OSHA Inspection: SUMMIT MIDSTREAM PARTNERS LLC

Issued

Nov 19, 2019

Abate by

Mar 23, 2020

Penalty

Initial $8,051 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complied with recognized and generally accepted good engineering practices:    (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not document that equipment complied with recognized and generally accepted good engineering practices (RAGAGEP).  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  A control building, located approximately 150 feet from the nearest process equipment, was constructed of steel frame with metal siding and roof.  The control building contained windows and multiple doors.  The control building was intended for occupancy.  A facility site study performed for the employer in 2014 identified the location of the control building as within Zone 1 of an external vapor cloud explosion of the process area.  The site study identified multiple deficiencies with the control building in the event of an explosion or fire.  The employer did not document that the control building complied with RAGAGEP such as American Petroleum Institute RP 752 "Management of Hazards Associated with Location of Process Plant Permanent Buildings".  This condition exposed employees to fire, explosion, and chemical hazards.

Issued

Nov 19, 2019

Abate by

Jan 21, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(v): The employer's process hazard analysis did not address facility siting:  (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer's process hazard analysis did not address facility siting.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  A light wood trailer was placed adjacent to the control building in 2014.  The trailer and a control building were utilized as office, work space, and break area.  The trailer was intended for occupancy.  A facility site study performed for the employer in 2014 was utilized for the 2016 PHA.  The light wood trailer was located within the area identified as Zone 1 of an external vapor cloud explosion of the process area.  Light wood trailers intended for occupancy cannot be located within Zone 1.  The 2016 PHA did not address facility siting issues related to the light wood trailer.  This condition exposed employees to fire, explosion, and chemical hazards.

Issued

Nov 19, 2019

Abate by

Mar 23, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The employer's process hazard analysis did not address human factors:    (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer's process hazard analysis did not address human factors.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  The employer performed a PHA in 2016 using a HAZOP methodology.  Employees performed maintenance and operations tasks.  Tasks may have standard operating procedures.  The PHA did not address human factors issues related to deviation from any developed standard operating procedures.  This condition exposed employees to fire, explosion, and chemical hazards.    (b)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer's process hazard analysis did not address human factors.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  The employer performed a PHA in 2016 using a HAZOP methodology.  Employees performed non-routine tasks such as the de-energization, purging, and isolation of piping to the residue compressors prior to work performed on the compressors as part of the gas plant expansion project.  The PHA did not address human factors issues related to non-routine tasks.  This condition exposed employees to fire, explosion, and chemical hazards.

Issued

Nov 19, 2019

Abate by

Mar 23, 2020

Penalty

Initial $0 · Current $0

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 are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions:  (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  A control building, located approximately 150 feet from the nearest process equipment, was constructed of steel frame with metal siding and roof.  The control building contained windows and multiple doors.  The control building was intended for occupancy.  A facility site study performed for the employer in 2014 was utilized for the 2016 PHA.  The facility site study performed for the employer in 2014 identified the location of the control building as within Zone 1 of an external vapor cloud explosion of the process area.  The site study identified multiple deficiencies with the control building in the event of an explosion or fire, including potential building collapse (BDL 4) in the event of a leak from the NGL surge tank resulting in a vapor cloud explosion or fire.  The 2016 PHA did not respond to the facility site study referred to in the PHA nor make recommendations for corrective action.  This condition exposed employees to fire, explosion, and chemical hazards.

Issued

Nov 19, 2019

Abate by

Jan 21, 2020

Penalty

Initial $0 · Current $0

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:  (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not establish and implement written procedures to manage changes to facilities that affect a covered process.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  A light wood trailer was placed adjacent to the control building in 2014.  The trailer and control building were utilized as office, work space, and break area.  The trailer was provided with electricity to power lighting, phones, HVAC, and office equipment.  The trailer was intended for occupancy.  The light wood trailer was located approximately 135 feet from the process area.  The electrical equipment were potential ignition sources in the event of a release of natural gas or natural gas liquids from process equipment.  The employer did not establish and implement written procedures to manage the installation of the light wood trailer in proximity to the covered process.  This condition exposed employees to fire, explosion, and chemical hazards.  (b)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not establish and implement written procedures to manage changes to facilities that affect a covered process.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  Five light wood trailers were placed to the west of the control building in 2018.  The trailers were utilized as office, work space, and break areas for the gas plant expansion construction project, while the original gas plant was still in operation. The trailers were provided with electricity to power lighting, phones, HVAC, and office equipment.  The trailers were intended for occupancy.  The nearest of the five light wood trailers was located approximately 130 feet from the original gas plant process area.   The electrical equipment were potential ignition sources in the event of a release of natural gas or natural gas liquids from process equipment.  The employer did not establish and implement written procedures to manage the installation of the five light wood trailers in proximity to the covered process.  This condition exposed employees to fire, explosion, and chemical hazards.

