OSHA Inspection: FOX RIVER VALLEY ETHANOL, LLC

Issued

2018-11-06 00:00:00

Abate by

2019-06-30 00:00:00

Penalty

Initial $5497.00 · Current $3848.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer shall complete a compilation of written process safety information. This process safety information shall include information pertaining to the equipment in the process including piping and instrument diagrams (P&ID's):    At a facility located at 4995 State Road 91, Oshkosh, WI 54904; the employer did not complete a compilation of written process safety information (PSI) pertaining to the piping and instrument diagrams:    a)  Multiple valves, pressure indicators and other equipment were not labeled, tagged or marked on the system with corresponding identifications to the P&IDs. Many other valves, pressure indicators and other equipment were labeled or tagged on the system with corresponding P&ID identifiers.    In Distillation 1:    b)  At the Beer Column, a pressure indicator and temperature indicator upstream of 1/2" ball valve V42133 were not drawn on the P&ID.    c)  At the Beer Column, temperature indicator TI42108 labeled on the system as TI42118.    d)  At the Reflux Condenser, 1/2" ball valve V42136 and pressure indicator PI42133 were drawn coming directly off the Reflux Condenser on the P&ID. On the system, the valve/indicator pair came off of the liquid gage line from the Reflux Condenser.     e)  At the Reflux Condenser, 1/2" ball valve V42120, pressure indicator PI42170 and temperature indicator TI42171 were drawn on the line entering the top of the Reflux Condenser. These items were not on the line as drawn in the P&ID.    f)  At the Product Cooler, plugs (four total) on the 4" lines entering and exiting the Product Cooler were not drawn on the P&ID.    g)  At the Product Cooler, a pressure indicator located on 1/2" ball valve V44124 was not drawn on the P&ID.    h)  At the Product Cooler, a 2" ball valve was labeled as V44120 on the system but was identified on the P&ID as V44123.    In Distillation 2:    i)  At the Stripper Column Reboiler, 1/2" ball valves V42567 and V42593 were drawn in line with each other. On the system, there was a tee between the valves with a capped dead end from the tee which was not drawn on the P&ID.    j)  At the Stripper Column Reboiler, air bleeding device AV4212 symbol was not defined in the Project Legend 116-A-0002.    k)  At the Rectifier Column, an unidentified 1/2" ball valve was drawn on the 8" line exiting the top of the Rectifier Column. No valve was present on the system in this area.    l)  At the Regeneration Cooler, a 1/2" ball valve V43577 was drawn coming off the 4" line just before the Regeneration Cooler, downstream of 1 1/2" ball valve V43517. On the system, V43577 was upstream of valve V43517.    m) At the Regeneration Cooler, a pressure indicator located on 1/2" ball valve V43515 was not drawn on the P&ID.    At the Whitefox:    n)  At the Stripper Column, chemical seals drawn on the P&ID at pressure indicators PI43712 and PI43714 were not on the system.    o)  Near the Membrane Modules, butterfly valve EV43730 was drawn teed off the 8" line downstream of the tee off the line to EV43729. On the system the EV43730 tee was upstream of the EV43729 tee.    p)  At the Retentate Condenser, butterfly valve 43815 drawn on line from Retentate Membrane upstream of Retentate Condenser was not on the system.    q)  At the Retentate Condenser, temperature indicator TI43755 drawn on line from Retentate Membrane downstream of Retentate condenser was actually a pressure indicator on the system.    r)  At the Retentate Condenser, butterfly valve 43814 drawn on line from Retentate Membrane downstream of Retentate Condenser was not on the system.    s)  At the Retentate Condenser, pressure indicator PI43735 drawn on a 2" ball valve on the line from Beer upstream of Retentate Condenser was not on the system.    t)  At the Retentate Condenser, an unidentified pressure indicator and two unidentified 2" ball valves drawn on the line from Beer downstream of the Retentate Condenser were not on the system.

Issued

2018-11-06 00:00:00

Abate by

2019-06-30 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D):  The employer shall complete a compilation of written process safety information. This process safety information shall include information pertaining to the equipment in the process including relief system design and design basis:    At a facility located at 4995 State Road 91, Oshkosh, WI 54904; the employer did not complete a compilation of written process safety information (PSI) pertaining to pressure relief system design and design basis for the following equipment:    a) Beer columns, stripper columns, rectifier columns, acid reduction columns, and mole sieve vessels in Distillation 1 and Distillation 2.    b) The stripper column of the Whitefox.

Issued

2018-11-06 00:00:00

Abate by

2019-06-30 00:00:00

Penalty

Initial $5497.00 · Current $1000.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii):  The employer shall document that equipment complies with recognized and generally accepted good engineering practices:    At a facility located at 4995 State Road 91, Oshkosh, WI 54904; the employer did not document that the 2" quarter-turn ball valve (V42144, JamFlow M#YK531S) complied with recognized and generally accepted good engineering practices (RAGAGEP) when the valve was used to throttle flow through the 2" line (2"-AV-4201-21-SS1-1"H) instead of being at full open or full closed. The P&ID notated that valve V42144 was normally closed.

Issued

2018-11-06 00:00:00

Abate by

2018-12-17 00:00:00

Penalty

Initial $0.00 · Current $2500.00

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D):  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 steps for each operating phase including 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:    At a facility located at 4995 State Road 91, Oshkosh, WI 54904; the employer did not develop and implement written operating procedures that provided clear instructions in the written Standard Operating Procedures (SOP) for Distillation 1 and Distillation 2 Emergency Shutdown (DOC#s 600.20 and 600.21 respectively). The written SOPs did not include clear conditions under which emergency shutdown would be required.

Issued

2018-11-06 00:00:00

Abate by

2018-12-17 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1)(iii):  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 safety and health considerations:    At a facility located at 4995 State Road 91, Oshkosh, WI 54904; the employer did not develop and implement operating procedures that provided clear instructions to address safety and health considerations:    a)  The operating procedures did not contain specific considerations for the properties of, and hazards presented by ethanol and caustic soda in the Distillation 1, Distillation 2, or Whitefox systems.    b)  The operating procedure did not contain specific considerations for control measures to be taken if physical contact or airborne exposures occurred to ethanol or caustic soda in the Distillation 1, Distillation 2 or Whitefox systems.

Issued

2018-11-06 00:00:00

Abate by

2019-04-28 00:00:00

Penalty

Initial $0.00 · Current $2750.00

General-duty citation text

29 CFR 1910.132(a):  Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact:    At a facility located at 4995 State Road 91, Oshkosh, WI 54904; the employer did not provide employees with fire resistant clothing (FRC) when they conducted operational and maintenance work in the Distillation 1, Distillation 2 or Whitefox areas which were designated by the employer as hazardous (classified) locations.

Issued

2018-11-06 00:00:00

Penalty

Initial $0.00 · Current $0.00

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:  At a facility located at 4995 State Road 91, Oshkosh, WI 54904; the employer did not certify annually that operating procedures were current and accurate.