OSHA Inspection: TRADEMARK NITROGEN CORP.

Issued

2016-11-08 00:00:00

Abate by

2016-11-16 00:00:00

Penalty

Initial $4988.00 · Current $2494.00 Reduced

General-duty citation text

29 CFR 1910.23(c)(1): Open-sided floors and/or platforms four feet or more above adjacent floor or ground level were not guarded with standard railings (or equivalent) and toeboards:    a) For the ammonia process, as observed on or about/between 07/07/2016 - 08/31/2016, employees were exposed to fall hazards of approximately 15 ft. while operating valves where top rails were missing on the upper catwalk's railings for the ammonia bottles.

Issued

2016-11-08 00:00:00

Abate by

2017-01-06 00:00:00

Penalty

Initial $6236.00 · Current $3118.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the consequences of failure of engineering and administrative controls:    For the ammonia process, as observed on or about/between 07/07/2016 - 08/31/2016, the employer's process hazard analysis and all revalidations did not address the failure of engineering controls such as, but not limited to, the following:      a) Failure of Detcon ammonia detectors and alarm system was not addressed in the process hazard analyses that had been conducted.    b) Failure of ammonia Sensidyne sensors that activated a deluge system was not addressed in the process hazard analyses that had been conducted.    c) Failure of equipment interlocks via sensors/switches/controllers such as, but not limited to, Fisher 4160 pneumatic controller were not addressed in the process hazard analyses that had been conducted.

Issued

2016-11-08 00:00:00

Abate by

2017-01-06 00:00:00

Penalty

Initial $6236.00 · Current $3118.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(A): 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 that addressed initial startup.    a) For the ammonia process, as observed on or about/between 07/07/2016 - 08/31/2016, written startup procedures were not available for startup of the ammonia bottles flowing the complete shutdown of the acid plant.

Issued

2016-11-08 00:00:00

Abate by

2017-01-06 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1)(i)(B): 29 CFR 1910.119(f)(1)(I)(B): The employer's written operating procedures covering the steps for each operating phase did not address normal operations:    For the ammonia process, as observed on or about/between 07/07/2016 - 08/31/2016, normal operating procedures were not developed for the following normal operations:    a) Written normal operating procedures were not developed for steps necessary to keep the pH value in the neutralizer at a safe, operational level.    b) Written normal operating procedures were not developed for draining and isolating ammonia lines around the neutralizer section ammonia pump for the purpose of isolating the pump.    c) Written normal operating procedures were not developed for draining and isolating ammonia lines around the vaporizers for the purpose of isolating the vaporizers.    d) Written normal operating procedures were not available for normal operation activities conducted around the acid plant and neutralizer including, but not limited to, making converter temperature adjustments, measuring compressor and motor vibrations, and taking pressure and temperature tank readings of the neutralizer.

Issued

2016-11-08 00:00:00

Abate by

2017-01-06 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1)(i)(E):  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 that addressed emergency operations.    For the ammonia process, as observed on or about/between 07/07/2016-08/31/2016, the employer's operating procedures for the ammonia processes did not address emergency operations. The operating procedures for the acid plant, neutralizer, and ammonia bottles did not include what steps are to be followed in emergency operations where operating conditions are outside of safe, established limits.     a) Emergency operating procedures were not in place to address how to handle deviations in process operating parameters such as, but not limited to, temperature, pressure, flowrate, and pH level.    b) Emergency operating procedures were not in place to address how to handle power failures and the resulting startup from power failures.

Issued

2016-11-08 00:00:00

Abate by

2017-01-06 00:00:00

Penalty

Initial $0.00 · Current $0.00

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 safely conducting activities involved in each covered process consistent with the process safety information that addressed normal shutdown.    a) For the ammonia process, as observed on or about/between 07/07/2016 -08/31/2016, written operating procedures were not developed for normal shutdown of the ammonia bottles following acid plant shutdown.

Issued

2016-11-08 00:00:00

Abate by

2017-01-06 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(A): The employer did not develop and implement written operating procedures that addressed the consequences of deviations from the operating limits in the covered process;      a) For the ammonia process, as observed on or about/between 07/07/2016-08/31/2016, the employer did not develop operating procedures that addressed the consequences of deviation from process operating parameters such as, but not limited to, deviation of pH values, ammonia flow, and nitric acid flow at the neutralizer.

Issued

2016-11-08 00:00:00

Abate by

2017-01-06 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(B): The employer did not develop and implement written operating procedures that provide clear instructions for steps required to correct or avoid deviation from the operating limits in the covered process.    For the ammonia process, as observed on or about/between 07/07/2016 - 08/31/2016, the employer's operating procedures did not contain clear steps to correct or avoid deviation from operating limits such as, but not limited to, how to correct/avoid deviations in pH, ammonia flow, and nitric acid flow at the neutralizer.

