OSHA Inspection: THREE RIVERS ENERGY, LLC

Issued

May 6, 2016

Penalty

Initial $3,500 · Current $3,388 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i):  Information concerning the technology of the process shall include at least the following:    29 CFR 1910.119(d)(2)(i)(C): Maximum intended inventory:    a.  On or about November 20, 2015, the process safety information pertaining to the technology of the ethanol production process did not include an accurate maximum intended inventory for flammable liquids in the process.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i):  Information concerning the technology of the process shall include at least the following:     29 CFR 1910.119(d)(2)(i)(D):  Safe upper and lower limits for such items as temperatures, pressures, flows or compositions:     a.  On or about November 20, 2015, the process safety information pertaining to the technology of the ethanol production process did not include the safe upper and lower limits for such items as temperatures, pressures, flows, and levels in equipment.

Issued

May 6, 2016

Abate by

Dec 29, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(2)(i):  Information concerning the technology of the process shall include at least the following:     29 CFR 1910.119(d)(2)(i)(E):  An evaluation of the consequences of deviations, including those affecting the safety and health of employees:     a.  As of January 15, 2016, the employer failed to compile the process safety information pertaining to the technology of the ethanol production process, in that the employer did not perform an evaluation of the consequences of deviations, including those affecting the safety and health of employees.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $7,402

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.    29 CFR 1910.119(d)(3): Information pertaining to the equipment in the process.    29 CFR 1910.119(d)(3)(i): Information pertaining to the equipment in the process shall include:    29 CFR 1910.119(d)(3)(i)(B): Piping and instrument diagrams (P&ID's);    On or about November 20, 2015, the employer failed to maintain accurate Piping and Instrument diagrams, in that:      a.     P&ID 61081-PI-4501 Evaporation (sheet 1 of 2) was not accurate and not updated to include pump PC 4102 feed into the line for pump PC-4501 feed to the top of the 1st Effect Evaporator. This line includes two valves that were also not updated on the P&ID  V-45150 and V-45151.      b.     P&ID 61081-PI-4301 Dehydration was not accurate and not updated to include a valve in line with valve V-43130 and an added flex line for the Regen filter #1.  For this same piece of equipment; piping from valve V-43129 was not updated on the P&ID.      c.     P&ID 61081-PI-4301 Dehydration was not accurate and not updated to include a valve in line with valve V-43158 and an added flex line for the Regen filter #2.  For this same piece of equipment; piping from valve V-43157 and an additional valve were not updated on the P&ID.    d.     P&ID 61081-PI-4301 Dehydration was not accurate in that valve V-43119 is indicated to be car sealed open on the diagram when this valve is not car sealed open.    e.     P&ID 61081-PI-4401 Product Acid Reduction was not accurate and not updated to include a valve in line with valve V-44105 on top of product filter #2.    f.      P&ID 61081-PI-4301 Dehydration was not specific in that four time controllers associated with the Mole Sieve bed dehydration control system were not specifically identified. The controllers are only marked as KIC without a tag number/numeric indication.  The controllers are individually associated with the Regen valve for Sieve Bed #1, the Regen valve for Sieve Bed #2, the outlet valve for Sieve Bed #1 and the outlet valve for Sieve Bed #2.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $4,900 · Current $0 Reduced

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.    29 CFR 1910.119(d)(3): Information pertaining to the equipment in the process.    29 CFR 1910.119(d)(3)(i): Information pertaining to the equipment in the process shall include:    29 CFR 1910.119(d)(3)(i)(D): Relief system design and design basis;    a. On or about November 20, 2015; the employer had not documented and compiled relief system design information for overpressure protection of ethanol processing equipment including, but not limited to 8 relief systems in Dehydration, 5 systems in Distillation, Rectification and Stripping and 6 systems in Beer Distillation. The employer had not compiled information regarding relief vent pipe design, safe venting location information, information/documentation regarding backpressure effects/forces associated with venting, the design requirements for structural supporting members for the relief device and any supporting piping (including vent pipe).    b. On or about November 20, 2015; the employer had not documented and compiled relief system design basis information for overpressure protection of ethanol processing equipment including, PSV-42182, PSV-42181, PSV-43182, PSV-43183, PSV-43184 and PSV-45180.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.    29 CFR 1910.119(d)(3): Information pertaining to the equipment in the process.    29 CFR 1910.119(d)(3)(ii): The employer shall document that equipment complies with recognized and generally accepted good engineering practices.    On or about November 20, 2015, the employer did not document compliance with recognized and generally accepted good engineering practices (RAGAGEP) in that:    a. The employer did not document RAGAGEP compliance and had not determined safe venting locations for pressure vessel sources when pressure vessels are the potential source of a relieving event. Pressure vessels with overpressure protection that vents to atmosphere include, but are not limited to the Rectifier column C-4201, Mole Sieve Bed #2 VS-4302, the Beer Column C-4101 and the Reflux Condenser E-4201. The ASME Boiler and Pressure Vessel Code, Section UG-135(f) is an example of RAGEGEP for discharging pressure vessels to safe locations.    b. The employer did not document RAGAGEP compliance and had not designed, installed, evaluated and maintained the components of safety systems/interlocks used to monitor operating condition parameters and to control identified hazards associated with overheating and overpressure in process equipment in accordance with RAGAGEP. Safety systems/interlocks used to monitor and control hazards include, but are not limited to the Beer Column pressure instruments interlocked to stop flow into the column by controlling the supply pumps for alcohol containing "beer" into the column. The employer does not have calibration and testing of interlock components or monitoring system components in accordance with chemical process industry practice, manufacturer's instructions and has not documented compliance with RAGAGEP for safety systems, such as ANSI/ISA ANSI/ISA-84.00.01-2004 (IEC 61511-1 Mod), Functional Safety: Safety Instrumented Systems for the Process Industry Sector - Parts 1, 2 and 3.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E): Ventilation system design;    a. The employer failed to document the ventilation system design for the main processing building, thereby exposing employees to fire and explosion hazards.    b. The employer failed to document the ventilation system design for the DD&E building, thereby exposing employees to fire and explosion hazards.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.    29 CFR 1910.119(d)(3): Information pertaining to the equipment in the process.    29 CFR 1910.119(d)(3)(i): Information pertaining to the equipment in the process shall include:    29 CFR 1910.119(d)(3)(i)(H): Safety systems (e.g. interlocks, detection or suppression systems).    On or about November 20,2015, the employer failed to document and compile information pertaining to process equipment related to safety systems, including but not limited to the components and analytical records of action for the following safety integrated system interlocks:    a. the "beer column" interlocks,  b. the "rectifier column" interlocks,  c. the "reflux condenser" interlocks,  d. the "stripper column reboiler" interlocks, and  e. the "reflux vent condenser" interlocks.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $4,900 · Current $4,639 Reduced

