OSHA Inspection: COSTAR MIDSTREAM, LLC

Issued

Aug 17, 2015

Abate by

Sep 8, 2015

Penalty

Initial $4,500 · Current $1,900 Reduced

General-duty citation text

1910.119(d)(3)(i)(C): The employer's information pertaining to the equipment in the process did not include electrical classification:    a) The employer's information pertaining to the equipment in the process did not include electrical classification.  The employer did not document all areas designated as hazardous (classified) locations under the Class and Zone system and areas designated under the Class and Division system.  The employer's information pertaining to the equipment did not include an updated electrical classification map in areas that are classified as Class I Division II.   The facility's electrical classification map had not been updated since 2006.

Issued

Aug 17, 2015

Abate by

Jun 30, 2016

Penalty

Initial $6,300 · Current $1,900 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) The employer did not document that the Control Room, Administrative, and Instrumentation and Electronics buildings, comply with recognized and generally accepted good engineering practices, such as, but not limited to, API 752 Facility Siting for Permanent Buildings Sections; thereby allowing employees to occupy inadequately protected structures exposed to explosion, fire, toxic material, or high pressure hazards resulting from the release of highly hazardous chemicals from process equipment.       b) The employer did not implement a system for the positive identification of the contents of piping systems with sufficient detail such as contents, direction of flow, temperature, and pressure, etc.; as is necessary to identify the hazard to comply with recognized and generally accepted good engineering practices, such as, but not limited to, ASME A13.1-2007.  The labeling of the following piping circuits was not in accordance with did not ASME A13.1-2007.        3 G-595-A-D             Gas  2 G-1065-A-B            Gas  6 G-3011-A-D            Gas  6 G-3012-A-D            Gas  6 G-3017-A-D            Gas  6 G-3035-A-D            Gas  2 G-3022-A-D            Gas  8 G-3032-A-D            Gas  6 G-3036-A-D            Gas    4 NG-348-A-B            Natural Gas Liquids  2 NG-567-A-B            Natural Gas Liquids   3 NG-568-A-B            Natural Gas Liquids   2 NG-606-A-A            Natural Gas Liquids   2 NG-639-A-A            Natural Gas Liquids   2 NG-674-A-A            Natural Gas Liquids   2 NG-683-A-A            Natural Gas Liquids   2 NG-690-A-A            Natural Gas Liquids       8 RP-721-A-B             Refrigerant Propane  8 RP-724-A-B             Refrigerant Propane

Issued

Aug 17, 2015

Abate by

Jun 30, 2016

Penalty

Initial $6,300 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting:    On or about February 17, 2015, the employer's 2014 process hazard analysis was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in the process. The employer's 1993, 1998, 2004, 2009 and 2014 process hazard analysis did not address facility siting as follows:    a) The 1993 facility siting process hazard analysis and all subsequent process hazard analyses (1998, 2005, 2009, and 2014) have not included a blast study; thus allowing employees to occupy potentially inadequately protected (i.e., not adequately protected by separation or building construction) structures. This exposes employees to explosion, fire, toxic material, or high pressure hazards resulting from the release of highly hazardous chemicals from process equipment. Buildings that are located in unacceptable areas of the blast zone include the Administrative building (Plant Office), Service Building (Instrumentation and Electronics), and Control Room/Building, and Truck loading/unloading building.    b) Responses to potential problem reports included in the 1993 process hazard analysis are no long being implemented.    c) The 2004 process hazard analysis which included the addition of the E/P Treater, GWG Chiller and GWG Cryo Plant was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in the risk of additional process equipment and flammable materials.    d) 2012 and 2014 process hazard analysis for the truck/loading was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in having tanker trucks (containing flammable materials) traffic adjacent to the Cryo Unit vessels and occupied buildings.    e) Motor vehicle usage inside the plant.    f) Failed to carry out building siting evaluations for existing buildings intended for occupancy in accordance with Section 6, Section 7, and Section 8 of API 752 as part of their process hazard analysis.

