OSHA Inspection: CENEX RENSSELAER TERMINAL LLC

Issued

Aug 23, 2018

Abate by

Mar 30, 2019

Penalty

Initial $9,239 · Current $6,000 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) Butane injection process:    On or prior to 3/1/18, the Process Hazard Analysis (Failure Modes and Effects Analysis) did not address the hazards of the process, including but not limited to:     -- Mechanical failure of liquid transfer pumps and related components, resulting in release of liquid butane with evaporation and possible ignition.

Issued

Aug 23, 2018

Abate by

Feb 28, 2019

Penalty

Initial $9,239 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119 (f)(1)(i)(E) The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information that addressed the steps for each operating phase, including emergency operations.    (a)  Butane injection process:   On or prior to 3/01/18, written operating procedures did not address emergency procedures, including, but not limited to:  loss of power or air pressure during railcar offloading.

Issued

Aug 23, 2018

Abate by

Sep 27, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(B): The employer did not develop and implement written operating procedures that provide clear instructions for steps required to correct or avoid deviation from the operating limits in the covered process.  (a)  Butane injection process:  On or prior to 3/01/18,  LPG Gasoline Tank Butane Injection Procedure(s) (line up procedure)did not address positions of hydrostatic expansion relief valve isolation valves to ensure they were in open position prior to operation of the process.

Issued

Aug 23, 2018

Penalty

Initial $7,853 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment:    (a) Butane injection process: On or prior to 3/1/2018, employees perform maintenance on butane transfer pumps including greasing the bearing assemblies and cleaning the inlet strainers.  The employer failed to establish written mechanical integrity procedures for these maintenance activities.      (b) Butane injection process: On or prior to 3/1/2018, employees perform maintenance on butane tanks including replacing the butane tank temperature probes.  The employer failed to establish written mechanical integrity procedures for this maintenance activity .

Issued

Aug 23, 2018

Abate by

Jan 15, 2019

Penalty

Initial $9,239 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process    (a) Butane injection process:   On or prior to 3/1/18,  Management of change procedures were not implemented following 12/21/17 discovery of a leaking belly valve (valve 3-B) on Tank 3, which required monitoring of the leak, attempts to tighten the valve, and removal of tank 3 from service with transfer of contents to the remaining 11 tanks until the valve could be repaired on 3/13/18.

Issued

Aug 23, 2018

Abate by

Feb 28, 2019

Penalty

Initial $7,391 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.132(a): Protective equipment was not used when necessary whenever hazards capable of causing injury and impairment were encountered:    (a)   At the facility:  On or prior to 3/1/18, use of FR (fire resistant) clothing was not required for use during job tasks where employees were exposed to potential flash fire hazards, including but not limited to:  Off Loading Butane Tanker Trucks, Off Loading Butane Rail Cars, Loading Butane Tanker Trucks, Butane Fitting Inspections, and Butane Blending Transfers

Issued

Aug 23, 2018

Abate by

Feb 28, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.132(d)(1): The employer did not assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment:    (a)  Butane injection process:   On or prior to 3/1/18, the employer did not perform a hazard assessment to determine personal protective equipment needed for protection from flash fire and related hazards during maintenance job tasks, including but not limited to:  cleaning butane transfer pump inlet strainers, greasing butane transfer pump bearing assemblies, and replacing thermometer assembly on butane tanks.

Issued

Aug 23, 2018

Abate by

Feb 15, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Information pertaining to equipment in the process did not include piping and instrumentation diagrams (P&IDs).     (a) Butane injection process:   On or prior to 3/1/18, P&IDs, including but not limited to 4163 P1R2, 4163 P2R3, and 4163 P4, did not accurately reflect installed pipes and equipment, in that the P&IDs contained errors including, but not limited to:    -Isolation valves (1/4 turn ball valves) for hydrostatic expansion relief valves were not indicated on drawings 4163-P1R1, 4163-P2R2, and 4163 R4     -2 inch relief line and associated components for P-1 as indicated on drawing 4163-P1-R1 was not installed     -Isolation valves 14-A, 14-B, and 14-C located on 6 inch liquid and 4 inch vapor lines were not indicated on drawing 4163-P1R1, 4163-P2R2, and 4163-R4    -Location of 4 inch SS flex lines upstream of inlet to butane transfer pumps were installed upstream of the Y strainer where drawing 4163-P1R1 and 4162-P2R3 indicated them installed on the downstream side.    -Bill of materials on drawing 4163-P1R1 consistently indicated different components than were actually installed, i.e Paget 4 inch inlet strainer where field verification found a Marshall Excelsion ME 24-100 was installed; P1 was indicated as a Blackmer 4 inch pump where a Corken Z4500 was installed, etc.    - Liquid butane line to truck rack upstream of 3 inch jumper valve was indicated as a 4 inch line where a 6 inch line was installed; 3 inch jumper valve (WOG 1000) was not indicated on drawing 4163-P1R1