OSHA Inspection: O'RYAN OIL & GAS

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $5,115 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(c)(1): The employer did not develop a written plan of action regarding the implementation of the employee participation required by this paragraph.      On or about October 31, 2018, and times prior thereto, the ORyan Oil and Gas Plant did not ensure a written plan of action was developed addressing the implementation of the employee participation component of their process safety management program.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $11,934 · Current $8,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(2): The employer did not complete a compilation of written process safety information concerning the technology of the process.       On or about October 31, 2018, and times prior thereto, the employer did not ensure information concerning the technology of the process, the production of gas liquids, included:    a.     Process chemistry;  b.     Maximum intended inventory;   c.     Safe upper and lower limits for such items as temperatures, pressures, flows or compositions; and   d.     an evaluation of the consequences of deviation, including those affecting the safety and health of employees.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3): The employer did not complete a compilation of written process safety information pertaining to the equipment in the process.   On or about October 31, 2018, and times prior thereto, the employer did not ensure that the information concerning the equipment in the process included:   a.     materials of construction; b.     piping and instrumentation diagram; c.     electrical classification;  d.     relief system design and design basis; e.     design code and standards employed; and f.      safety systems and interlocks.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $11,934 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910.119.        On or about October 31, 2018, and times prior thereto, the employer did not conduct a process hazard analysis for the evaluation and control of the hazards involved in the process, production of natural gas liquids, exposing employees to inhalation, fire, and explosion hazards.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $11,934 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1): 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 and addressing at least steps for each operating phase, safe operating limits, safety and health considerations, and safety systems and their functions as outlined by this paragraph:      On or about October 31, 2018, and times prior thereto, the employer did not ensure that written operating procedures for the natural gas liquid processes were developed and implemented, exposing employees to inhalation, fire, and explosion hazards. The written operating procedures must include, but not be limited to the following elements:      a) Steps for each operating phase including Initial startup;      b) Steps for each operating phase including Normal operations;      c) Steps for each operating phase including Temporary operations;      d) Steps for each operating phase including Emergency shutdown and 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;      e) Steps for each operating phase including Emergency Operations;      f) Steps for each operating phase including Normal shutdown;      g) Steps for each operating phase including Startup following a turnaround, or after an emergency shutdown;      h) Operating limits;      i) Consequences of deviation;      j) Steps required to correct or avoid deviation;      k) Safety and health considerations including Properties of, and hazards presented by, the chemicals used in the process;      l) Safety and health considerations including Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment;      m) Safety and health considerations including Control measures to be taken if physical contact or airborne exposure occurs;      n) Safety and health considerations including Quality control for raw materials and control of hazardous chemical inventory levels;      o) Safety and health considerations including Any special or unique hazards; and      p) Safety systems and their functions.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $5,115 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(g)(3): The employer did not prepare a record which contained the identity of the employee, the date of training, and the means used to verify that the employee understood the training.      On or about October 31, 2018, and times prior thereto, the employer did not ensure that a record of the training conducted was prepared which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $5,115 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(i): The employer, when selecting a contractor , did not obtain and evaluate information regarding the contract employer's safety performance and program.      On or about October 31, 2018, and times prior thereto, the employer did not evaluate information regarding the following employers safety and performance programs. Contractors selected and who had performed tasks in the facility, included but were not limited to:      a.  Medline Electric  b.  Eagle Automation   c.  Louisiana Valve  d.  Smith Equipment  e.  Johnson Controls  f.  Coastal Chemical

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $11,934 · Current $8,000 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.        On or about October 31, 2018, and times prior thereto, The employer did not establish and implement written procedures to maintain the on-going integrity of the following process equipment:      NGL Tank 1 and 2  Slop Tank A and B  High Stage Compressor  Low Stage Compressor  Inlet Compressor  Flare and Knockout Drums  32-803 Propane Economizer  32-802 Propane Accumulator  32-805 Propane Scrubber  21-603 Trim Reboiler  31-602 Blue Tower Nitrogen Regeneration Column  V-100a  Sweet Gas After Scrubber  Pressure relief valves  Process piping  P-200 Amine Charge Pump A&B  P-201 Amine Reboiler Pump A&B  P-202 Reflux Pump  P-300 Hot Oil Pump  F-100 Inlet Filter Separator  F-200 Amine Solids Filter  F-300 Hot Oil Filter  NGL Stabilizer  Amine flash tank  After Scrubber