Issued

Nov 19, 2019

Abate by

Jan 21, 2020

Penalty

Initial $8,051 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(F): The employer did not develop and implement written operating procedures that provided clear instructions for conducting activities during normal shutdown:    (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not develop and implement written operating procedures that provided clear instructions for conducting activities during normal shutdown.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  The employer had developed written operating procedures for normal operations, shut-down, start-up, and emergency shut-down for some process activities.  The employer had not developed a written procedure for the shutdown of the C-4701 and C-4702 residue compressors.  This condition exposed employees to explosion, fire, and chemical hazards.    (b)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not develop and implement written operating procedures that provided clear instructions for conducting activities during normal shutdown.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  The employer had developed written operating procedures for normal operations, shut-down, start-up, and emergency shut-down for some process activities.  The employer had not developed a written procedure for the shutdown of the gas plant, including, but not limited to the purging of flammable hydrocarbon gases from process equipment including pipelines.  This condition exposed employees to explosion, fire, and chemical hazards.

Issued

Nov 19, 2019

Abate by

Jan 21, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(A): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities in that the written operating procedures did not include properties of, and hazards presented by, the chemicals used in the process:  (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities in that the written operating procedures did not include properties of, and hazards presented by, the chemicals used in the process.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  The employer's written operating procedure "H2S Sweeting Skid COD & Emergency Operations" directed operators to "verify atmosphere in the H2S building with MX4 personal monitor" when the H2S building LEL alarm was in high high mode or when the H2S building H2S detector was in high high mode.  The written operating procedure did not provide adequate information regarding the hazards of hydrogen sulfide.  This condition exposed employees to a respiratory hazard.

Issued

Nov 19, 2019

Abate by

Jan 21, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(B): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities in that the written operating procedures did not provide instructions addressing the personal protective equipment precautions necessary to prevent employee exposures:  (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities in that the written operating procedures did not provide instructions addressing the personal protective equipment precautions necessary to prevent employee exposures.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  The employer's written operating procedure "H2S Sweeting Skid COD & Emergency Operations" directed operators to "verify atmosphere in the H2S building with MX4 personal monitor" when the H2S building LEL alarm was in high high mode or when the H2S building H2S detector was in high high mode.  A MX4 personal monitor is a passive device 4 gas meter worn by a worker.  The written operating procedure did not provide instructions regarding personal protective equipment, including respiratory protection, to be worn into a work environment where an unknown concentration of flammable, toxic gas may be present.  This condition exposed employees to a respiratory hazard.

Issued

Nov 19, 2019

Abate by

Mar 23, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(iv): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities in that the written operating procedures did not provide information on safety systems and their functions:    (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities in that the written operating procedures did not provide instructions addressing the personal protective equipment precautions necessary to prevent employee exposures.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  The employer had developed written operating procedures for normal operations, shut-down, start-up, and emergency shut-down for some process activities.  The written operating procedures did not provide information regarding safety systems and their functions, such as but not limited to methane and propane detection systems, LEL alarms, H2S detectors, H2S alarms, Emergency Shut Down buttons, the "gold shut-down button", and 4 gas meters.  This condition exposed employees to explosion, fire, and chemical hazards.

Issued

Nov 19, 2019

Abate by

Dec 23, 2019

Penalty

Initial $8,051 · Current $6,000 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 programs:    (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On or about 6/5/19, the employer, when selecting a contractor, did not obtain and evaluate information regarding the contract employer's safety performance and programs.  Archrock Services LP and Femco Holdings LLC were hired to perform contract work at the natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  Summit Midstream Partners LLC did not obtain and evaluate information regarding Femco Holdings LLC safety performance and programs prior to the work at the gas plant.  This condition exposed employees of Archrock Services LP, Summit Midstream Partners LLC, and Femco Holdings LLC to fire, explosion, and chemical hazards.

Issued

Nov 19, 2019

Abate by

Dec 23, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(h)(2)(iii): The employer did not explain to contract employers the applicable provisions of the emergency action plan required by paragraph (n) of this section:  (a) Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On or about 6/5/19, the employer did not explain to contract employers the applicable provisions of the emergency action plan required by paragraph (n) of this section.  Archrock Services LP and Femco Holdings LLC were hired to perform contract work at the natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  The gas plant alarm system had been disabled while integrating the alarm system from the old section of the plant with the alarm system for the gas plant expansion.  Summit Midstream Partners did not explain to the contractors that the alarm system had been disabled or if there was an alternative alarm system in place.  This condition exposed eight employees of Archrock Services LP and Femco Holdings LLC to fire, explosion, and chemical hazards.

Issued

Nov 19, 2019

Abate by

Dec 23, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(h)(2)(v): The employer did not periodically evaluate the performance of contract employers in fulfilling their obligations as specified in paragraph (h)(3) of this section:  (a) Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On or about 6/5/19, the employer did not periodically evaluate the performance of contract employers in fulfilling their obligations as specified in paragraph (h)(3) of this section.  Archrock Services LP and Femco Holdings LLC were hired to perform contract work at the natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  Summit Midstream Partners LLC did not periodically evaluate the performance of Archrock Services LP and Femco Holdings LLC regarding their obligations under (h)(3) of this section, such as, but not limited to documentation of training, training of employees in work practices necessary to safely perform their jobs, training of employees in the known potential fire, explosion, or toxic release hazards related to their jobs, and assurance that employees follow the safety rules of the facility.  This condition exposed employees of Archrock Services LP, Summit Midstream Partners LLC, and Femco Holdings LLC to fire, explosion, and chemical hazards.