Issued

Aug 17, 2015

Abate by

Sep 29, 2015

Penalty

Initial $6,300 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team's findings and recommendations;  assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions:    The employer did not establish a system to promptly address the team's findings and recommendations to assure that the recommendations identified in the 2014 Process Hazard Analysis (PHA) are resolved in a timely manner and completed as soon as possible.  The 2014 PHA does not contain a written schedule of when the recommended actions are to be completed for the following items:    a) 1614 - CSO the Pump PSV isolation valves and update P&IDs.    b) 1512 - Consider car sealing open the 2" 300# drain valve on V-511 (2°d stage suction scrubber for C-37-40), to prevent overpressure from line# 3210. Update P&ID accordingly.    c) Start-up bypass valves Ensure the G\'('G compressor start-up and loading procedures (and operator training) address the backflow leading to potential overpressure from a discharge check valve leak. The suction valves should stay open unless the unit is down for maintenance and isolated.    d) 1502 - Review the need and sizing basis for PSVs on E-502 (shell and tube side).    e) 1283A/1284 - Consider adding PSVs on F-310, and F-316 for code compliance.    f) 1269-1271 - Add the low level transfer pump shutdown on the truck tanks to the P&IDs.    g) 1247C - Consider disconnecting  or installing a spec blind on 2" vapor line #3128 to eliminate the possibility of accidently connecting the vapors from V-210 to those from the Raw Surge tanks.    h) 1246A - Consider adding a thermal/fire sized PSV for AC-237A/B.    i) Car seal open the ANSI 150# valves on the King and Cole scrubbers.    j) Automate the King/Cole scrubber pump controls.    The employer did not establish a system to promptly address the team's findings and recommendations to assure that the recommendations identified in the 2009 Process Hazard Analysis (PHA) are resolved in a timely manner and completed as soon as possible.  The 2009 PHA does not contain a written schedule of when the recommended actions are to be completed for the following items:    k) PPR 1233: PSV-P5a should be replaced with a balanced valve set as close to 450 psig as possible.  Consider programming a pressure override on FV-4106.  As of November 2014 this 2009 PHA item had still not yet been corrected/completed.    l) PPR 1515/1515a: A relief valve will be installed to protect the lower rated piping. Consider car sealing them to open to reduce the likelihood of them being closed without isolation of the high pressure feed first.     m) PPR 93: A relief valve will be installed to protect the lower rated piping.  As of November 2014 this 2009 PHA item had still not yet been corrected/completed.    n) PPR 91/1511A: Murphy switch gauges will be added to the 1st Stage discharge on all Gas-Well-Gas compressors.  As of November 2014 this 2009 PHA item had still not yet been corrected/completed.

Issued

Aug 17, 2015

Abate by

Sep 8, 2015

Penalty

Initial $4,500 · Current $1,900 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.    On or about February 17, 2015 the employer does not ensure that written operating procedures were developed and implemented for the collection of samples of flammable liquids and vapors from process equipment.  Written procedures have not been developed for sampling such as but not limited to the following:    a) Measuring H2S gas concentration at the flare   b) Collecting samples at the GWG Cryo Inlet  c) Collecting samples of lean glycol from the glycol system

Issued

Aug 17, 2015

Abate by

Aug 24, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not certify annually that operating procedures were current and accurate:  The employer did not ensure that the operating procedures for the Longview Gas Plant are certified annually for the years 2012, 2013, and 2014.  Operating procedures that had not been certified annually include:  a) Glycol System Normal Operation  b) Amine System Normal Operation  c) Cryo Plant Normal Operation  d) Gas Well Gas Inlet System  e) Gas Well Gas Cryo Plant  f) Gas Well Gas Chiller System  g) Scrubber Oil System Normal Startup and Shutdown Operation

