OSHA Inspection: CLIFFSTAR, CORPORATION LLC

Issued

Nov 9, 2015

Abate by

Dec 13, 2015

Penalty

Initial $4,250 · Current $4,250

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): The employer did not compile information pertaining to the equipment in the process: Relief system design.    a) On or about 5/27/15, the employer did not compile information pertaining to the relief system design including system design calculations for a 3-inch relief header connected to:       Suction accumulator (V-14) safety relief valves PSV 11022 and PSV 11023,   Dump tank (V-15) safety relief valves PSV 11025 and PSV 11081,  Oil Separator/RC4 (V-18) safety relief valves PSV 11026 and PSV 11027,   Oil Separator/RC5 (V-17) safety relief valves PSV 11031 and PSV 11032 and,  Heat Exchanger (H-13) safety relief valve PSV 11035 all vent into a 3 inch relief header (RV-05-C1).      ABATEMENT CERTIFICATION REQUIRED

Issued

Nov 9, 2015

Abate by

Dec 13, 2015

Penalty

Initial $4,250 · Current $0 Reduced

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):    (a) On or about 5/14/15, process safety information pertaining to the equipment in the process did not include the fixed ammonia detection systems that includes sensor ID AT01, AT02, ATV03, AT04, AT05, AT06, and AT07.  The process safety information did not include an explanation of how the fixed ammonia detection system works and what are the alarm notifications.      ABATEMENT CERTIFICATION REQUIRED

Issued

Nov 9, 2015

Penalty

Initial $4,250 · Current $0 Reduced

General-duty citation text

1910.119(d)(3)(ii) The employer did not document that equipment complies with recognized and generally accepted engineering practices.      a) Compressor room - On or about 5/14/15 , metal conduit from the Frick SUB2BRK9 480 VAC electrical box penetrates the compressor room wall to the processing area.  The compressor room wall was not sealed to prevent the escape of anhydrous ammonia vapor per recognized and generally accepted good engineering practices (RAGAGEP) such as, but not limited to, ANSI/ASHRAE Standard 15-2010, Safety Standard for Refrigeration Systems, Section 8.12c.  Employees in the processing area are exposed to a toxic inhalation hazard.    b) Compressor room - On or about 5/14/15, metal conduit from RCP1 Panel 12 electrical box penetrates the compressor room wall to the processing area. The compressor room wall was not sealed to prevent the escape of anhydrous ammonia vapor per recognized and generally accepted good engineering practices (RAGAGEP) such as, but not limited to, ANSI/ASHRAE Standard 15-2010, Safety Standard for Refrigeration Systems, Section 8.12c.  Employees in the processing area are exposed to a toxic inhalation hazard.    c) Compressor room - On or about 5/14/15, metal conduit from 120 VAC box penetrates the compressor room wall  to the boiler room.   The compressor room wall was not sealed to prevent the escape of anhydrous ammonia vapor per recognized and generally accepted good engineering practices (RAGAGEP) such as, but not limited to, ANSI/ASHRAE Standard 15-2010, Safety Standard for Refrigeration Systems, Section 8.12c.  Employees in the processing area are exposed to a toxic inhalation hazard.    d) Compressor room - On or about 5/14/15, metal conduit from Panel 13, sub 2, breaker 12 (480 VAC) penetrates the compressor room wall to the electric room.  The compressor room wall was not sealed to prevent the escape of anhydrous ammonia vapor per recognized and generally accepted good engineering practices (RAGAGEP) such as, but not limited to, ANSI/ASHRAE Standard 15-2010, Safety Standard for Refrigeration Systems, Section 8.12c.  Employees in the processing area are exposed to a toxic inhalation hazard.      NO ABATEMENT CERTIFICATION REQUIRED

Issued

Nov 9, 2015

Penalty

Initial $4,250 · Current $4,250

General-duty citation text

29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process:    a) On or about 7/16/15, Cliffstar LLC, Section #4 - Process Hazard Analysis, Rev. 04-01-2013 did not address the hazards associated with ammonia inbounding.      NO ABATEMENT CERTIFICATION REQUIRED

Issued

Nov 9, 2015

Abate by

Dec 13, 2015

Penalty

Initial $4,250 · Current $4,250

General-duty citation text

29 CFR 1910.119(f)(1)(i)(F): 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 should address at least the following elements: Normal shutdown.    a) On or about 5/14/15, the employer did not develop and implement written operating procedures that provide clear instructions for safely conducting high pressure safety, low pressure safety, and low oil pressure differential shut-off tests on the Frick #1 compressor.      b) On or about 5/14/15, the employer did not develop and implement written operating procedures that provide clear instructions for safely conducting high pressure safety, low pressure safety, and low oil pressure differential shut-off tests on the Frick #2 compressor.    c) On or about 5/14/15, the employer did not develop and implement written operating procedures that provide clear instructions for safely conducting high pressure safety, low pressure safety, and low oil pressure differential shut-off tests on the Frick #3 compressor.    ABATEMENT CERTIFICATION REQUIRED

Issued

Nov 9, 2015

Penalty

Initial $4,250 · Current $0 Reduced

General-duty citation text

1910.119(f)(1)(iii)(D) 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 should address at least the following elements: [D] Quality control for raw materials and control of hazardous chemical inventory levels:      a) On or about 5/14/15, Cliffstar LLC Standard Operating Procedure Dunkirk Processing High Pressure Receiver SOP #DPRREC, Version #1, effective date 4/10/13 does not address quality control of incoming ammonia in that an ammonia certificate of analysis is not required.    NO ABATEMENT CERTIFICATION REQUIRED

Issued

Nov 9, 2015

Penalty

Initial $4,250 · Current $0 Reduced

General-duty citation text

1910.119(f)(4) The employer must develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel.  These safe work practices must apply to employees and contractor employees.    a) On or about 5/27/15, the employer failed to document ammonia line breaking procedures used by a contractor.    NO ABATEMENT CERTIFICATION REQUIRED

Issued

Nov 9, 2015

Penalty

Initial $3,400 · Current $3,400

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) Compressor room - On or about 5/14/15, the Ingersoll Rand HRM air dryer was connected to an extension cord.  The extension cord was plugged into a dual outlet receptacle (120 volts).    (b) Compressor room - On or about 5/14/15, a dial controller was connected to an extension cord.  The extension cord was plugged into a dual outlet receptacle and was attached to the wall.     NO ABATEMENT CERTIFICATION REQUIRED

Issued

Nov 9, 2015

Abate by

Dec 29, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1026(l)(1)(ii): The employer did not address at least the following hazards with employees exposed to hexavalent chromium: Cancer, eye irritation, and skin sensitization and 29 CFR 1910.1026(l)(1)(iii): The employer did not include chromium (VI) in the hazard communication program, established to comply with the Hazard Communication Standard, 29 CFR 1910.1200, ensure that each employee had access to labels on containers of chromium (VI) and to safety data sheets, and was trained in accordance with the requirements of the Hazard Communication Standard and 29 CFR 1910.1026:    a) Plant - On or about 5/27/15, an employee conducts TIG welding on stainless steel pipe.  The employer did not address at least the following hazards with employees exposed to hexavalent chromium: Cancer, eye irritation, and skin sensitization.  In addition, the employer did not include hexavalent chromium in the hazard communication program.      ABATEMENT CERTIFICATION REQUIRED