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(3): The employer did not train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner.  On or about October 31, 2018, and times prior thereto, the employer did not train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner. perform inspections and tests on following process equipment:   NGL Tank 1 and 2 Slop Tank A and B High Stage Compressor Low Stage Compressor Inlet Compressor Flare and Knockout Drums 32-803 Propane Economizer 32-802 Propane Accumulator 32-805 Propane Scrubber 21-603 Trim Reboiler 31-602 Blue Tower Nitrogen Regeneration Column V-100a  Sweet Gas After Scrubber Pressure relief valves Process piping P-200 Amine Charge Pump A&B P-201 Amine Reboiler Pump A&B P-202 Reflux Pump P-300 Hot Oil Pump F-100 Inlet Filter Separator F-200 Amine Solids Filter F-300 Hot Oil Filter

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $11,934 · Current $7,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment.      On or about October 31, 2018, and times prior thereto, the employer did not perform inspections and tests on the following process equipment:      P-2008 Amine Charge Pump  PV-803-1        K-3902 Acid Gas compressor and PV-361  P-401-2 transfer pump.   C-1340 Inlet compressor.  26-100 Inlet gas filter/separator and its alarm switch.  NGL Tank 1 and 2  Slop Tank A and B  High Stage Compressor  Low Stage Compressor  32-802 Propane Accumulator  32-805 Propane Scrubber  21-603 Trim Reboiler  31-602 Blue Tower Nitrogen Regeneration Column  V-100a  Sweet Gas After Scrubber  Pressure relief valves  Process piping  P-201 Amine Reboiler Pump A&B  P-202 Reflux Pump  P-300 Hot Oil Pump  F-100 Inlet Filter Separator  F-200 Amine Solids Filter  F-300 Hot Oil Filter   Amine Surge Tank  Amine Flash Tank  NGL Stabilizer  NGL Exchange  After Scrubber

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $0 · Current $0

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 on paragraph (d) of this section) in a safe and timely manner when necessary means where taken to assure safe operation.    On or about October 31, 2018, and times prior thereto, ORyan Oil and Gas did not correct deficiencies in equipment that were not operational:      a.     the Mesh Guard-RAE hydrogen sulfide fixed monitors were not operable; and b.     26-100 Inlet gas filter/separator alarm was not operable.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $8,525 · Current $8,000 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes  to process chemicals, technology, equipment,  and procedures; and, changes to facilities that affect a covered process.         On or about October 31, 2018, and times prior thereto, ORyan Oil and Gas did not establish written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $8,525 · Current $7,000 Reduced

Hazardous substances 14808890

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:    On or about October 31, 2018, and times prior thereto, the employer exposed employees to inhalation, fire, and explosion hazards by not establishing and implementing an emergency action plan to ensure that employees working at the facility were protected from emergencies involving natural gas liquids. The emergency action must include, but is not limited to the following:     a) Procedures for reporting a fire or other emergency to include;        -Procedures for emergency evacuation, including type of evacuation and exit route assignments.        -Procedures to be followed by employees who remain to operate critical plant operations before they evacuate.        -Procedures to account for all employees after evacuation.        -Procedures to be followed by employees performing rescue or medical duties.        -The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.        -Employee alarm system with a distinctive signal for each purpose.         -Employee training.            -Review of emergency action plan with each employee covered by the plan.    b) Procedures for handling small releases.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 8890

General-duty citation text

29 CFR 1910.120(q)(1): The employer did not develop and implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:  On or about October 31, 2018, and times prior thereto, O'Ryan Oil and Gas did not develop a written emergency response plan to handle anticipated emergencies prior to the commencement of emergency response operations. The plan would need to include the following:    a) Pre-emergency planning and coordination with outside parties;  b) Personnel roles, lines of authority, training and communication;     c) Emergency recognition and prevention;      d) Safe distances and places of refuge;   e) Site security and control;  f) Evacuation routes and procedures;  g) Decontamination;  h) Employee medical treatment and first aid;   i) Emergency alerting and response;  j) Critique of response and follow-up; and  k) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $11,934 · Current $7,000 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.    On or about October 31, 2018, and times prior thereto, ORyan Oil and Gas did not certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. ORyan Oil and Gas did not perform compliance audits at any time between the years 2014-2018.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $8,525 · Current $2,000 Reduced