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(e)(1): The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process.      The employer failed to identify and control process hazards where "safeguards" were identified and claimed as controlling identified hazards in the 2007 and 2013 PHAs that did not exist, were ineffective or were non-compliant:      a.     For the 2007 PHA, regarding Node 12 involving ethanol vapors from the Rectifier Column C-4201 being condensed in Reflux Condenser E-4201; the employer claimed Safeguard 12.5 MI program and SOP for an identified hazard associated with tube failure in the condenser. The employer does not have a mechanical integrity program that addresses tube components for tube and shell heat exchangers. Additionally the employers standard operating procedures are not compliant for this equipment.   b.     For the 2007 PHA, regarding Node 12 involving ethanol vapors from the Rectifier Column C-4201 being condensed in Reflux Condenser E-4201; the employer claimed Safeguard 12.2 SOP and Operator Training for failed valve closure on the cooling water supply to the condenser.  The employers standard operating procedures are not compliant for this equipment and do not address this situation.  c.     For the 2007 PHA, regarding Node 13 involving ethanol vapors condensing in the Reflux Vent Condenser E-4203; the employer claimed Safeguard 13.17 MI Tube Program to control hazards associated with tube failure in the condenser. The employer does not have a mechanical integrity program that addresses tube components for tube and shell heat exchangers.   d.     For the 2007 PHA, regarding Node 17 involving pumping rectifier bottoms containing ethanol to the Stripper Column C-4202; the employer claimed Safeguard 17.2 SOP and Operator Training and the identical Safeguards 17.3 and 17.4 MI Program for hazards caused by valve closure and valve  failure. The employer does not have a compliant mechanical integrity program for valves. The employer does not have compliant standard operating procedures for this equipment and the procedures do not address this situation.  e.     For the 2007 PHA, regarding the Node 24.7 Deviation Misdirected Flow hazard caused by tube failure in a tube and shell heat exchanger; the employer claimed Safeguard 24.9 MI Program when a mechanical integrity program to address tube failure does not exist. Additionally the identical Node 25.7 and 33.7 Deviation Misdirected Flow also claim the identical administrative control for a mechanical integrity program to address tube failure.  f.      For the 2007 PHA, regarding Node 26.7 Deviation Misdirected Flow caused by valve failure open or misalignment; the employer claimed Safeguard 26.7 SOP and Operator Training to control this hazard. The employer does not have compliant standard operating procedures for this equipment and procedures do not address this situation.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(e)(2): The employer shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed.    29 CFR 1910.119(e)(2)(iv): Hazard and Operability Study (HAZOP);     For the 2013 process hazard analysis (PHA) revalidation; the employer did not appropriately apply their identified HAZOP PHA methodology to systematically identify hazards in covered processes, identify controls used and evaluate the consequences for failure of those controls resulting in an inadequate determination and evaluation of hazards in the covered processes exposing employees to the hazards related to fire and explosions related to flammable liquid and/or vapor release from ethanol processing equipment. Examples of the inappropriate and/or inadequate application of the methodology include, but are not limited to:     a. The HAZOP methodology was not properly applied in an appropriate or adequate manner, in that systematic nodes were not developed to be analyzed for hazards from one point of process flow to the end of that process node.        b. The HAZOP methodology was not properly applied in an appropriate or adequate manner, in that, the Guide Word deviation related Causes are not linked to specific Consequences. Consequences are not linked to specific Existing Safeguards. Existing Safeguards or specific Consequences are not linked to specific Suggested Actions (or Recommendations.) The analysis was not systematically applied to the process by application of the process parameter or condition and Guide Word deviation to each process point by linking to a specific Cause, which is linked to any specific Existing Safeguards and then linking to any specific Suggested Actions (or Recommendations.)       c. The HAZOP methodology was not properly applied to the hazard analysis in that there was a lack of detail, or specificity in identifying specific equipment and locations in the ethanol process in the analysis. The revalidation failed to systematically detail specific equipment and/or location(s) in the process to Guide Word parameters for deviation(s), to Causes and to Consequences.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis shall address:    29 CFR 1910.119(e)(3)(i): The hazards of the process;     a. For the 2007 PHA, Node 4.1 Deviation of ?No Flow? due to Cause ?E-4103 Plugged? does not address the potential overpressure hazard to the Beer Column Feed Heater and additionally increasing overpressure risk to the Beer Column.      b. For the 2007 PHA, Node 7.2 Deviation of ?More Steam Flow? due to Cause ?V-41138 Open? does not address the release of ethanol containing product through an open pressure relief device.      c. For the 2007 PHA, Node 7.7 Deviation of ?Misdirected Flow? does not address the hazard of increased potential for release due to flow into either the Clean In Place (CIP) return line or CIP supply line.      d. For the 2007 PHA, Node 7.14.2 Deviation of ?High Concentration of Ethanol in Stillage Bottoms? for the Cause ?Rectifier Valve Closed? does not address the hazards of Beer Column overpressure and increased risk for ethanol release from process.      