OSHA Inspection: REG GEISMAR, LLC

Issued

Jun 9, 2016

Abate by

Nov 15, 2016

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.38(d): Employee alarm system. An employer must have and maintain an employee alarm system. The employee alarm system must use a distinctive signal for each purpose and comply with the requirements in 29 CFR 1910.165    On or about 12/11/2015, at the Renewal Energy Group (REG) Geismar, LLC located in Geismar Louisiana, the employer failed to ensure that the facility has an employee alarm system which complies with the requirements in � 1910.165.  This condition exposed employees to inhalation, fire, and explosion hazards from releases of hazardous materials.

Issued

Jun 9, 2016

Abate by

Nov 15, 2016

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(e)(5): The employer shall 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.    On or about 12/11/2015, at the Renewal Energy Group (REG) Geismar, LLC located in Geismar Louisiana, the employer did not ensure that PHA recommendations such as sitting study findings were resolved in a timely manner such as but not limited to:      a.     Pressure Vessel Burst scenarios for Hydrogenation Reactors, Isomerization Reactor, Hot Separator, De-ethanizer, and Debutanizer have the potential to create blast was >> (much greater) 2.85 psi at the control room, with a peak identified at 7.98 psi.  The design criteria specified for that building was 2.85 psi.  The permit office, warehouse, penthouse all have identified overpressure > (greater) 3 psi, and were not designed to protect occupants for that situation.  It is recommended that REGI perform a detailed risk analysis (LOPA, Fault Tree, or similar) to confirm that the probability of overpressure due to any identified cause for these vessels is low enough to produce a tolerable risk level.  Mitigation by installation of blast walls or similar is considered impractical due to the number and size of affected buildings and the number of different sources of overpressure.      b.    The maintenance building is exposed to a maximum blast wave of 1.0 psi due to a BLEVE (Boiling Liquid Expanding Vapor Explosion) at LPG (liquid Petroleum Gas) bullet.  The existing building and components should be evaluated to determine its ability to protect occupants for the identified blast.      These conditions exposed employees to inhalation, fire, and explosion hazards from releases of hazardous materials.

Issued

Jun 9, 2016

Abate by

Feb 28, 2017

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment.      Instance a. On or about 12/11/2015, at the Renewal Energy Group (REG) Geismar, LLC located in Geismar Louisiana, the employer failed to perform testing and inspections of controls designated as safeguards such as but not limited to:      1.    Level gauge LG-5427 (AG-08252-F1 Rev.13)   2.    Level transmitter/level indicator LT/LI-6012 (PF01-60-PROC-P&ID-0008 Rev. 8)  3.    Level transmitter/level indicator LT/LI-6023 (PF01-60-PROC-P&ID-0008 Rev. 8)      These conditions exposed employees to inhalation, fire, and explosion hazards from releases of hazardous materials.    Abatement due 11/15/2016      Instance b. On or about 12/11/2015, at the Renewal Energy Group (REG) Geismar, LLC located in Geismar Louisiana, the employer failed to perform 5 years visual inspections for the following pressure vessels but not limited to:       1.    50-R-5027 First Stage Reactor (PF01-50-PROC-P&ID-0003 Rev. 11)  2.    50-V-5401 HI Make-up Gas Scrubber (AG-08252-F1 Rev.13)  3.    50-V-5623 LPG Desulfurizer (PF01-50-PROC-P&ID-0027 Rev. 10)      These conditions exposed employees to inhalation, fire, and explosion hazards from releases of hazardous materials.    Abatement due 02/28/2017

Issued

Jun 9, 2016

Abate by

Nov 15, 2016

Penalty

Initial $7,000 · Current $7,000

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 (RAGAGEP).       On or about 12/11/2015, at the Renewal Energy Group (REG) Geismar, LLC located in Geismar Louisiana, the employer failed to establish corrosion rates for pressure vessels according to recognized and generally accepted good engineering practices such as America Petroleum Institute (API) Standard 510 - 2006 (Pressure Vessel Code: In-service Inspection, Rating, Repair, and Alteration), Section 7.1.2 that includes, but is not limited to the following vessels:      a.    50-R-5027 First Stage Reactor (PF01-50-PROC-P&ID-0003 Rev. 11)  b.    50-V-5401 HI Make-up Gas Scrubber (AG-08252-F1 Rev.13)  c.    50-V-5623 LPG Desulfurizer (PF01-50-PROC-P&ID-0027 Rev. 10)       These conditions exposed employees to inhalation, fire, and explosion hazards from releases of hazardous materials.

Issued

Jun 9, 2016

Abate by

Nov 15, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(2): Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment.     On or about 12/11/2015, at the Renewal Energy Group (REG) Geismar, LLC located in Geismar Louisiana, the employer did not implement its Mechanical Integrity procedure such as establishing corrosion rates for pressure vessels that includes but not limited to the following:       a.    50-R-5027 First Stage Reactor (PF01-50-PROC-P&ID-0003 Rev. 11)   b.    50-V-5401 HI Make-up Gas Scrubber (AG-08252-F1 Rev.13)   c.    50-V-5623 LPG Desulfurizer (PF01-50-PROC-P&ID-0027 Rev. 10)    These conditions exposed employees to inhalation, fire, and explosion hazards from releases of hazardous materials.