OSHA Inspection: PLAINS LPG SERVICES, L.P.

Issued

Jun 15, 2017

Abate by

Jul 19, 2017

Penalty

Initial $7,695 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): The employer did not include, in the process safety information compilation, the relief system design and the design basis:  For the propane LPG terminal, as observed on or about 01/06/2017, the employer did not have information/calculations for the design basis of relief system components such as, but not limited to, the following:  a) Relief valve PSV 0109 for the vapor blower inlet on piping and instrumentation diagram PID 1  b) Relief valve PSV 0133 for the PLC 500 Cabnet relief on piping and instrumentation diagram PID 1  c) Relief valve PSV 0341 for the PLC 100 control cabinet on piping and instrumentation diagram PID 3  d) Relief valve PSV 0518 for the suction side P-101D on piping and instrumentation diagram PID PID 5  e) PSV 0791A, PSV 0791B, and PSV 0791C for the H-205 Heater on piping and instrumentation diagram PID 7B  f) PSV 0792 for the H-205 nitrogen tank on piping and instrumentation diagram PID 7B  g) PSV 0811 for barge load line on piping and instrumentation diagram PID 8A  h) PSV 0812 for barge vapor separator on piping and instrumentation diagram PID 8A  i) PSV 0816 for barge load line on piping and instrumentation diagram PID 8A  j) PSV 0910 downstream of control valve bay #1 on piping and instrumentation diagram PID 9  k) PSV 0911 upstream of control valve bay #1 on piping and instrumentation diagram PID 9  l) PSV 0925 downstream of control valve bay #2 on piping and instrumentation diagram PID 9  m) PSV 0926 upstream of control valve bay #2 on piping and instrumentation diagram PID 9   n) PSV 0935 barge load line on piping and instrumentation diagram PID 9A  o) PSV 0946 barge load line on piping and instrumentation diagram PID 9A  p) PSV 0948 barge load line on piping and instrumentation diagram PID 9A  q) PSV 0949 barge load line on piping and instrumentation diagram PID 9A  r) PSV 1011 upstream of control valve bay 3 on piping and instrumentation diagram PID 10  s) PSV 1015 downstream of control valve bay 3 on piping and instrumentation diagram PID 10  t) PSV 1026 upstream of control valve bay 4 on piping and instrumentation diagram PID 10  u) PSV 1611 top of V-208 receiver (air compressor) on piping and instrumentation diagram PID 16  v) PSV 1616 Air drier on piping and instrumentation diagram PID 16  w) PSV 1617 Air drier on piping and instrumentation diagram PID 16  x) PSV 1623 Air compressor unit (internal) on piping and instrumentation diagram PID 16  y) PSV 1632 air compressor unit (internal) on piping and instrumentation diagram PID 16  z) PSV 2160 discharge on low stage compressor 201B on piping and instrumentation diagram PID 21  aa) PSV 2162 discharge on low stage compressor 201C on piping and instrumentation diagram PID 21  bb) PSV 2274 discharge on low stage compressor 201A on piping and instrumentation diagram PID 22  cc) PSV 2276A and PSV 2276B top of low stage oil separator (V-201) on piping and instrumentation diagram PID 22  dd) PSV 2285A and PSV 2285B top of oil cooler (shell side) E-203 on piping and instrumentation diagram PID 22  ee) PSV 2288A and PSV 2288B north end of oil cooler (tube side) E-203 on piping and instrumentation diagram PID 22  ff) PSV 2286 booster lube oil pump 204A on piping and instrumentation diagram PID 22  gg) PSV 2287 booster lube oil pump 204b on piping and instrumentation diagram PID 22  hh) PSV 2355 discharge on high stage compressor 202A on piping and instrumentation diagram PID 23  ii) PSV 2359 discharge on high stage compressor 202B on piping and instrumentation diagram PID 23  jj) PSV 2450A and 2450B top of high stage separator (V202A) on piping and instrumentation diagram PID 24  kk) PSV 2460A and PSV 2460B on top of oil cooler (shell side) E-204 on piping and instrumentation diagram PID 24  ll) PSV 2461A and PSV 2461B end of oil cooler (tube side) E-204 on piping and instrumentation diagram PID 24  mm) PSV 2462 high stage oil lube pump 205A on piping and instrumentation diagram PID 24  nn) PSV 2463 high stage lube oil pump 205B on piping and instrumentation diagram PID 24  oo) PSV 2527A and PSV 2527B on top of subcooler E-202 on piping and instrumentation diagram PID 25  pp) PSV 2532A and PSV 2532B on top of oil distiller V-209 on piping and instrumentation diagram PID 25  qq) PSV 2622A and PSV 2622B top of receiver V-203 on piping and instrumentation diagram PID 26  rr) PSV 3205 york HMI panel purge on piping and instrumentation diagram PID 32