e. For the 2007 PHA, the entire Node 8 does not address the hazards of potential ethanol release associated with the Beer Column and the listed control/instrumentation equipment in the node.      f. For the 2007 PHA, Node 9.1 Deviation ?No Flow First Effect Evaporator E-4501? Cause ?Pump Failure,? Node 9.21 Deviation ?Increase in Number of Phases? Cause ?PC-4102 Overheating and Flashing? and Node 9.24 Deviation ?No Level? Cause ?C-4101 Too Hot? Consequence ?Starve Pump Potential Pump Damage? do not address the hazards associated with catastrophic pump failure.      g. For the 2007 PHA, Node 10.10 Deviation ?Higher Pressure,? Node 11.10 Deviation ?Higher Pressure,? Node 33.2 ?More Ethanol Flow,? Node 33.8 ?higher Temperature? and Node 33.10 ?Higher Pressure? do not address the hazards associated with 1st Effect Evaporator E-4501 overpressure and the increased risk for ethanol release from the process.      h. For the 2007 PHA, Node 11.1 Deviation ?No Flow? does not address the hazard for overpressurization of the Rectifier column C-4201 for the circumstance of no vapor flow out of the column.      i. For the 2007 PHA, the Node 12.7 deviation ?Misdirected Flow? does not address the hazards of ethanol release through the Vent Gas Scrubber due to valve misalignment or failure of valve V-42184 for the Reflux Vent Condenser Line.       j. For the 2007 PHA, for the guideword ?No? Node 14 Cause 14.2.2 ?Manual Valve V-41123 Closed? does not address the hazard of Beer Column C-4101 overpressure and increased risk for ethanol release from the process for closing this valve and preventing ethanol vapor from exiting the column to flow to the rectifier column.      k. For the 2007 PHA, the Node 17.7 deviation ?Misdirected Flow? does not address the hazards of ethanol release through valve V-42186 due to valve misalignment or failure.      l. For the 2007 PHA, the Node 17.1 deviation ?No Flow? Cause ?PC-4301? Consequence 17.1.1.3 ?Potential Pump Damage? does not address the hazards associated with catastrophic pump failure for the Rectifier Column Pump PC-4201.      m. The 2007 PHA, Nodes 20 and 21 and the 2013 PHA Mole Sieves ?Process/Unit? section do not completely address overpressure and ethanol vapor release hazards associated with integrated Mole Sieve #1 and Mole Sieve #2 operational and regeneration control system and potential failures associated with the system. Potential issues not addressed by the PHA include but are not limited to, component failure, logic/programming inconsistencies, communications interface, field wiring, installation of components, power source interruptions/failures, timing issues, system reliability, system design, system/component inspection, component calibration and component testing. The PHA has not addressed system failures that could disrupt the specific opening and closing of valves that control the cycle of heated, pressurized high concentrate ethanol vapor into, through and from process equipment. Mole Sieve control system upsets and/or failure can lead to the overpressurization of process equipment and/or ethanol vapor release.      n. For the 2007 PHA, Node 28.1.2 and Node 28.2.3 for the identical Cause ?Pump Failure? does not address hazards associated a catastrophic pump failure of the Product Pump PC-4401.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis shall address:    29 CFR 1910.119(e)(3)(iii): Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.);     a. For the 2007 PHA, Node 4.1 Deviation of No Flow due to Cause E-4103 Plugged does not address the existing engineering controls or any potential for additional engineering control additions for the potential overpressure hazard associated with this deviation.      b. For the 2007 PHA, Node 7.14 Deviation High Concentration of Ethanol in Bottoms Stillage due to Cause Rectifier Valve closed does not address the existing engineering controls for parameter indication, DCS alarms and the overpressure protection for the Beer Column.       c. For the 2007 PHA, Node 9.1 Deviation No Flow First Effect Evaporator E-4501 Cause Pump Failure, Node 9.21 Deviation Increase in Number of Phases Cause PC-4102 Overheating and Flashing and Node 9.24 Deviation No Level Cause C-4101 Too Hot Consequence Starve Pump Potential Pump Damage do not address potential engineering and administrative controls to prevent pump failure and minimize the risk for pumps as an ignition source, such as but not limited to an effective mechanical integrity program.      d. For the 2007 PHA Node 9, the identical Safeguards 9.15 and 9.17 DCS Alarms and Interlocks lack specificity. These PHA safeguards do not address the actual engineering and administrative controls used to control the identified hazard.      e. For the 2007 PHA Node 12, Safeguard 12.1 Instrumentation and DCS Alarms on E-4201 lacks specificity. The PHA safeguard does not address which actual instrument and DCS alarm employees would rely on to the lack of cooling water or the lack of ethanol vapor flow into the Reflux Condenser E-4201.      f. For the 2007 PHA Node 14, the identical Safeguards 14.1 and 14.3 Instrumentation and DCS Alarms on Column, FIC-42159, UIC-42117, the identical Safeguards 14.4 and 14.5 Instrumentation and DCS Alarms on Column, 14.6-14.8, 14.13 and 14.17 Column Instrumentation and DCS Alarms C-4101 and C-4201 and 14.9 Column Instrumentation and Alarms lack specificity. The PHA safeguard does not address which actual instruments, controls, DCS Beer Column alarms and DCS Rectifier Column alarms are intended to address and control the identified Rectifier Column C-4201 overpressure hazards. In addition, FIC-42159 is a control that is not in existence.     