OSHA Inspection: HOUSTON AMMONIA TERMINAL L.P.

Issued

2021-03-19 00:00:00

Abate by

2022-12-13 00:00:00

Penalty

Initial $13653.00 · Current $8874.00 Reduced

General-duty citation text

29 CFR  1910.119(e)(3)(iv): The process hazards analysis did not address the consequences of failure of engineering and administrative controls.   On or about October 22, 2020, and at times prior thereto, at the Houston Ammonia Terminal located in Pasadena, Texas, the employer failed to address the consequences of the loss of Nitrogen gas for purging, or inerting the Ammonia flare system.

Issued

2021-03-19 00:00:00

Abate by

2022-12-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR  1910.119(f)(1)(i)(E): Emergency Operations; The employer did not develop written operating procedures that provide clear instructions for safely conducting activities involved in each covered process.    On or about October 22, 2020, and at times prior thereto, at the Houston Ammonia Terminal located in Pasadena, Texas, the employer failed to develop an emergency procedure for flare operations if or when Nitrogen purge gas for the flare system is lost or unavailable.

Issued

2021-03-19 00:00:00

Abate by

2022-12-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR  1910.119(g)(1)(i): Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, was not trained in the emergency operating procedure    On or about October 22, 2020, and at times prior thereto, at the Houston Ammonia Terminal located in Pasadena, Texas, the employer failed to provide training on emergency procedure for flare operations when Nitrogen purge gas for the flare system was unavailable.

Issued

2021-03-19 00:00:00

Abate by

2022-12-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR  1910.119(l)(1): The employer did not implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.   On or about October 22, 2020, and at times prior thereto, at the Houston Ammonia Terminal located in Pasadena, Texas,  the employer failed to implement an MOC when the flare nitrogen purge gas was lost and the decision was made to continue to operate the flare outside the gas flow set limits.

Issued

2021-03-19 00:00:00

Abate by

2022-12-13 00:00:00

Penalty

Initial $13653.00 · Current $8874.00 Reduced

General-duty citation text

29 CFR  1910.119(f)(1)(i): Employer did not develop and implement written operating procedural steps for each operating phase to include, but not limited to; 1910.119(f)(1)(i)(C) Temporary operations;1910.119(f)(1)(i)(D) Emergency Shutdown including the conditions under which emergency shutdown is required 1910.119(f)(1)(i)(E) Emergency Operations;   On or about October 22, 2020, and at times prior thereto, at the Houston Ammonia Terminal located in Pasadena, Texas, the employer failed to document steps for each operating phases on  V-4 (Aqua Contactor) including but not limited to  Temporary Operations; Emergency Shutdown and Emergency Operations.

Issued

2021-03-19 00:00:00

Abate by

2022-12-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR  1910.119(f)(1)(ii):  The employer did not develop and implement written operating procedures that address the following: 1910.119(f)(1)(ii) Operating limits, 1910.119(f)(1)(ii)(A) Consequences of deviation; and 1910.119(f)(1)(ii)(B) Steps required to correct or avoid deviation.  On or about October 22, 2020, and at times prior thereto, at the Houston Ammonia Terminal located in Pasadena, Texas, the employer failed to provide written operating procedures that include safe operating limits, consequences of deviations and steps to correct the deviations for Liquid Level on V-4 (Aqua Contactor).

Issued

2021-03-19 00:00:00

Abate by

2022-12-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR  1910.119(f)(1)(iv): Employer did not develop and implement a written Operating Procedure that documented equipment safety systems and their functions.   On or about October 22, 2020, and at times prior thereto, at the Houston Ammonia Terminal located in Pasadena, Texas; the employer failed to document in its written procedure, the safety systems associated with the V-4 (Aqua Contactor).

Issued

2021-03-19 00:00:00

Abate by

2022-12-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR  1910.119(g)(1)(i): Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process was not trained in the operating procedures.    On or about October 22, 2020, and at times prior thereto, at the Houston Ammonia Terminal located in Pasadena, Texas; the employer failed to ensure employees were trained in operating procedures including but not limited to Temporary Operations; Emergency Shutdown and Emergency Operations, Safe Operating Limits for Liquid Level and Safety Systems for V-4 (Aqua Ammonia Contactor).

Issued

2021-03-19 00:00:00

Abate by

2022-12-13 00:00:00

Penalty

Initial $13653.00 · Current $8874.00 Reduced

General-duty citation text

29 CFR  1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.   On or about October 22, 2020, and at times prior thereto, at the Houston Ammonia Terminal located in Pasadena, Texas the employer did not ensure visual inspection and thickness measurement testing on process piping was consistent with its own established "HAT Risk Based Assessment for piping" procedures, such piping includes but is not limited to AV-WTG-224-10"1R1B piping section.

Issued

2021-03-19 00:00:00

Abate by

2022-12-13 00:00:00

Penalty

Initial $13653.00 · Current $8874.00 Reduced

General-duty citation text

29 CFR  1910.119(j)(4): The employer did not perform inspection and testing on equipment to maintain on-going mechanical integrity.   Instance a) On or about October 22, 2020, and at times prior thereto, at the Houston Ammonia Terminal located in Pasadena, Texas the employer failed to perform inspection and testing on process piping; including but not limited to AV-WTG-037-2" 1P1J vent discharge piping from V-5B (Aqua Ammonia Storage Tank) to the ammonia flare.  Instance b) On or about October 22, 2020, and at times prior thereto, at the Houston Ammonia Terminal located in Pasadena, Texas  when the employer failed to perform inspection and test to maintain the on-going integrity of process equipment including but not limited to safety systems;  1) Emergency Shutdown Device ESD-003 (T-1),  2) Emergency Shutdown Device ESD-004 (T-2)  3) Emergency Shutdown Device ESD 40-1(V-3). 4) High Level Alarm on Refrigerated Ammonia Storage Tanks T-1/T-2 and 5) Alarms and Interlocks on Aqua Ammonia Systems such as:     5a) 270" High Level in V-5B trip;     5b) V-5B Overflow Level trip;      5c) Low DI Water Pressure trip at 50 psig.      5d) Low DI Water Pressure at 50 psig Alarm.     5e) V-4 High Level Trip.     5f) V-4 Low Level Trip.

Issued

2021-03-19 00:00:00

Abate by

2022-12-13 00:00:00

Penalty

Initial $1095.00 · Current $712.00 Reduced

General-duty citation text

29 CFR  1910.119(j)(5): Equipment deficiencies. The employer did not correct deficiencies in equipment that are 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 are taken to assure safe operation.  On or about October 22, 2020, and at times prior thereto, at the Houston Ammonia Terminal located in Pasadena, Texas; the employer failed to ensure the loose and/or missing insulation on the process piping AV-WTG-224-10"1R1B was repaired and sealed to prevent condensation and corrosion.