Issued

Aug 17, 2015

Abate by

Jun 30, 2016

Penalty

Initial $6,300 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not conduct inspections and tests of process equipment:    On or about February 17, 2015 the employer did not conduct testing and inspection of pressure vessels.    a) The employer did not conducting internal inspections of its pressure vessels. The employer did not complete internal visual inspections for its pressure vessels as specified by consensus standards, such as, but not limited to API 510.  API 510 recommends an internal visual inspection of pressure vessels every 10 years. There were no records available indicating that internal visual inspections had been performed on pressure vessels, such as but not limited to the following: V-20, V-30, V-31, V-110, V-120, V-130, V-210, V-221, V-222, V-231, V-404 V-501, V-511, V-535, V-630, V-810, D1-A, D1-B, T-5, T-6, T-340, T-350, T-360, T-830, T-1276, E-21A, E-21B, F-316    b) Where entrance is not possible, internal inspections may require other techniques described in API 510 and API 572 such as but not limited to acoustic emission, magnetic scanning, and AUT systems, and remote visual inspection techniques using inspection ports.  No records were available indicating that any of these techniques had been performed on pressure vessels, such as but not limited to the following: V-201, V-202, V-203, V-204, V-205, V-206, V-207, V-208, V-210, V-215

Issued

Aug 17, 2015

Abate by

Sep 30, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(ii): Inspection and testing procedures did not follow recognized and generally accepted good engineering practices:    On or about February 17, 2015, the employer did not conduct inspections and testing in accordance with API 510, such as but not limited to the following instances:    a) The employer has not provided access to possible confined spaces so that inspection and testing of pressure vessels and piping could be conducted.  The employer did not complete inspections of process equipment as specified by consensus standards, such as but not limited to API 510.  API 510 Section 6.5.2.5 requires that the inspector be given sufficient access to all parts of the vessel so that an accurate assessment of the vessel condition can be made.  Inspection records for the past ten year indicate that UT and visual inspections were limited due to access, such as but not limited to the following vessels: CB31D, CB12D, 261D, CB271D, CB272D, 281D, 301D, 302D, 311D, 312D, 313D, 361D     b) The employer did not complete inspection and testing of process equipment as specified by consensus standards, such as but not limited to API 510, Section 6.5.1.1.  Inspection records indicate that the following pressure vessels have not had visual or UT inspections during the past ten years in accordance with API 510: V-5, V-6, V-7, V-8, V-9, V-11, V-13, V-270, V-300, V-318, V-320, V-502, V-620, V-661, V-662, V-1250, V1260     c) The employer did not to complete inspection and testing of process equipment as specified by consensus standards, such as but not limited to API 570, Section 6.3.3.  Inspection records indicate that Midstream did not schedule inspection intervals; not to exceed the lesser of one half the remaining life of the pipe as determined from corrosion rates indicated in API 570, Section 7.1.1.1 or the maximum intervals recommended in Table 2:      - Piping circuit 3 G-3061 A-D, located in the New Cryo Area was inspected on August 2, 2011 and (TML 2.02) the pipe was found to have a remaining life of 6.87 years. The pipe was not inspected in 3.4 or 5 years in accordance with API 570, Section 6.3.3.   -Piping circuit 2 G-3022 - A-B, located in the Liquid Product Storage Area was inspected on October 3, 2005 and the pipe was found to have a remaining life of 6.1 years. The pipe was not inspected in 3.0 or 5 years in accordance with API 570, Section 6.3.3.  -Piping circuit 6 NG-3090 A-B, located in the Liquid Product Storage Area was inspected on October 10, 2005 and the pipe was found to have a remaining life of 5.6 years. The pipe was not inspected in 2.8 years in accordance with API 570, Section 6.3.3.      d) The employer did not to complete inspection and testing of process equipment as specified by consensus standards, such as, but not limited to, API 510, Section 6.5.1.1.  Inspection records indicate that the inspection period between internal or on-stream inspections and thickness measurement inspections exceeded one-half the remaining life of the pressure vessel and whenever the remaining life is less than four years, the inspection interval exceeded a maximum of two years for E/P Mix Tank V-210 and V-345 North Glycol after Scrubber.