The 2013 PHA lacks specificity for engineering and administrative controls claimed by the PHA to control identified hazards. The following listed ?Existing Safeguards? in the 2013 PHA revalidation lack specificity:       g. for the ?Beer Column? page, there are three identical controls ?interlock with control system to prevent column flooding? and the control ?alarm/operator intervention ? Evap system? listed without specificity to the exact engineering and administrative control claimed.      h. for the ?Rectifier Column? page, there are two identical controls ?interlock with control system to prevent column flooding? and two identical controls ?interlock with operator alarms? listed without specificity to the exact engineering and administrative control claimed.      i. for the ?Stripper Column? page, there are two identical controls ?interlock with control system to prevent column flooding,? the control ?operator intervention,? the control ?operator alarms? and the control ?interlock with operator alarms? listed without specificity to the exact engineering and administrative control claimed.      j. for the Mole Sieves page that addresses the VS-4301 and VS-4302, the mole sieve beds, the control ?PSVs, alarms, operator intervention? and ?routine inspection, alarms and operator intervention? are listed controls lacking specificity to the exact engineering and administrative control claimed.      k. for the Mole Sieves page that addresses the regeration process equipment, the control ?secondary containment, alarm, operator intervention,? the control ?system design, fire protection system, PSVs? and the control Routine inspections, alarms and operator intervention, secondary containment? are listed control lacking specificity to the exact engineering and administrative control claimed.      l. for the 1st Effect Evaporator page, there are two identical controls ?pressure indicator, operator intervention?  and the control ?Routine inspections, alarms, and operator intervention, secondary containment? listed without specificity to the exact engineering and administrative control claimed.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis shall address:    29 CFR 1910.119(e)(3)(iv): Consequences of failure of engineering and administrative controls;    a. For the 2007 PHA, Node 4.3 Deviation of Less Flow due to Cause E-4103 Plugged and PSV-41182 Failed Open does not address the consequences of failure for existing engineering controls for the potential overpressure hazard associated with this deviation.      b. for the 2007 PHA, Nodes 5.2 More Flow deviation and 5.3 Low Flow deviation does not address the consequences of failure for the existing engineering controls associated with the Beer Column level indication interlock, LIC-41107.    c. for the 2007 PHA, Node 6.2 Deviation More Flow due to Cause Loss of Cooling Water, Node 6.10 Deviation Higher Pressure and Node 6.13 deviation High Concentration of Ethanol do not address the consequences of failure for the existing engineering controls associated with the VG Scrubber line temperature interlock, TIC-41125. Additionally Node 6.10 Deviation Higher Pressure does not address the failure of the engineering control PSV-41124.      d. for the 2007 PHA, Node 7.2 Deviation More Flow Steam due to the Causes High Steam Flow and Loss of Cooling Water does not address the consequences of failure for the existing engineering and administrative controls for the claimed safeguards listed.      e. for the 2007 PHA, the entire Node 8 fails to address the consequences of failure for the existing engineering and administrative controls for the pressure and temperature monitoring controls comprising this Node.      f. for the 2007 PHA, the employer does not address the consequences of failure of engineering and administrative controls for Safeguard 9.13 Column Instrumentation and FT-41140, the identical Safeguards 9.15 and 9.17 DCS Alarms and Interlocks and Safeguard  9.18 LL Level LIC-41107 will Shut Down all Three Pumps.      g. The employer does not address the consequences of failure of engineering and administrative controls for the 2007 PHA Safeguard 10.1 PT-45106, the identical Safeguards 33.1 and 33.3 TT-45109, PT-45106, C-4301 Instrumentation and Safeguard 33.2 TT-45109, PT-45106, C-4301 Instrumentation, PSV-45180.      h. The employer does not address the consequences of failure of engineering and administrative controls for the 2007 PHA Consequence 12.1.1 Overpressure Column Safeguard 12.1 Instrumentation and DCS Alarms on E-4201 which are intended to provide overpressure protection for C-4201 the Rectifier Column.      i. The employer does not address the consequences of failure of engineering and administrative controls for the 2007 PHA Safeguards 13.1 and 13.2 for temperature instruments TI-42169, TI-42166 and DCS temperature alarms; and for the 2007 PHA Safeguard 13.5 for TI-42169, TI-42166, TC-42165 and DCS temperature alarms.      j. The employer does not address the consequences of failure of engineering and administrative controls for the 2007 PHA Consequence 13.2.1.1 Overpressure of E-4201 which has the listed hazard control Safeguard 13.5 PSV-42181, the overpressure protection for Reflux Condenser E-4201.       k. The employer does not address the consequences of failure of engineering and administrative controls for the 2007 PHA Node 19.3 Deviation More Ethanol Flow which has the listed control Safeguard 19.5 PIC-43102, KIC-43102, PT-43114A which can control flow into the Mole Sieve Bed #1 VS-4301 from the Superheater E-4301.      l. The employer does not address the consequences of failure of engineering and administrative controls for the 2007 PHA Node 24 Safeguard 24.11 PSV-43183 and Safeguard 24.12 LIC-43145 for the hazard ethanol boiling in E-4304 (Consequence 24.19.1.1.)       m. The employer does not address the consequences of failure or engineering and administrative controls for the 2007 PHA Node 27 Safeguard 27.7 PIC-44108 DCS Alarm to control an overheated column.    n. The employer does not address the consequences of failure of engineering and administrative controls for the Beer Column overpressure protection (PSV-41124 is the listed safeguard.)

