OSHA Inspection: AMERIGAS PROPANE, LP

Issued

Sep 24, 2015

Abate by

Nov 12, 2015

Penalty

Initial $7,000 · Current $7,000

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:  Terminal:  On, or about, August 5, 2013, the company did not have process safety information related to the cathodic protection system that was installed on buried piping that led from Tank 3 to the terminal building to provide liquefied petroleum gas for the building heating system and the emergency generator.

Issued

Sep 24, 2015

Abate by

Nov 12, 2015

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(d)(3)(iii): For existing equipment designed and constructed in accordance with codes, standards, or practices no longer in general use, the employer did not determine and document that the equipment in the process was designed, maintained, inspected, tested, and operating in a safe manner:    Terminal:  On, or about, April 23, 2015, the company had not documented that Tank 3, a Cherokee Steel Model P-300 30,000 gallon storage tank used to store liquefied petroleum gas, had been designed, maintained, inspected and tested in a safe manner.

Issued

Sep 24, 2015

Abate by

Nov 12, 2015

Penalty

Initial $5,500 · Current $7,000

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:    Terminal:  On, or about, April 23, 2015, the initial Process Hazard Analysis dated September 2, 2008 and the revalidated Process Hazard Analysis dated July 11, 2013 for the covered process did not include a qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace for each of the "What If" scenarios included in the PHA in that none of the scenarios listed safety and health effects such as, but not limited to, freeze burns or third degree burns.

Issued

Sep 24, 2015

Abate by

Nov 12, 2015

Penalty

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

General-duty citation text

29 CFR 1910.132(c): Personal protective equipment was not of safe design and construction for the work to be performed:    A. Rail Yard Tower Platforms:  On, or about, April 23, 2015, employees unloading railcars were provided with personal fall arrest systems that were rigged in such a way that the potential fall distance was approximately 10 feet.  The retractable lanyard was attached to the anchor point on the railcar below the "D" ring provided on the harness, which was not in accordance with the manufacturer's requirements.    B. Rail Yard Tower Platforms: On, or about, April 23, 2015, the employer lacked rescue Procedures to be followed in the event that an employee fell while working on the top of the tank cars located in the rail yard. Employees were required to used personal fall arrest systems when working on the top of the tank cars and a large portion of the rail yard was not visible from the terminal area.

Issued

Sep 24, 2015

Penalty

Initial $27,500 · Current $42,000

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:     On, or about, April 23, 2013, the Compressor Room P&ID did not show an accurate reflection of the state of the equipment:      A.  The second compressor was not included in the diagram  B.  A pressure gauge that had been removed from the piping system was still depicted.  C.  Valve 207 was tagged as Valve 206.        AmeriGas Propane, LP was previously cited for a violation of this occupational safety and health standard, which was contained in OSHA Inspection Number 735302, Citation Number 1, Item Number 1 and was affirmed as a final order on July 29, 2013, with respect to a workplace located at Conroe, Texas.

Issued

Sep 24, 2015

Abate by

Nov 12, 2015

Penalty

Initial $38,500 · Current $7,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment:    Terminal:  On, or about, April 23, 2015, the employer had not established adequate written procedures to maintain process equipment in that:    A.  The company had not developed nor implemented written inspection and testing procedures for six pressurized liquid petroleum storage tanks.      B.  The company had not developed nor implemented written inspection and testing procedures for an underground piping system that was installed between Tank 3 and the terminal building.      AmeriGas Propane, LP was previously cited for a violation of this occupational safety and health standard, which was contained in OSHA Inspection Number 735302, Citation Number 1 Item Number 12a and was affirmed as a final order on July 29, 2013, with respect to a workplace located at Conroe, Texas.

Issued

Sep 24, 2015

Abate by

Nov 12, 2015

Penalty

Initial $38,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(ii): The employers inspection and testing procedures did not follow recognized and generally accepted good engineering practices (RAGAGEP):    Terminal:  On, or about, April 23, 2015, the employer had not performed inspections and tests on the following equipment that was consistent with recognized and generally acceptable good engineering practices:    A.  Storage tanks 1-6 were not subject to inspection and testing methods and frequencies that followed RAGAGEP.  Examples of RAGAGEP include but are not limited to the National Board Inspection Code, NB23 sections:       4.4.7 - Determining Inspection Intervals  4.4.7.3 - Estimating Inspection Intervals for Pressure-Retaining Items   S7.3.1 - Nondestructive Examination (NDE)  S7.4 - External Inspection     B.  A piping system that was installed between Tank 3 and the terminal building to supply propane for the heating system in the building and the emergency generator was not subject to inspection and testing methods and frequencies that followed RAGAGEP.  Examples of RAGAGEP include but are not limited to:       American Petroleum Institute (API) Standard 570 - 2009, Piping Inspection Code:  In-service Inspection, Rating, Repair and Alteration of Piping Systems.  Relevant sections include but are not limited to:      5 - Inspection, Examination, and Pressure Testing Practices  6 - Interval/Frequency and Extent of Inspection  9 - Inspection of Buried Piping      American Petroleum Institute (API) Standard 651 - 2014, Cathodic Protection of Aboveground Petroleum Storage Tanks, specifically Section 11 - Operation and Maintenance of Cathodic Protection Systems.    AmeriGas Propane, LP was previously cited for a violation of this occupational safety and health standard or its equivalent standard [29 CFR 1910.119(j)(4)(i)], which was contained in OSHA Inspection Number 735302, Citation Number 1, Item Number 13 and was affirmed as a final order on July 29, 2013, with respect to a workplace located at Conroe, Texas.

Issued

Sep 24, 2015

Abate by

Nov 12, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): Information pertaining to the equipment and process did not include design codes and standards that were employed:  Terminal:  On, or about, April 23, 2015, the process safety information related to the railcar unloading terminal operations did not include design codes and standards regarding the location of storage tanks.