Hazardous substances 14808890

General-duty citation text

29 CFR 1910.134(c)(1): A written respiratory protection program that included the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures was not established and implemented where respirators are necessary to protect the health of the employees:        On or about October 31, 2018, and times prior thereto, and at times prior thereto, O'Ryan Oil and Gas did not establish and implement a written respiratory protection program exposing employees to health hazards. Respirators were available to employees in the event of an emergency;    a. Self-Contained Breathing Apparatus (SCBA) respirator located in the control room;      b. Two Self-Contained Breathing Apparatus (SCBA) respirators located outdoors in the facility; and      c. One bottled air-supplied system located adjacent to the knockout drums and flare.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $8,525 · Current $4,000 Reduced

Hazardous substances 14808890

General-duty citation text

29 CFR 1910.134(h)(3)(i)(B): Respirators maintained for use in emergency situations were not inspected at least monthly and in accordance with manufacturer recommendations:      On or about October 31, 2018, and at times prior thereto, the employer did not inspect, at least monthly, respirators maintained for use by employees in emergency situations. A bottled air-supplied respirator located outdoors adjacent to the knockout drums and flare was not inspected monthly.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 14808890

General-duty citation text

29 CFR 1910.134(h)(3)(iii): Self-contained breathing apparatus were not inspected monthly, maintained in a fully charged state, recharged when the pressure falls to 90% and the employer did not determine that the regulator and warning devices function properly:  On or about October 31, 2018, and times prior thereto, O'Ryan Oil and Gas did not inspect the following self-contained breathing apparatus (SCBA) monthly, did not maintain air and oxygen cylinders in a fully charged state and did not determine that the regulator and warning devices function properly.   Draeger PROAIR PLUS  a. One Self-Contained Breathing Apparatus (SCBA) respirator located in the control room; and b. Two Self-Contained Breathing Apparatus (SCBA) respirators located outdoors in the facility.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 14808890

General-duty citation text

29 CFR 1910.134(h)(3)(iv): 29 CFR 1910.134(h)(3)(iv): For respirators maintained for emergency use, the employer did not [A] Certify the respirator by documenting the date the inspection was performed, the name (or signature) of the person who made the inspection, the findings, required remedial action, and the serial number or other means of identifying the inspected respirator; and [B] Provide this information on a tag or label that is attached to the storage comparment for the respirator, is kept with the respirator, or is included in the inspection reports stored as paper or electronic files. This information shall be maintained untill replaced following a subsequent certification:  On or about October 31, 2018, and times prior thereto, O'Ryan Oil and Gas did not certify the following respirators, maintained for emergency use, by documenting: date the inspection was performed, the name (or signature) of the person who made the inspection, the findings, required remedial action, and a serial number or other means of identifying the inspected respirator; and did not provide this information on a tag or label that is attached to the storage compartment for the respirator, is kept with the respirator, or is included in inspection reports stored as paper or electronic files.  a. One Self-Contained Breathing Apparatus (SCBA) respirators located in the control room;    b. Two Self-Contained Breathing Apparatus (SCBA) respirators located outdoors in the facility; and    c. A bottled supplied-air breathing system located adjacent to the knockout drums and flare.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $11,934 · Current $7,000 Reduced

Hazardous substances 14808890

General-duty citation text

29 CFR 1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met:    On or about October 31, 2018, and times prior thereto, the employer did not develop a written hazard communication program which included the employee information and training, safety data sheets, labeling and the following provisions:      a. a list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet and,       b. the methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas.      The hazard communication program would need to address chemicals at the facility such as but not limited to, natural gas liquids (NGLs) which contain ethane, propane, butane, isobutane, and pentane; and hydrogen sulfide.

Issued

Mar 27, 2019

Abate by

Apr 24, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 14808890

General-duty citation text

29 CFR 1910.1200(f)(6)(ii): Except as provided in 29 CFR 1910.1200(f)(7) and 29 CFR 1910.1200(f)(8), the employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals and which, in conjunction with the other information immediately available to employees under the hazard communication program, would provide employees with the specific information regarding the physical and health hazards of the hazardous chemical   On or about October 31, 2018, and at times prior thereto, ORyan Oil and Gas did not ensure that each container of hazardous chemicals used in the workplace was labeled, tagged or marked with the specific information regarding the physical and health hazards of the hazardous chemical.    The following containers/vessels and associated piping containing natural gas liquids (e.g., ethane, propane, butane, isobutane, and pentane) were not properly labeled:   E-201 Amine Reboiler E-202 Amine Reclaimer V-300 Hot Oil Surge Tank V-200 Amine Flash Tank V-201 Amine Surge Tank V-202 Reflux Accumulator T-100 Amine Contactor T-200 Amine Still V-100 Amine Scrubber