Issued

Aug 17, 2015

Abate by

Mar 31, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The employer did not ensure that the frequency of inspections and tests of process equipment was consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:    The employer did not ensure that the frequency of inspections and tests of process equipment was consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.     a) American Midstream is not completing visual inspections of its pressure vessels within the timeframes specified by consensus standards such as but not limited to API 510.  API 510 recommends a visual inspection of all pressure vessels a minimum of every 5 years. The following pressure vessels have not had a visual inspection in accordance with API 510, such as but not limited to API 510.        Pressure Vessels:  -Initial inspection conducted in 2005; visual not performed by 2010: V-53, V-60, V-131, V-132, V-524, V-670, T-1270, T-1275, T-1276, T-1277    -Initial inspection conducted in 2006; visual not performed by 2011: V-15, V- 30, V-31, V-404, V- 620, F-316    -Initial inspection conducted in 2007; visual not performed by 2012: V-115, V-120, V-130, V-135, V-140, V-150, V-345, V-355, V-365, V-401, V-405, V-501, V-505, V- 511, V-512, V-730, T-340, T-350    -Initial inspection conducted in 2008; visual not performed by 2013: V-10, T-5, T-6, E-18, E19A, E19B, E-20, E21A, E21B, E-22    -Initial inspection conducted in 2009; visual not performed by 2014: V-20, E-46, E-47    b) Midstream Partners is not completing visual inspections of its Class I Piping within the timeframes specified by consensus standards such as but not limited to API 570.  API 570 recommends a visual inspection and UT testing of all Class 1 piping a minimum of every 5 years. The following piping had not had a visual inspection or UT testing in accordance with, but not limited to API 570.        Last visual and tested in 2009; not performed by 2014:  V-20 Inlet  6 RP-275-A-A   V-20 Outlet  6 RP-552-A-A  C-3 startup bypass 6 RP 562-A-A  C-2 Discharge  8 RP-557-A-B  C-1 Discharge  8 RP-549-A-B  C-1 Interstage Low Pressure Vent 8 LV 553-A-A  C-3 Discharge  6 RP-564-A-A  C-3 Inlet  12 RP-561-A-A  C-1 Fuel Gas Supply 3 FG C-1  CB-11D Low Pressure Vent 3 LVC C-1    D-1A Regen Out  4 G 229 A-A   D-1B Regen Out 4 G 240 A-A  E-1 Outlet  4 G 241 A-AA  C-1 Bypass  4 G 246 A-A  C-1 startup bypass 4 RP 548-A-A    Last visual and tested in 2008; not performed by 2013:  6 NG-487-A-B  6 NG-488-A-B   4 NG-451-A-B   4 NG-452-A-B  4 NG-448-A-B  3 NG-444-A-B  6 G-3011-A-D    Last visual and tested in 2007; not performed by 2012:  V-512 Inlet 6 G-Unknown-4-A-B  V-522 Inlet 6 G-Unknown-5-A-B  E-511 Inlet 8 G-3014-A-B  V-365 Outlet 6 G-3122-A-D  T-350 Inlet 6 G-426-A-D  V-130 Inlet 8 G-110-A-B  And Piping circuits identified as Index #1-15, 17-40 (see exhibit A)    Last visual and tested in 2006; not performed by 2011:  12 G-021-A-A/12 G-022-A-A    2 GL-128-A-B  4 NG-470-A-B  3 NG-3001-A-B  4 NG-3002-A-B  4 RP-3026-A-A  4 RP-3026-A-A (2)  10 RP-279-A-A  12 RP-551-A-A    Last visual and tested in 2005; not performed by 2010:  6 G-3017-A-D  And Piping circuits identified as Index # 2, 3, 14-18, 20-29, 35-37, 39-45 48-50, 52-54 (see exhibit B)

Issued

Aug 17, 2015

Abate by

Sep 30, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employers did not correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation:    The employer did not correct deficiencies in equipment that are outside acceptable limits in a safe and timely manner.      a) Inspection and testing results performed in in October 2012 for pressure vessel E/P Mix tank V-210 indicated significant corrosion/ metal (wall) loss below the calculated remaining life of the vessel. The employer did not conducted further inspections, rerated, or retired V-210.    b) Inspection and testing results performed in October 2005 indicate that the following piping circuits were in operation below their calculated retirement thickness:  -Piping circuit 2 G-3022 A-B, located in the Liquid Product Storage Area was inspected on October 3, 2005 and the pipe was found to have a remaining life of 6.1 years. The pipe was not inspected in 3.0 years and has not been retired or rerated as of February 17, 2015.    -Piping circuit 6 NG-3090 A-B, located in the Liquid Product Storage Area was inspected on October 10, 2005 and the pipe was found to have a remaining life of 5.6 years. The pipe was not inspected in 2.3 years and has not been retired or rerated as of February 17, 2015.      c) PSV 830A: A Mercer conventional PSV was incorrectly installed on the GWG Demethanizer pump P830A. The correct valve is the pilot type PSV which is least effected by backpressure.