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis shall address:    29 CFR 1910.119(e)(3)(v): Facility siting;    a. The employer failed to fully develop and evaluate fully the PHA to address facility siting hazards, in that the protection of personnel in occupied buildings and work areas in the facility was not addressed and that the layout of buildings, the spacing between buildings in the facility and the proximity of high risk/high energy operations to other high risk/high energy operations were not addressed by the August 2013 PHA.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis shall address:    29 CFR 1910.119(e)(3)(vi): Human factors; and    For the 2007 initial PHA and the 2013 PHA revalidation, the employer failed to address all human factors in the analysis. In that;   a. The employer did not adequately address valve misalignment and the human factors in responding to valve misalignment, valve failures and/or other valve issues where valve information is not included or completely available in the digital control system/operator monitoring system, such as the amount of time taken to troubleshoot, identify the specific condition and then control hazardous system conditions or parameters during these situations.  b. The employer did not address the human factor for employee exposure to hazardous conditions when troubleshooting, or responding to emergency situations involving open drain valves or securing manual isolation valves, such as the lack of any area monitoring for ethanol vapor in the facility or ensuring drain plugs in drain and sample valves.  c. The employer did not address the human factors associated with loss of power and/or loss of process utilities.  d. The employer did not address the human factors associated with incomplete standard operating procedures, to include evaluation of the amount of time necessary to respond to alarms and other control system indications before hazardous system conditions can occur.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(e)(3)(vii): A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace.    For the 2007 initial PHA and the 2013 PHA revalidation; the employer did no perform a complete evaluation of the range of safety and health effects of failure of controls in the workplace, in that:    a. fire was not considered when addressing ethanol vapor release(s) in the PHAs, including but not limited to the 2007 PHA Node 7 Cause 7.2.2 "loss of cooling water" with the listed Consequence was "environmental discharge,"  the 2207 PHA Node 7 Cause 7.14.1 "Lack of Boil Up" with Consequence 7.14.1.2 "Potential for environmental discharge," the 2013 revalidation "Beer Column" page Consequence "PSV-41124 activates; low/proof flammability" and the 2013 PHA revalidation "1st Effect Evaporators" page Guide Word "Internal Leak/Rupture" Consequence "high proof alcohol leak into whole stillage, to process condensate - not safety related."    b. vapor cloud ignition was not considered when addressing ethanol vapor release(s) in the PHAs, including but not limited to the 2007 Node 7 Consequence 7.2.1.2 "More Vapor Flow to E-4102 and Scrubber"