Issued

Jun 15, 2017

Penalty

Initial $7,695 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(6): The process hazard analysis was not updated and revalidated every five years:  a) For the propane LPG terminal, as observed on or about 01/06/2017, the process hazard analysis had not been updated in the last five years. The last complete update to the process hazard analysis was conducted on 10/22/2010, and a partial process hazard analysis for ship loading had been conducted on 11/10/2011.

Issued

Jun 15, 2017

Abate by

Aug 2, 2017

Penalty

Initial $7,695 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(ii): The employer's inspection and testing procedures did not follow recognized and generally accepted good engineering practices:  a) For the propane terminal as observed on or about 01/06/2017, an inspection plan was not established for the facility to address all the potential failure mechanisms of the piping present. Piping inspections were not scheduled to monitor failure mechanisms of piping. Non-destructive measurement methods were not used. Measurement methods other than external visual measurements were not used. Piping systems were not evaluated based on present or possible types of damage mechanisms. Examinations were not scheduled at intervals to consider the type of damage, rate of damage progression, tolerance of the equipment to the type of damage, capability of the NDE (non-destructive testing) method to identify the damage, maximum intervals as defined in codes and standards, and extent of examination.   b) For the propane terminal as observed on or about 01/06/2017, an inspection plan that addressed all the failure mechanisms was not established for propane pressure vessels such as, but not limited to, a propane fuel tank, a propane receiver, and propane liquid/vapor separation vessels. Pressure vessel inspections were not scheduled to monitor failure mechanisms. Non-destructive measurement methods were not used. Measurement methods other than external visual measurements were not used. Piping systems were not evaluated based on present or possible types of damage mechanisms. Examinations were not schedules at intervals to consider the type of damage, rate of damage progression, tolerance of the equipment to the type of damage, probability of the NDE (non-destructive testing) method to identify the damage;

Issued

Jun 15, 2017

Abate by

Jul 12, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that was performed on process equipment wherein the documentation identified the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test:  a) For the propane LPG terminal, as observed on or about 01/06/2017, piping inspections of propane piping were not documented. Inspections were visual only. Propane piping was exposed to low temperature and high pressure, icing was observed on piping, and the potential for corrosion was present. The equipment was in a marine environment and multiple corrosion mechanisms were listed by the employer as being present.   b) For the propane LPG terminal, as observed on or about 01/06/2017, documentation for the last two inspections of the heat exchanger's pressure relief valves, PSV-0761 and PSV-0755, was not available. Pressure Relief valves were scheduled to be inspected and tested on an annual basis.  c) For the propane LPG terminal, as observed on or about 01/06/2017, documentation of inspections/tests for pressure vessels such as, but not limited to, the propane receiver (V-203), the propane fuel tank (V-204), and pressure vessel V-105 were not available. The pressure vessels contained high pressure, low temperature propane. The equipment was in a marine environment and multiple corrosion mechanisms were listed by the employer as being present.

Issued

Jun 15, 2017

Penalty

Initial $6,157 · Current $0 Reduced

General-duty citation text

29 CFR 1910.212(b): Machine(s) designed for fixed location(s) were not securely anchored to prevent walking or moving:  a) For the facility maintenance shop as observed on or about 01/06/2017, pedestal grinders were not secured in place, were observed to move/shift, and could potentially fall over.

Issued

Jun 15, 2017

Abate by

Jul 12, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(6)(ii): The employer did not certify that periodic inspections of the energy control procedures had been performed:  a) For the propane terminal facility, as observed on or about 01/06/2017, employees performed maintenance on and locked/tagged out equipment such as, but not limited to, compressors, pumps, and pressure vessels. Hazardous energy present included fire, explosion, electricity, and contact with moving parts. A certification record of the employer's periodic inspection of energy control procedures was not available.