OSHA Inspection: CREEKSTONE FARMS PREMIUM BEEF LLC

Issued

Oct 12, 2018

Abate by

Nov 5, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices:  Employees engaged in operating, inspecting, testing, and maintaining activities or performing other critical operations before evacuating such as turning valves on the roof to isolate leaks on the floor at the covered process equipment on the roof top of the Old Fab area and the engine rooms were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injury to persons in and near the facility in that the employer fails to document and implement compliance with recognized and generally accepted good engineering practices for the marking/labeling of Ammonia refrigeration piping and system components. The following was noted during the walk around:   (a) Two (2) valves for Frick HS-9 Compressor by the HSS VAP Ammonia Low above the HS09 valve inside the engine room 2 were missing the Tag Identifications.  (b) Eleven (11) valves for suction side on the roof by the Old Fab area showing Identification Tags with marker was observed fading out and could not be read, or broken in pieces.  (c) One (1) isolation valve for suction line low side on the roof by the Old Fab area missing a hand-wheel.  (d) Three (3) valves for liquid side on the roof by the Old Fab area were missing the Tag Identifications.  29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is complete.

Issued

Oct 12, 2018

Abate by

Nov 5, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i): The Process Hazard Analysis did not address the hazards of the process:  Employees engaged in operating, inspecting, testing, and maintaining activities at the covered process equipment or employees engaged in production activities throughout the facility were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injury to persons in and near the facility in that the Process Hazard Analysis did not address the hazards of quality of incoming Ammonia.  a) 2006 PHA "What-If" questions under the NH3 Charging section did not address the requirement of Ammonia inbounding.  b) 2010 PHA "What-If" questions under the Charging NH3 to System section did not address the requirement of Ammonia inbounding.  c) 2015 PHA "What-If" questions under the Charging section did not address the requirement of Ammonia inbounding.  29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is complete.

Issued

Oct 12, 2018

Abate by

Nov 5, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team's findings and recommendations; assure that the recommendations were resolved in a timely manner with documented resolutions; document the actions that were to be taken; complete actions as soon as possible; develop a written schedule of action completion dates; or communicate the actions to operating maintenance, and other employees working in the process areas or who may have been affected by the recommendations or actions:  Employees engaged in operating, inspecting, testing, and maintaining activities at the covered process equipment or employees engaged in production activities throughout the facility were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injury to persons in and near the facility in that a system was not developed and implemented to resolve the Process Hazard Analysis findings and recommendations and act on them when appropriate, in a timely manner with documented resolutions.  a) The employer did not ensure that the findings and recommendations from the 2010 Process Hazard Analysis were resolved and acted on in a timely and appropriate manner. There are still open items since 2010.  b) The employer did not document the resolution of action items from the 2015 Process Hazard Analysis. A system was not created to promptly address the findings. There are 21 items of findings and recommendations for the Main Plant; 20 items of findings and recommendations for the New Addition. The current status of completion is unknown.     29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is complete.

