OSHA Inspection: WEST VIRGINIA AMERICAN WATER COMPANY

Issued

Dec 12, 2014

Penalty

Initial $3,000 · Current $2,100 Reduced

General-duty citation text

29 CFR 1910.23(a)(8)(ii): Every floor hole into which persons could accidently walk was not guarded by a floor hole cover of standard strength and construction:    (a)  South Basins Valve Platform: The floor of the grating had two unguarded holes that employees could step into that each measured one foot by one foot as observed on September 5, 2014.

Issued

Dec 12, 2014

Abate by

Dec 24, 2014

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): Information pertaining to the equipment in the process did not include design codes and standards that were employed.    (a) Chlorine Building:  The employer did not determine and document the design codes and standards that would be employed for the design and use of the chlorine gas detection system that measured chlorine gas levels inside the chlorine building and alerted employees to a chlorine gas leak as determined on or about September 10, 2014.    ABATEMENT CERTIFICATION REQUIRED.    Abatement Note:  Proper abatement would be to document a Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) that the facility will follow such as, but not limited to, industry standard NFPA 55 Compressed Gases and Cryogenic Fluids Code 2010 Edition Section 7.9.3.2.2.4.

Issued

Dec 12, 2014

Abate by

Dec 24, 2014

Penalty

Initial $5,000 · Current $3,500 Reduced

Hazardous substances 0640

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 further use:    (a) Chlorine Cylinder Room:  The flexible copper tubing that connects the one-ton chlorine cylinders to the chlorine headers were not replaced at least every three years or twenty cylinder changes per the manufacturer's instructions in that eight of the ten flexible connectors that were connected for use were older than three years and/or were disconnected greater than twenty times as determined on or about September 10, 2014.    (b) Chlorine Building:  Equipment used on site did not comply with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) in that the ADVANCE Gas Detection system that measured chlorine gas levels and alerted employees to a chlorine gas leak was set to alarm at 3 parts per million of chlorine which is three times the OSHA ceiling limit as determined on or about September 10, 2014.    ABATEMENT CERTIFICATION REQUIRED.    ABATEMENT NOTE:  Proper abatement of instance (b) would be to follow NFPA 55 Compressed Gases and Cryogenic Fluids Code 2010 Edition Section 7.9.3.2.2.4 which states to set chlorine detection alarms for employees to activate when they reach the OSHA ceiling limit.

Issued

Dec 12, 2014

Abate by

Dec 24, 2014

Penalty

Initial $5,000 · Current $3,500 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the consequences of failure of engineering and administrative controls:    (a)  Chlorine Building:  The Process Hazard Analysis (PHA) developed for the use of chlorine on site did not address the consequence of failure of engineering and administrative controls including, but not limited to, the failure of the chlorine gas detection system, the gas detection alarms, and the chlorine scrubber system as determined on or about September 10, 2014.    ABATEMENT CERTIFICATION REQUIRED.

Issued

Dec 12, 2014

Abate by

Jan 2, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(e)(3)(vii): The process hazard analysis did not address a qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace:    (a)  Chlorine Building:  The Process Hazard Analysis (PHA) developed for the use of chlorine on site did not discuss any potential consequences and degree of injury or illness to employees so that the PHA team can appropriately address the potential need for additional controls or procedures as determined on or about September 10, 2014.    ABATEMENT CERTIFICATION REQUIRED.

Issued

Dec 12, 2014

Abate by

Dec 24, 2014

Penalty

Initial $5,000 · Current $3,500 Reduced

Hazardous substances 0640

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) Chlorine Building:  Written procedures were not developed for maintaining the mechanical integrity of the chlorine system including, but not limited to, safe equipment and line opening procedures and inspections for the integrity of the metal piping and piping components that are exposed to chlorine gas as determined on or about September 10, 2014.    ABATEMENT CERTIFICATION REQUIRED.

Issued

Dec 12, 2014

Abate by

Jan 2, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:  (a)  Chlorine Cylinder Room: Inspections were not conducted on process piping and equipment that contains chlorine gas to determine the integrity of the piping and equipment, such as inspecting for corrosion, and calculating the remaining life of the piping and equipment prior to failure as determined on or about September 10, 2014.  ABATEMENT CERTIFICATION REQUIRED.

Issued

Dec 12, 2014

Abate by

Jan 2, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 0640

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)  Chlorine Building:  The ADVANCE brand gas detector that was used to measure leaks of chlorine gas was not calibrated at least monthly and after an exposure, as required by the manufacturer of the instrument, in that the last calibration was conducted on April 29, 2014 and the last exposure high enough to set off the alarm was August 13, 2014 as determined on or about September 8, 2014.  ABATEMENT CERTIFICATION REQUIRED.  ABATEMENT NOTE:  The manufacturer of the equipment recommends calibrating the instrument on a weekly basis and after each exposure.

Issued

Dec 12, 2014

Penalty

Initial $4,000 · Current $2,800 Reduced

General-duty citation text

29 CFR 1910.23(a)(3)(i):   When a floor opening was not in use, the hinged floor opening cover was not closed or the exposed side was not guarded at both top and intermediate position by removable standard railings:    (a)    Raw Water Pump Room:  Employees were exposed to a seventeen foot fall hazard in that a hatchway leading down to the water sump pumps had a hatch cover that was not closed and there were no standard railings on all exposed sides in that the ends of the chain railing were fifty-one inches high and the mid rail chain was not positioned midway between the floor and the top rail chain as observed on September 5, 2014.

Issued

Dec 12, 2014

Abate by

Dec 24, 2014

Penalty

Initial $5,000 · Current $3,500 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.36(d)(1): Employee(s) were not able to open an exit route door from the inside at all times without keys, tools, or special knowledge:    (a)  Chlorine Cylinder Room:  Exit doors located on the North side of the room did not operate without special knowledge in that they were equipped with a panic bar that did not function when operated due to the doors were also equipped with chain operated latches that had to be operated first as observed on September 5, 2014.    ABATEMENT CERTIFICATION REQUIRED

Issued

Dec 12, 2014

Abate by

Dec 24, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.36(d)(2): Exit route doors were not free of any device or alarm that could restrict emergency use of the exit route if the device or alarm failed:    (b)  Chlorine Cylinder Room:  Exit doors located on the North side of the room were equipped with floor latches that if engaged could inhibit or prevent immediate evacuation through the doors during a leak of chlorine gas as observed on September 5, 2014.      ABATEMENT CERTIFICATION REQUIRED

Issued

Dec 12, 2014

Abate by

Dec 24, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(E): 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 and did not address any special or unique hazards:  (a)  Chlorine Cylinder Room:  The written operating procedures for changing cylinders did not address the hazard of assuring that all cylinders connected to a single manifold are the same temperature to prevent accidental liquefaction of the chlorine in the vapor space of the tank, the flexible whip connector, or the chlorine piping as determined on or about September 10, 2014.  ABATEMENT CERTIFICATION REQUIRED.

Issued

Dec 12, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.305(g)(1)(iv)(A): Flexible cords and/or cables were used as a substitute for the fixed wiring of a structure:  (a)  Raw Water Pump Room:  The 24 volt Redundant Transmitting Unit (RTU) was powered on a continuous basis for one month using two connected extension cords coming from a standard wall outlet that were connected into a 110 volt power converter as observed on September 5, 2014.  (b)  Chlorine Cylinder Room:  Five electrical heat trace lines on a chlorine manifold were continuously powered by a power strip which was then plugged into a wall outlet using an extension cord as observed on September 5, 2014.