OSHA Inspection: CAYUGA OPERATING COMPANY, LLC

Issued

2016-03-18 00:00:00

Abate by

2016-03-30 00:00:00

Penalty

Initial $3500.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Information pertaining to the equipment in the process did not include piping and instrument diagrams (P&ID's):    a) On or about 9/23/2015, At the facility, Bulk Storage Area:  The companies P & ID's did not accurately depict the system, discrepancies were such as, but not limited to,:          - Main valves HV-101 and HV-100 were not depicted on the P&ID's.            - The ammonia absorption water bucket located at the hose connection area was not noted on the P&ID's.            - A pressure relief device located TU-1 was not present on the P&ID's.            - A dead end pipe located at TU-2 was not present on the P&ID's.            - Piping shown on the P&ID prior to the pumps, was not present on the system.            - Pressure switch PSH4520 and valve PLHC04 were not shown on the P&ID's.            - A ball valve leading to the vaporizer skid was not shown on the P&ID's.    b) On or about 9/23/2015, At the facility, Vaporizer Skid Area:   The companies P & ID's did not accurately depict the system, discrepancies were such as, but not limited to:          - A ball valve on the NH3 line descending to the vaporizer skid was not shown on the P&ID's.          - A valve and gauge located after PRV, but before PSVD27 was not shown on the P&ID's.          - TED24 and TED26 were on the intake side of the vaporizers, not on the discharge side as depicted on the P&ID's.          - Four valves were located around the Duplex filter, and were not shown on the P&ID's,          - The ammonia absorption water bucket intended to be located at PCV-D18 was not noted on the P&ID's.          - Valves located below the Duplex filter were not noted on the P&ID's.    Abatement certification is required for this item.

Issued

2016-03-18 00:00:00

Abate by

2016-03-30 00:00:00

Penalty

Initial $3500.00 · Current $5000.00

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that the equipment in the process complies with recognized and generally accepted good engineering practices:    a) On or about 9/23/2015, At the facility at the bulk tanks:  The employer did not comply with recognized and generally accepted good engineering practice, such as but not limited to, ANSI K61.1 - 1999, section 4.4.1, when it is used a container to absorb and contain ammonia that could leak, however, the discharge hose that was used to route ammonia to the container was not weighted or secured near the bottom of the container to prevent displacement of the hose.  Additionally, the container was not full of water, nor were there any design specifications for the quantity of water needed to mitigate the hazard of exposing employees to toxic ammonia vapors.      b) On or about 9/23/2015, At the facility at the vaporizers:  An Ammonia absorption container was not in place, ready to be used to absorb ammonia that could leak from upstream equipment.    One potential source of RAGAGEP includes but is not limited to ANSI K61.1 - 1999, Safety Requirements for the Storage and Handling of Anhydrous Ammonia, section 4.4.1.    c) On or about 9/23/2015, At the facility, at the vaporizers:  Pressure relief valves were vented into the breathing space, not upward and away from potential employee exposure.  One potential source of RAGAGEP includes but is not limited to ANSI K61.1 - 1999, Safety Requirements for the Storage and Handling of Anhydrous Ammonia, section 5.8.3.     Abatement certification is required for this item.

Issued

2016-03-18 00:00:00

Abate by

2016-03-30 00:00:00

Penalty

Initial $3500.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iv): The employer failed to ensure that the Process Safety Management Standard Operating Procedures included safety systems and their functions:    a) On or about 9/23/2015, At the facility:  The employer did not address the use of safety devices such as water buckets used as ammonia absorption water buckets, in their operating procedures.       Abatement certification is required for this item.

Issued

2016-03-18 00:00:00

Abate by

2016-03-30 00:00:00

Penalty

Initial $0.00 · Current $0.00

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) On or about 9/23/2015, At the facility:  The employer had not established written procedures to ensure on going integrity of process piping and equipment such as, but not limited to the NH3 piping and vaporizers along with the control of corrosion under insulation and maintenance of safety devices such as water buckets used as ammonia absorption water buckets and rain caps on hydrostatic relief devices.      Abatement certification is required for this item.

Issued

2016-03-18 00:00:00

Abate by

2016-03-30 00:00:00

Penalty

Initial $3500.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process piping and equipment:    a) On or about 9/23/2015, At the facility:  The employer failed to perform inspections and tests to ensure the integrity and operability of piping and equipment.  This includes ensuring the mechanical integrity of piping and vaporizers with visible rust and rust under insulation.      b) On or about 9/23/2015, At the facility:  The employer failed to perform inspections and tests to ensure the integrity and operability of piping and equipment.   Daily inspections did not address the existence and maintenance of ammonia absorption water buckets used as safety devices.    Abatement certification is required for this item.

Issued

2016-03-18 00:00:00

Abate by

2016-03-30 00:00:00

Penalty

Initial $3500.00 · Current $0.00 Reduced

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 9/23/2015, At the facility Ammonia vaporizer area:  The Process Hazard Analysis did not address the failure/ damage to process piping and equipment due to falling ice and snow from adjacent roofs and structures.     Abatement certification is required for this item.