Issued

Oct 12, 2018

Abate by

Nov 5, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were 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 were taken to assure safe operation:  Employees engaged in operating, inspecting, testing, and maintaining activities or performing other critical operations before evacuating such as turning valves on the roof to isolate leaks on the floor at the covered process equipment on the roof top and the engine rooms were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injury to persons in and near the facility in that the Five Year Independent Mechanical Integrity Inspection Audit findings and recommendations since 2006 to 2015 have not been corrected. The employer failed to correct deficiencies in equipment that were outside acceptable limits.   Identified findings and recommendations such as but not limited to the following:  A) 2006 Mechanical Integrity Audit Action Register.  1. All accumulators and intercoolers equipped with high-level float switches that sound a high liquid alarm level 2. Field test pressure 3. Aisles in the machinery room clearly marked  B) Updated MIA Tracking Report 2010.  1. Column 141 - Evaporators Grading Cooler Units (all) - Need to improve access to these units. 2. Column 143 - Evaporators Grading Cooler Units (all) - Some of the exposed piping at the valve stations is starting to rust and corrode.  This should be sanded, cleaned, primed, and re-painted. 3. Column 144 - Evaporators Hall East of Offal Unit 21-1 - Need to improve unit protection from impacts by forklifts.  This standard is covered in IIAR Bulletin 109, Section 4.4.2. 4. Column 147 - Evaporators Offal Units (all) - Some of the exposed piping at the valve stations is starting to rust and corrode.  This should be sanded, cleaned, primed, and re-painted. 5. Column 150 - Evaporators Ground Beef Units Zone 23 (all) - Some of the exposed piping at the valve stations is starting to rust and corrode.  This should be sanded, cleaned, primed, and re-painted. 6. Column 152 - Evaporators Offal Processing Units Zone 24 (all) - Some of the exposed piping at the valve stations is starting to rust and corrode.  This should be sanded, cleaned, primed, and re-painted. Scheduled Completion Date 1/20/2016. 7. Columns 153 - 154 - 156 - 158 - 159 - 161 - 162 - 164 - Scheduled Completion Date 1/20/2016. 8. Columns 166 - 168 - 175 - 177 - 180 - 182 - 185 - 187 - 191 - 192 - 194 - 196 - 198 - 203 - 208 - 213 - 215 - 216 - 217 - 218 - 230 - 235 - 236 -- Scheduled Completion Date 2/20/2016; 2/21/2016; 2/15/2016; 2/2/2016; 2/1/2016.  C) PSM corrective actions needed to close out 2010 MIA RR. PSM Compliance items needing completed to close out 2010 Mechanical Integrity Audit: 4 items listed, but no status updated.  D) 2015 detailed MIA Tracking Report and 2015 MI short action item list. Many columns did not show a completion date, or status updated.  E) 2015 MI short action item list. A lot of columns showed comments but there was not any completion date validated.  F) 2015 Main Plant - Executive Summary 2015. Unknown status on the following recommendations: 1. Evaluate Evaporative Condenser ECD-3 for replacement. 2. Reattach the nameplate to Thermosyphon Vessel TSV-1 following ASME procedures. 3. Recommend nondestructive testing of piping and vessels. 4. Valves open to atmosphere must be capped or plugged when not in use. Seal caps should also be used whenever possible to prevent exposure of valve stems to the elements. 5. The exposed piping and valve trains need immediate attention to prevent further corrosion. Clean with a wire brush, prime, and apply preventive paint. At the same time, the small areas of broken insulation should be repaired to restore the vapor barrier. 6. Install identification labels on all piping and equipment in the system that conforms with the identification utilized on the P&IDs and IIAR Bulletin 114. 7. Evaluate all control wiring junction boxes for support and proper installation. 8. Lighting must be installed in all working areas to provide safe working conditions. The lighting on the roof was not adequate to afford safe access. 9. Ensure the sign currently outside the Engine Room door, setting forth the owner/installing or servicing contractors name, design pressure for the system, pounds of ammonia in the system, brand and type of lubricant used, and the quantity thereof is correct and provides the necessary information as require. 10. The upper catwalk for Evaporative Condensers EC-3 and EC-4 needs to be evaluated for load bearing mechanical strength.  11. Install guards to prevent forklift impact as necessary. 12. Ensure the Engine Room ventilation system is adequate for normal and emergency ventilation as well as temperature requirements.  G) 2015 Main Plant - Relief Valves. Unknown status on the following recommendations: See Relief Valve Calculations report for recommendations. Consider corrected the valves found by the Lamb Group LLC on 2015, based on their relief system calculations for the existing relief valves and discharge piping for the Main Plant ammonia refrigeration system.  H) 2015 Main Plant - Ventilation. Unknown status on the following recommendations: Recommend that a ventilation study be conducted based on current conditions to determine if the exhaust fans are adequate during normal and emergency situations.  I) 2015 New Addition - Executive Summary 2015. Unknown status on the following recommendations: 1. Install panic hardware on the machinery room exit doors. 2. Install an audible and visual alarm for ammonia inside the Machinery Room and outside each entrance to the Machinery Room. Install signs to indicate the meaning of each alarm near each alarm.  3. Revised the system charge calculations and documentation to coincide with the actual amount of ammonia in the system.   29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is complete.

Issued

Oct 12, 2018

Abate by

Nov 5, 2018

Penalty

Initial $9,239 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(n): The employer did not establish an emergency plan for the entire plant in accordance with the provisions of 29 CFR 1910.38:  The current Emergency Action Plan was not updated in that the emergency shutdown procedures and assignment section listing at least one out of five site contacts was no longer working at the plant and still on the list. Employees engaged in performing critical operations before evacuating such as turning valves on the roof to isolate leaks at the covered process equipment were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injury to persons in and near the facility.  Reference: NFPA 101 Life Safety Code, 2009 Edition, page 101-38, Section 4.8.2.3 stated "the Emergency plans shall be reviewed and updated as required by the authority having jurisdiction."  29 CFR 1903.19(c)(1) requires certification that the abatement of the above violation is complete.

Issued

Oct 12, 2018

Abate by

Nov 5, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they had evaluated compliance with provisions of 29 CFR 1910.119 at least every three years to verify that the procedures and practices developed under this standard were adequate and are being followed:   Employees engaged in operating, inspecting, testing, and maintaining activities were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injury to persons in and near the facility in that the employer did not certify or evaluate compliance with the provisions of this section that the procedures and practices are adequate and being followed:  a) The employer provided no certifications that it had performed compliance evaluations to verify that its procedures and practices developed under the standard are adequate and being followed for the 2014 PSM Compliance Audit.  b) The employer provided no certifications that it had performed compliance evaluations to verify that its procedures and practices developed under the standard are adequate and being followed for the 2017 PSM Compliance Audit.   29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is complete.

Issued

Oct 12, 2018

Abate by

Nov 5, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected:  Employees engaged in operating, inspecting, testing, and maintaining activities were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injury to persons in and near the facility in that the following appropriate responses to each of the findings of the compliance audits were not promptly addressed, the identified deficiencies have not been corrected with document:  a) The employer does not ensure that findings are responded to in a prompt fashion and does not ensure nor document that deficiencies are or have been corrected. The employer did not document the corrected deficiencies from the 2014 Compliance Audit. The audit has uncompleted findings, 11 items still open since 2014.  b) The employer did not document the corrected deficiencies from the 2017 Compliance Audit. The audit has uncompleted findings, 18 items still open since 2017.   29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is complete.