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $4,900 · Current $0 Reduced

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(e)(5): Process hazard analysis. 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.      a.     For the 2007 PHA the employer failed to resolve the recommendation R-15 ?Evaluate Installing Check Valves on Discharge of Pumps PC-4101A and PC-4101B.?  b.     For the 2007 PHA the employer failed to resolve the recommendation R-26 ?Evaluate Putting Check Valves on MI List? related to overpressurizing the Vent Gas System (C-4202 Vent Gas Scrubber and associated piping systems.)   c.     For the 2007 PHA, the employer failed to resolve the recommendation R-6 ?Ensure All PSV are included in the MI Program and Tested Routinely.? Although some pressure testing was performed in August 2013 ? said testing was not compliant with Recognized and Generally Accepted Good Engineering Practice.  d.     For the 2007 PHA the employer failed to resolve the recommendations R-33 ?overloading? of the Vent Gas Scrubber via the Regeneration process and R-39 which involves interlocking the Mole Sieve Bed inlet valves, Regen/equalization valves and Mole Sieve Bed outlet valves to prevent ethanol vapor release through the Vent Gas Scrubber. The employer claimed resolution that is production based stating the control system is setup for appropriate Mole Sieve Bed operations and did not address any potential upset conditions.  e.     For the 2007 PHA, the employer failed to resolve recommendation R-41 which involved establishing SOPs for the loss of process water flow.   f.      For the 2007 PHA, the employer failed to resolve recommendation R-43, R-45 and R-46 which involve increased vapor to the Vent Gas Scrubber column and potential ethanol release. The employer?s response evaluates normal operations and compliance with a regulatory air discharge permit rather than controlling the hazard of an upset condition involving more ethanol vapor flow (R-43), ?Too Hot of Feed? or ?high concentration of VOC? ? ethanol (R-46).  g.     For the 2013 PHA, the employer failed to resolve recommendation(s) for evaluating safe venting discharge of overpressure protection relief systems to a safe location for PSV-42101  (relief valve for the overpressure protection system for the Rectifier Column C-4201,) PSV-42143  (relief valve for the overpressure protection system for the Stripper Column C-4202,) a non-specific valve or valves related to ?PSV activation? involving one or any of five vessels in Dehydration (E-4301, VS-4301, VS-4302, E-4304 and E-4305,) PSV-43103 (relief valve for the overpressure protection system for the Regeneration Receiver Column VS-4303,) PSV-43182  (relief valve for the overpressure protection system for the Regeneration condenser E-4303 and the Mole Sieve Bed equalization line,) PSV-44114 (relief valve for the overpressure protection system for the Acid Reduction Column C-4401) and PSV-45180 (relief valve for the overpressure protection system for the 1st Effect Evaporator E-4501.) The employer does not have this documentation in compiled Process Safety Information and has not resolved these recommendations.      h.     For the 2013 PHA, the employer failed to resolve a recommendation for adding an expansion joint to the piping near or at the inlet to the beer column, C-4101 to address thermal expansion and beer column sway.      i.      For the 2013 PHA, the employer failed to resolve a recommendation regarding ?PM for gaskets?  during the section addressing the Regen Vacuum Condenser E-4303, Mole Sieve Bed #1 VS-4301, Mole Sieve Bed #2 VS-4302,PC-4303 Regen Pump, Regen Preheater E-4304 and the DD&E Condensate Preheater E-4305. The employer does not have a compliant mechanical integrity program for gaskets and seals of process piping and connections to other process equipment associated with gasket and seal use.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $12,675

General-duty citation text

29 CFR 1910.119(f)(1)(i)(B): The employer shall 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 shall address at least the following elements. Normal operations;     a. The employer failed to include safe operating limits such as temperature, pressure, and flow in the normal operations procedures for the distillation, thereby exposing employees to fire and explosion hazards.      b. The employer failed to include safe operating limits such as temperature, pressure, and flow in the normal operations procedures for the Acid Reduction and dehydration system, thereby exposing employees to fire and explosion hazards.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D): Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.    a. The employer failed to identify what conditions would constitute the initiation of emergency shutdown or the responsibilities of operators to ensure safe shutdown.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $4,900 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(A): Operating limits: Consequences of deviation; and    a. The employer failed to address consequences of deviation in the operating procedures, thereby exposing employees to an explosion hazard.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(B): Operating limits: Steps required to correct or avoid deviation.    a. The employer failed to develop and include steps for correcting deviations as part of the operating procedures, thereby exposing employees to fire and explosion hazards.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(A): Properties of, and hazards presented by, the chemicals used in the process;    a. The employer failed to include the properties and hazards presented by the chemicals in the process, thereby exposing employees to fire and explosion hazards.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(C): Control measures to be taken if physical contact or airborne exposure occurs;    a. The employer failed to include measure to be taken if physical contact or airborne exposure occurs, thereby exposing employees to atmospheric hazards.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iv): Safety systems and their functions.    a. The employer failed to include safety systems and their functions in the operating procedures, thereby exposing employees to fire and explosion hazards.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(3): The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer shall certify annually that these operating procedures are current and accurate.    a. The employer failed to perform annual review of operating procedures, thereby exposing employees to fire/explosion hazards.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(4): The employer shall 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 shall apply to employees and contractor employees.    a. The employer failed to develop safe work practices for control of entrance into the covered process areas by maintenance, contractor, laboratory, or other support personnel, thereby exposing employees to fire or explosion hazards.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(g)(1)(i): Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks.    a. The employer failed to train employees on the operating procedures, and safe work practices applicable to the employee's jobs, thereby exposing employees to fire and explosion hazards.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

