OSHA Inspection: PERGAN MARSHALL, LLC

Issued

Mar 15, 2019

Abate by

Jul 3, 2019

Penalty

Initial $7,293 · Current $8,000

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process:    On or before September 21, 2018, and at times thereafter the employer did not ensure that the  Piping and Instrument Diagram (P&ID's) for B1-6 was accurate in that vessels T-311 was mislabeled F-311 and T-312 was mislabeled F-312.

Issued

Mar 15, 2019

Abate by

Jul 3, 2019

Penalty

Initial $10,210 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): The employer did not complete the compilation of written process safety information pertaining to the equipment in the process:    On or before September 21, 2018, and at times thereafter the employer did not compile written process information for the relief system design and design basis.

Issued

Mar 15, 2019

Abate by

Jul 3, 2019

Penalty

Initial $10,210 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E): Information pertaining to the equipment in the process did not include a ventilation system design:    On or before September 21, 2018, and at times thereafter the employer did not compile the written information for the ventilation system design for:    a) the drum filling operation in the B1 Packaging Area.    b) the can filling operation in the M1/M2 Packaging Area.

Issued

Mar 15, 2019

Abate by

Jul 3, 2019

Penalty

Initial $10,210 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): Inspections and tests were not performed on process equipment.    On or before September 21, 2018, and at times thereafter the employer did not perform inspections and tests on the following process equipment:    a) Pressure relief valves had not been inspected: PSV-6, PSV-11A, PSV-11B, PSV-T5-2, PSV-T5CV, PSV-312, PSV-E201B, PSV-E-202, PSV-E203, PSV-T40A, PSV-T40B, PSV-T40C, PSV-T40D, PSV-D-201;    b) Out of service or retired from service vessels had not been inspected: D-233, F-403, T-302, T-301, T-303, F-206;    c) Heat exchangers had not been inspected: E-201B, E-202B, E-1000, E-2000;    d) Vessels R-1000, R-2000, R-4000b had not been inspected.

Issued

Mar 15, 2019

Abate by

Jul 3, 2019

Penalty

Initial $10,210 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(ii): Inspection and testing procedures did not follow recognized and generally accepted good engineering practices:    On or before September 21, 2018, and at times thereafter the employer did not perform external visual inspections and on-stream/condition monitoring inspections and tests on piping circuits and establish corrosion rates in vessels in accordance with recognized and generally accepted good engineering practices, such as, but not limited to API 570 and API 510.  Equipment include but is not limited to the following:    Piping Circuits:   a) 2"-PR-30502-CBQ1-NI; 2"-PR-30503-CBQ1-NI; 2"-PR-30506-CBQ1-NI       2"-PR-30515-CBQ1-NI; 2"-N-30501-CBQ1-NI;       b) 3"-V-30407-30B1-NI; 2"-PR-30401-30B1-NI; 2"-PR-30402-30B1-NI;        1.5"-PR-30404-30B1-NI; 2"-PR-30406-30B1-NI; 2"-PR-30408-30B1-NI;       1.5"-PR-30409-30B1-NI; 1.5"-PR-30410-30B1-NI; 1.5"-PR-30427-30B1-NI;               c) 8"-PR-00724-35B7-CC; 1.5"-PR-00318-30B1-CC; 3"-PR-00701-30B1-CC;       2"-PR-00702-30B1-CC;       d) 1.5"-PR-00201-19A3-NI; 1.5"-PR-00202-30B1-CC;        .75"-RGR-00217-19A3-CC; 1"-PR-00207-19A3-CC; 4"-PR-00221-19A3-NI; 4"-PR-00227-19A3-NI;       e) 2"-PR-00802-30B1-CC; 3"-PR-00701-30B1-CC; 1.5"-PR-00319-30B1-CC;        1.5"-PR-00420-30B1-NI;       f) 1.5" PR-0804-30B1-NI;       g) 2"-PR-00413-30B1-CC; 2"-PR-00820-30B1-CC;    Vessel Corrosion Rates for the following vessels:    h) R4000B;    i)  R1000;    j)  R2000;    k) R400A;    l)  R400B;    m) F203;    n) F207;    o) D700;    p) T306;    q) T5;    r) T7000;    s) T312;    t) T311;    u) F313;    v) T6A;    w) T11;    x) R4000B;    y) R1000;    z) R2000.

Issued

Mar 15, 2019

Abate by

Jul 3, 2019

Penalty

Initial $10,210 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers' recommendations and good engineering practices, or more frequently if determined to be necessary by prior operating experience:    On or before September 21, 2018, and at times thereafter the employer did not perform inspections and tests of process equipment in accordance with recognized and good engineering practices such as, but not limited to, AP510 and 653 for the following process equipment:     a) F-313 Ultrasonic Thickness and external inspections had not been conducted since 2004;      b)  T-311 Ultrasonic Thickness and external inspections had not been conducted since 2002;    c)  T-312 Ultrasonic Thickness and external inspections had not been conducted since 2002;    d)  The Ultrasonic Thickness inspection for R-200 due on October 04, 2011 was not completed;     e) T-7000 Ultrasonic Thickness and external inspections had not been conducted since 2002;      f)  T-6A Ultrasonic Thickness and external inspections had not been conducted since 2002;     g)   T-11 Ultrasonic Thickness and external inspections had not been conducted since 2002;     h)  T-900, T-910, T-920 external inspection was last completed in April 2013;    i) 400A and 400C were last inspected in 2002 and inspections were recommended in 2005;    j) 400B was last inspected in 2013 and an inspection was recommended in 2015;      k) T-306 were last inspected in 2002.

Issued

Mar 15, 2019

Abate by

Jul 3, 2019

Penalty

Initial $10,210 · Current $5,000 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 on paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.    On or before September 21, 2018, and at times thereafter the employer did not correct deficiencies in process equipment that were outside acceptable limits; before further use or in a safe and timely manner for the following process equipment:    a) Vessel T-900 was operated below the retirement thickness as identified by ultrasonic testing;    b) Vessel T-910 was operated below the retirement thickness as identified by ultrasonic testing;    c) Vessel T-920 was operated below the retirement thickness as identified by ultrasonic testing.