Issued

Aug 17, 2015

Abate by

Dec 31, 2015

Penalty

Initial $4,500 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process:    Written management of change procedures were not implemented for the following changes to the equipment:    d) On or about February 24, 2014, no management of change document was prepared for the addition of a 3 flange and 3 valve to an unload line at the South Scrubber Oil Tanks.    e) On or about September 22, 2014, no management of change document was prepared for the addition of a new 3 blowdown line at the truck scales.     g) No management of change document was prepared for the addition of 2 discharge piping for the API north water pumps.    h) No management of change document was prepared for the addition of glycol cooler piping.    I) No management of change document was prepared for the addition of a west transfer pump for the BG tanks.

Issued

Aug 17, 2015

Abate by

Dec 31, 2015

Penalty

Initial $4,500 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected:    The employer did not promptly document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected. The employer did not document that the following items identified in the 2009 and/or 2013 compliance audit had been corrected.     a) Procedure for annual certification had not been implemented.  b) Inspections of pressure vessels and piping had not been completed and inspection frequencies were not current.  c) Safety critical switches and transmitters are not being tested.  d) High pressure shutdowns have not been added to the Gas Well Gas Compressors.  e) Electrical Classification drawing had not been updated.

Issued

Aug 17, 2015

Abate by

Dec 31, 2015

Penalty

Initial $4,500 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.120(q)(2)(i):The employer did not develop an emergency response plan for emergencies that addressed pre-emergency planning and coordination with outside parties:    a) On or about February 17, 2015, the employer did not develop an emergency response plan that addressed pre-emergency planning and coordination with outside parties. The emergency response plan did not include pre-emergency planning or coordination with the White Oak Fire Departments, such as but not limited to the following provisions:     Solicit and document information from responding agencies and personnel regarding their availabilities and capabilities.  Identify all participants and their respective responsibilities.  Identify life safety hazards, including emergency response safety.  The facilities emergency response capabilities.  Structure size and operation complexity.  Presence of hazardous materials, flammable, reactive and toxic materials including the inventory, storage and use locations.  The pre-incident plan did not include provisions for responders to visit the site so they could become familiar with the layout contents, construction and protection features.  Mock drills to test the implementation of the plan.

Issued

Aug 17, 2015

Abate by

Sep 8, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.120(q)(8)(i): Employees who were trained in accordance with paragraph (q)(6) of this section did not receive annual refresher training of sufficient content and duration to maintain their competencies, or did not demonstrate competency in those areas at least yearly:  a) The employer did not train employees in accordance with paragraph (q)(6) of this section they did not receive annual refresher training of sufficient content and duration to maintain their competencies, or did not demonstrate competency in those areas at least yearly.  Employees who may be involved in an emergency rescue or may be required to contain or stop a release from spreading, and prevent exposures were not provided annual refresher training in 2014.

Issued

Aug 17, 2015

Abate by

Aug 24, 2015

Penalty

Initial $6,300 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.132(a): Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, was not used wherever it was necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact:    a) Protective equipment, including personal protective clothing was not used by employees wherever it is necessary by reason of hazards of processes or environment, or chemical hazards, encountered in a manner capable of causing injury or impairment in the function of any part of the body due to fire. Operations and maintenance employees were not required to wear flame-resistant clothing (FRCs) during their normal course of work.

Issued

Aug 17, 2015

Abate by

Mar 31, 2016

Penalty

Initial $4,500 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.134(f)(2): Employees using a tight-fitting facepiece respirator were not fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter:    a) The employer did not provide fit tests annually for employees who may use tight-fitting self-contained breathing apparatus respirators in an emergency rescue situation.