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:      a.  As of November 20, 2015, the employer did not establish and implement specific written mechanical integrity procedures for inspecting, testing, and maintaining the ongoing integrity of pressure vessels, including, but not limited to, the following:  inspection and testing criteria, inspection criteria for corrosion under insulation, thickness measurement strategy, quality assurance criteria for inspecting and examining welds, welders performance qualifications, and criteria for resolving anomalous inspection data related to thickness growth.     b.  As of November 20, 2015, the employer did not establish and implement specific written mechanical integrity procedures for inspecting, testing, and maintaining the ongoing integrity of piping systems and valves including, but not limited to, the following:  inspection and testing criteria, inspection and testing schedule, inspection criteria for corrosion under insulation, thickness measurement strategy, quality assurance criteria for inspecting and examining welds, welders performance qualifications, and criteria for resolving anomalous inspection data related to thickness growth.     c.  As of November 20, 2015, the employer did not establish and implement specific written mechanical integrity procedures for inspecting, testing, and maintaining the ongoing integrity of all relief system components, vent systems and devices including, but not limited to, the following:   inspection and testing of over-pressure protection systems components (pressure relief valves, rupture disks, piping associated with relief devices and structural support members) for covered process pressure vessels to include the types of tests to perform on existing equipment, criteria for replacement and repair, inspection and testing schedule, and the appropriate designated methodologies for the inspection/test.     d.  As of November 20, 2015, the employer did not establish and implement specific written mechanical integrity procedures for inspecting, testing, and maintaining the ongoing integrity of emergency shutdown systems.     e.  As of November 20, 2015, the employer did not establish and implement specific written mechanical integrity procedures for inspecting, testing, and maintaining the ongoing integrity of controls including, but not limited to, the following:  inspection and testing schedule and calibration, inspection, and maintenance of monitoring devices and sensors, alarms, and interlocks.     f.  As of November 20, 2015, the employer did not establish and implement specific written mechanical integrity procedures for inspecting, testing, and maintaining the ongoing integrity of pumps including, but not limited to, the following:  inspection and testing schedule, inspection and rebuild/replacement of pumps, and vibration analysis.     g.  As of January 15, 2016, the employer's written "Regen Filter Change F-4301" procedure was not accurate in that the second drain valve on the bottom of the filter canister was not identified or addressed; there were no procedures for inspecting, cleaning, or lubricating the gasket; and there were no procedures for filling the filter canister with product after the filter change.      h.  As of February 2, 2016, the employer's written "Regen Filter F 4302" procedure was not accurate in that sequence numbers 9 and 10 were reversed; the second drain valve on the bottom of the filter canister was not identified or addressed; there were no procedures for inspecting, cleaning, or lubricating the gasket; and there were no procedures for filling the filter canister with product after the filter change.     i.  As of January 15, 2016, the employer's written "Final Product Filter Change F-4401" procedure was not accurate in that sequence numbers 9 and 10 were reversed; there were no procedures for inspecting, cleaning, or lubricating the gasket; and there were no procedures for filling the filter canister with product after the filter change.     j.  As of January 15, 2016, the employer's written "Final Product Filter Change F-4402" procedure was not accurate in that sequence numbers 9 and 10 were reversed; there were no procedures for inspecting, cleaning, or lubricating the gasket; and there were no procedures for filling the filter canister with product after the filter change.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $5,082

General-duty citation text

29 CFR 1910.119(j)(4)(i):  Inspections and tests shall be performed on process equipment:     a.  As of November 20, 2015, the employer did not ensure that inspections and tests were being performed on piping systems and piping components such as valves in the ethanol production process, including establishing the piping service classes for the process piping systems and the base-line thickness measurements to be used as initial thickness readings for corrosion rate calculations.    b.  As of November 20, 2015, the employer did not ensure that vibration analysis was being performed on centrifugal process pumps including, but not limited to, the following:  Beer Column Reboiler Pumps, PC-4101A and PC-4101B; Beer Column Pump, PC-4102; Rectifier Column Pump, PC-4201-A and PC-4201B; Stripper Column Pump, PC--4202; Rectifier Reflux Pump, PC-4203; Regeneration Pump, PC-4303; and Product Pump, PC-4401.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

Hazardous substances 1060

General-duty citation text

29 CFR 1910.119(j)(4)(ii):  Mechanical Integrity.  Inspection and testing.  Inspection and testing procedures shall follow recognized and generally accepted good engineering practices:    On or about November 20, 2015, for inspections performed on covered process equipment, inspections and tests were not performed to follow and comply with recognized and generally accepted good engineering practices (RAGAGEP); in that:    a.  For inspections of overpressure protection systems that protect pressure vessels, August 2013 inspections were not RAGAGEP compliant and did not include condition assessment of upstream and downstream piping, did not include documentation of the testing method and techniques utilized and did not include evaluation for the discharge piping structural support.     b.  For internal inspections of shell and tube heat exchangers, August 2013 inspections were not RAGAGEP compliant and did not include evaluation of corrosion effects for tubes and were not performed based on an inspection plan documented by the employer.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(5):  Equipment deficiencies.  The employer shall 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:     a.  As of February 4, 2016, the employer did not correct deficiencies with the Rectifier Column, C-4201, in a safe and timely manner as identified on the baseline inspection conducted on or about April 14, 2014, including the following:  insulation and jacketing missing on the shell.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $6,776