Issued

Nov 19, 2019

Abate by

Jan 20, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1926.20(b)(2): The employer did not initiate and maintain a safety program which provides for frequent and regular inspections of jobsites, materials, and equipment to be made by a competent person (i.e., a person who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authority to take prompt corrective measures to eliminate them):    a) Summit Midstream Partners, LLC at 67509 Weld County Road 71 in Grover, CO 80729: On or before 6/05/19, the employer issued a hot work permit to a contractor and subcontractor to modify cooler piping on an existing compressor. After issuing the permit, the employer did not ensure that the contractor and subcontractor followed all instructions outlined in the permit.  Although the employer observed the contractor using an air monitor, the employer did not ensure that the subcontractor working on the cooler piping was using air monitors.  Once it was determined that hydrocarbons were present, the employer communicated with the first contractor to shut the job down, but did not fully communicate to the subcontractor that the job was shut down. This condition exposed contractor subcontractor employees to respiratory, chemical, fire, and explosion hazards.

Issued

Nov 19, 2019

Abate by

Mar 23, 2020

Penalty

Initial $8,051 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment:    (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  Employees performed mechanical integrity inspections, calibration, and maintenance upon process equipment.  The employer did not establish an adequate written procedure for inspection, calibration, and maintenance of level, pressure, and temperature sensors and transmitters for process equipment.  This condition exposed employees to explosion, fire, and chemical hazards.    (b)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  Employees performed mechanical integrity inspections, calibration, and maintenance upon process equipment.  The employer did not establish an adequate written procedure for inspection, calibration, and maintenance of LEL, propane, and hydrogen sulfide sensors and transmitters for process equipment.  This condition exposed employees to explosion, fire, and chemical hazards.    (c)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  Employees performed mechanical integrity inspections, calibration, and maintenance upon process equipment.  The employer did not establish a written procedure for inspection, calibration, and maintenance of smoke detectors and the fire alarm system for the MCC building.  This condition exposed employees to explosion, fire, and chemical hazards.    (d)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  Employees performed mechanical integrity inspections, calibration, and maintenance upon process equipment.  The employer did not reference a recognized and generally accepted good engineering practice, such as American Petroleum Institute RP 576 "Inspection of Pressure-Relieving Devices", as a basis for its written procedure for inspection, calibration, and maintenance of pressure relief valves for pressure vessels at the gas plant.

Issued

Nov 19, 2019

Abate by

Dec 23, 2019

Penalty

Initial $4,831 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.1200(e)(2)(i): At a multi-employer workplace, the employer's hazard communication program as implemented did not include methods the employer used to provide other employers with on-site access to a safety data sheet for each hazardous chemical the other employers' employees may be exposed to while working:      (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/5/19, the employer's hazard communication program as implemented did not include methods the employer used to provide other employers with on-site access to a safety data sheet for each hazardous chemical the other employers' employees may have been exposed to while working.  Archrock Services LP and Femco Holdings LLC were hired to perform contract work at the natural gas plant.  Summit Midstream Partners LLC did not ensure that its written hazard communication program as implemented included the methods used to provide on-site access to SDSs for hazardous chemicals at the gas plant that other employers' employees may be exposed to while working at the multi-employer worksite.  Hazardous chemicals at the gas plant included, but were not limited to the following:    1.  Natural gas;   2.  Natural gas liquids;  3.  Glycol; and   4.  Nitrogen.

Issued

Nov 19, 2019

Abate by

Dec 23, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(g)(8): The employer did not ensure that Safety Data Sheets (SDS) were readily accessible during each work shift to employees when they were in their work area(s):    (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/10/19, the employer did not ensure that Safety Data Sheets (SDS) were readily accessible during each work shift to employees when they were in their work area(s).  The employer utilized an internet based resource for accessing Safety Data Sheets (SDSs).  The employer did not have a backup means for accessing SDSs.  Hazardous chemicals present in the workplace included, but were not limited to the following:    1.  Natural gas;   2.  Natural gas liquids;  3.  Glycol; and   4.  Nitrogen.

Issued

Nov 19, 2019

Abate by

Dec 23, 2019

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:  (a)  Summit Midstream Partners LLC, at 67509 Weld County Road 71, Grover, CO: On and preceding 6/4/19, the employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies had been corrected.  Summit Midstream Partners LLC operated a natural gas plant.  The gas plant contained highly hazardous chemicals in excess of the threshold quantity for flammable gases or liquids.  The gas plant was a PSM facility.  A PSM program compliance audit took place in 2016.  The compliance audit presented several findings for corrective action.  Summit Midstream Partners LLC did not document that deficiencies had been corrected.