Issued

Aug 17, 2015

Abate by

Mar 31, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(k)(5): Retraining was not administered annually:     a) The employer did not provide effective comprehensive, understandable training annually to employees who are required to use self-contained breathing apparatus respirators. Employees who may use tight-fitting self-contained breathing apparatus respirators in an emergency rescue situation were not provided training annually.

Issued

Aug 17, 2015

Abate by

Mar 31, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.34(m)(1): Records of medical evaluations required by this section were not retained and made available in accordance with 29 CFR 1910.1020:    a) The employer did not establish and retain written information regarding medical evaluations for employees.  Records of medical evaluations, including the respirator medical determinations and questionnaires were not retained in accordance with 29 CFR 1910.1020 "Employee medical records." The medical record for each employee was not preserved and maintained for at least the duration of employment plus thirty (30) years.

Issued

Aug 17, 2015

Abate by

Sep 8, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(h)(3)(iv)(A): The employer did not certify respirators maintained for emergency use, by documenting the date the inspection was performed, the name (or signature) of the person who made the inspection, the findings, required remedial action, and a serial number or other means of identifying the inspected respirator:  a) Respirators maintained for use by employees for emergency situations were not certified, by documenting the date the inspection was performed, the name (or signature) of the person who made the inspection, the findings, required remedial action, and a serial number or other means of identifying the inspected respirator.  There was no documentation of certification for five Self-Contained Breathing Apparatus (SCBA) respirators located in a cabinet on the floor beneath the control room.

Issued

Aug 17, 2015

Abate by

Dec 31, 2016

Penalty

Initial $6,300 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.147(c)(4)(ii): The energy control procedures did not clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, 29 CFR 1910.147(c)(4)(ii)(A), (c)(4)(ii)(B), (c)(4)(ii)(C), and (c)(4)(ii)(D):      a) The procedure for the change-out of process filters, which requires the opening of process equipment, did not include the following: specific statement of the intended use of the procedure; specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy; specific procedural steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them; and, specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures.

Issued

Aug 17, 2015

Abate by

Aug 24, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(5)(ii): Lockout devices and tagout devices were not singularly identified, and did not meet the requirements in paragraphs (A) through (D):  Tagout devices used on valves and piping during the opening of process equipment and the removal of a filter were not singularly identified and did not meet the following requirements:  a) Pink ribbons used as tagout devices were not constructed and printed so that exposure to weather conditions or wet and damp locations would not cause the tag to deteriorate or the message on the tag to become illegible.  b) Pink ribbons used as tagout devices, including their means of attachment, were not substantial enough to prevent inadvertent or accidental removal. The tagout device attachment means were not, self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds.  c) Pink ribbons used as Tagout devices were not identifiable indicating the identity of the employee applying the device(s).  d) Pink ribbons used as tagout devices did not warn against hazardous conditions if the equipment is energized and did not include a legend such as the following: Do Not Start. Do Not Open. Do Not Close. Do Not Energize. Do Not Operate.

Issued

Aug 17, 2015

Abate by

Aug 24, 2015

Penalty

Initial $2,700 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.157(g)(2): The employer did not provide the education required in paragraph (g)(1) of this section upon initial employment and at least annually thereafter:    a) Where portable fire extinguishers were provided for employee use in the facility, employees were not provided the required education involving the use of fire extinguishers upon initial employment and at least annually thereafter.  Annual training was not provided to plant operators who were expected to use fire extinguishers to eliminate small fires at the facility.

Issued

Aug 17, 2015

Abate by

Mar 31, 2016

Penalty

Initial $0 · Current $1,900

General-duty citation text

29 CFR 1910.1200(f)(6): When labels were not affixed to individual stationary process containers, the employer did not use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials to convey the information required by 29 CFR 1910.1200(f)(5) to be on a label:    a) The employer did not use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials to convey the appropriate hazard warnings and the identity of the hazardous chemicals contained in the following pressure vessels: V-355, V-365, T-360, V-501, V-511, V-810, T-4, T-5, T-6, T-235, T-345, T-360, T-830, T-1200, T-1210, T-1240, T-1270, T-1276