General-duty citation text

29 CFR 1910.119(l)(1):  The employer shall 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:      a.  As of February 24, 2016, a management of change covering the second 3/4 inch drain valve and flexible hose that was added to the bottom of the Regen Filter #1, F-4301 approximately 4-5 months ago was not written and implemented to ensure that the changes to the facility did not affect the covered process.       b.  As of February 24, 2016, a management of change covering the second 3/4 inch drain valve and flexible hose that was added to the bottom of the Regen Filter #2, F-4302 approximately 4-5 months ago was not written and implemented to ensure that the changes to the facility did not affect the covered process.     c.  As of February 24, 2016, a management of change covering the second 1/2 inch valve and additional 1/2 inch discharge piping that was added to valve V-43129 on top of the Regen Filter #1, F-4301 approximately 2 years ago was not written and implemented to ensure that the changes to the facility did not affect the covered process.        d.  As of February 24, 2016, a management of change covering the second 1/2 inch valve and additional 1/2 inch discharge piping that was added to valve V-43157 on top of the Regen Filter #2, F-4302 approximately 2 years ago was not written and implemented to ensure that the changes to the facility did not affect the covered process.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(m)(3):  An incident investigation team shall be established and consist of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident:     a.  As of November 20, 2015, the incident investigation report for the incident, which occurred on or about December 2, 2014, and involved a vapor line from the beer column to the rectifier column that was not locked in the closed position and allowed ethanol vapor to enter the beer column during entry, was investigated by only one person in lieu of establishing an incident investigation team.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(m)(4):  A report shall be prepared at the conclusion of the investigation which includes at a minimum:     29 CFR 1910.119(m)(4)(ii):  Date investigation began:     a.  On or about January 28, 2016, the incident investigation report for the incident, which occurred on or about December 16, 2015, and involved pump, PC-6101, that did not shutdown after suction valve, YV-61115, failed closed, did not include the date the investigation began.     b.  On or about November 20, 2015, the incident investigation report for the incident, which occurred on or about August 12, 2014, and involved a regeneration fluid (ethanol/water mixture) release in the DD&E building, did not include the date the investigation began.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(m)(4):  A report shall be prepared at the conclusion of the investigation which includes at a minimum:      29 CFR 1910.119(m)(4)(iv):  The factors that contributed to the incident:     a.  On or about November 20, 2015, the incident investigation report for the incident, which occurred on or about August 12, 2014, and involved a regeneration fluid (ethanol/water mixture) release in the DD&E building, did not include all of the contributing factors including the lack of having standardized procedures for changing the regen filters, F-4301 and F-4302 and the lack of operator training.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(m)(5):  The employer shall establish a system to promptly address and resolve the incident report findings and recommendations.  Resolutions and corrective actions shall be documented:     a.  As of January 28, 2016, the employer did not establish a system to promptly address and resolve the incident report findings and recommendations and document the resolutions and corrective actions for the incident which occurred on or about December 16, 2015, and involved pump, PC-6101, that did not shutdown after suction valve, YV-61115, failed closed.       b.  As of November 20, 2015, the employer did not establish a system to promptly address and resolve the incident report findings and recommendations and document the resolutions and corrective actions for the incident which occurred on or about August 12, 2014, and involved a regeneration fluid (ethanol/water mixture) release in the DD&E building.     c.  As of January 26, 2016, the employer did not document the scheduled dates for completion and resolve two of the incident report findings and recommendations in a timely manner for the incident which occurred on or about December 2, 2014, and involved a vapor line from the beer column to the rectifier column that was not locked in the closed position and allowed ethanol vapor to enter the beer column during entry.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $3,500 · Current $1,695 Reduced

General-duty citation text

29 CFR 1910.119(o)(4): The employer shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.    a. The employer failed to identify a timeline for responding to deficiencies identified in the compliance audit, thereby exposing employees to fire and explosion hazards.    b. The employer failed to documents that corrections were made to deficiencies identified in the compliance audit, thereby exposing employees to fire and explosion hazards.    c. The employer failed to respond to deficiencies identified in the compliance audit, thereby exposing employees to fire and explosion hazards.

Issued

May 6, 2016

Abate by

Dec 29, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.307(b): Documentation. All areas designated as hazardous (classified) locations under the Class and Zone system and areas designated under the Class and Division system established after August 13, 2007 shall be properly documented. This documentation shall be available to those authorized to design, install, inspect, maintain, or operate electric equipment at the location.    a. The employer failed to document how they designated class 1 and class 2 hazardous locations.