedures to maintain the on-going integrity of the Air-cooling evaporators utilized throughout the ammonia refrigeration system, on or about 7-9-14.    (d) Facility: The employer did not establish written procedures to maintain the on-going integrity of the pressure vessels and piping systems utilized throughout the ammonia refrigeration system, on or about 7-9-14.

Issued

2014-12-05 00:00:00

Abate by

2015-09-12 00:00:00

Penalty

Initial $4900.00 · Current $2533.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:    (a) Engine room: The employer did not perform engine oil analysis for the six compressors utilized in the anhydrous ammonia refrigeration system in accordance with its written maintenance schedule and manufacturers recommendations, on or about 7-9-14.    (b) Engine room: The employer did not perform vibration analysis for the six compressors utilized in the anhydrous ammonia refrigeration system in accordance with its written maintenance schedule and manufacturers recommendations, on or about 7-9-14.    (c) Engine room: The employer did not perform testing and calibration of the ammonia detection system utilized in the anhydrous ammonia refrigeration system in accordance with the manufacturers recommendations, on or about 7-9-14.    (d) Facility: The employer did not perform inspections and tests on the two condensers and their associated support structures which exhibited corrosion, to ensure that their mechanical integrity was maintained, on or about 7-9-14.    (e) Facility: The employer did not perform inspections and tests on the high pressure receiver and its associated support structure which exhibited corrosion, to ensure that its mechanical integrity was maintained, on or about 7-9-14.    (f) Engine room: The employer did not perform inspections and tests on the VD Vapor Ammonia line and the TSS Ammonia line which exhibited corrosion, to ensure that its mechanical integrity was maintained, on or about 7-9-14.

Issued

2014-12-05 00:00:00

Abate by

2015-06-20 00:00:00

Penalty

Initial $4900.00 · Current $2532.00 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they have evaluated compliance with the provisions of this section at least every three years:    (a) Facility: The employer had not conducted timely and complete compliance audits as required under 29CFR 1910.119(o), on or about 7-9-14.

Issued

2014-12-05 00:00:00

Abate by

2015-06-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(2)(i)(C): Process safety information pertaining to the technology of the process did not include the maximum intended quantity:  (a) Facility: The employer did not have an accurate calculation of the refrigeration system ammonia capacity on or about 7-9-14.

Issued

2014-12-05 00:00:00

Abate by

2015-06-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(g)(1)(i):  Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, was not trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks:  (a) Facility: Employees involved in operating the anhydrous ammonia refrigeration system were not adequately trained in the operating procedures, alarm systems, and emergency shutdown systems and procedures, on or about 7-9-14.

Issued

2014-12-05 00:00:00

Abate by

2015-06-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.120(q)(6): The employer did not provide training in accordance with 29 CFR 1910.120(q)(6)(i) through (q)(6)(v) for employees who participated in or were expected to participate in emergency response:  (a) Facility: The employer did not provide training in accordance with 29 CFR 1910.120(q)(6)(i) through (q)(6)(v) for employees who were designated as First Responders for the purpose of initiating an emergency response to an anhydrous ammonia release.