Issued

2016-11-08 00:00:00

Abate by

2017-01-06 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(A): Operating procedures did not address properties of, and hazards presented by, the chemicals used in the process    a) For the ammonia process, as observed on or about/between 07/07/2016-08/31/2016, the employer's operating procedures did not address the properties and hazards of hazardous chemicals present such as, but not limited to, anhydrous ammonia and nitric acid.

Issued

2016-11-08 00:00:00

Abate by

2017-01-06 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1)(iv): The employer failed to ensure that the Process Safety Management Standard Operating Procedures included safety systems and their functions.    a) For the ammonia process, as observed on or about/between 07/07/2016 - 08/31/2016, the employer's operating procedures for the neutralizer process, acid plant, and operation of ammonia bottles did not include safety systems such as, but not limited to, the following:    a) Detcon system for ammonia detection    b) Sensidyne ammonia sensors/detectors and deluge systems    c) Fisher Pressure Controllers

Issued

2016-11-08 00:00:00

Abate by

2017-01-06 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not annually certify that operating procedures were current and accurate.     a) For the ammonia process, as observed on or about/between 07/07/2016 - 08/31/2016, the employer did not annually certify operating procedures related to anhydrous ammonia for the following processes:    a) Acid Plant operation    b) Neutralizer process operation    c) Ammonia bottles operation

Issued

2016-11-08 00:00:00

Abate by

2016-12-06 00:00:00

Penalty

Initial $6236.00 · Current $3118.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not implement written procedures to maintain the on-going integrity of process equipment:    For the ammonia process, as observed on or about/between 07/07/2016 -08/31/2016, maintenance procedures were not being implemented in that the following equipment was not being inspected or serviced in accordance with the employer's mechanical integrity program.    a) Semi-annual inspections of auxiliary equipment for the ammonia process including, but not limited to, sight glasses and strainers for the ammonia process were not being done. The last inspection of this equipment had taken place in 2004.    b) Five year piping inspections were not being done according to the employer's mechanical integrity program for the ammonia process. The employer's mechanical integrity program specified a 5 year piping inspection audit, and the last piping inspection/audit occurred on 06/01/2009.    c) Hydrostatic testing of the ammonia transfer hoses was not being done. The manufacturer of the hoses specifies hydrostatic testing every 3 to 5 minutes every 12 months.

Issued

2016-11-08 00:00:00

Abate by

2016-12-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

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, and more frequently if determined to be necessary by prior operating experience.  For the ammonia process, as observed on or about/between 07/07/2016 - 08/31/2016, the following equipment was not inspected with the frequency specified in the manufacturer's recommendations, employers procedures, or good engineering practice:  a) Sensidyne ammonia sensors were calibrated annually while the manufacturer specifies a calibration frequency of once every 90 days. Bump tests were also not performed on a regular basis.  b) Ammonia piping 5-year audits/inspections were not conducted in the last five years as the employer's inspection frequency and selected industry design standards specified. The last time piping inspections were conducted that included non-destructive testing was in 2009.

Issued

2016-11-08 00:00:00

Abate by

2016-12-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that was performed on process equipment wherein the documentation identified the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.    For the ammonia process, as observed on or about/between 07/07/2016 - 08/31/2016, the following inspections and tests being performed were not documented:    a) Calibration and inspection of the Sensidyne ammonia sensor at the unloading section.    b) Visual inspection of the ammonia and water separators on the ammonia bottles.    c) Inspections of ammonia transfer hoses prior to use.

Issued

2016-11-08 00:00:00

Abate by

2017-04-17 00:00:00

Penalty

Initial $6236.00 · Current $3118.00 Reduced

General-duty citation text

29 CFR 1910.147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:    a) For the ammonia process, as observed on or about/between 07/07/2016 - 08/31/2016, employees performed maintenance on equipment such as, but not limited to, ammonia pumps, ammonia vaporizers, and ammonia tanks 318A, 318B, 601, 602, 603, and 607. Hazardous energy existed in the form of 480 VAC electricity, high temperature steam lines, ammonia lines, and moving parts.

Issued

2016-11-08 00:00:00

Abate by

2017-04-17 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.147(c)(4)(ii): Procedures did not clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, 29 CFR 1910.147(c)(4)(ii)(A), (c)(4)(ii)(B), (c)(4)(ii)(C) and (c)(4)(ii)(D):    For the Trademark Nitrogen facility, as observed on or about/between 07/07/2016 and 08/31/2016, lockout tagout procedures for equipment such as, but not limited to, the following were not clear and specific in their scope, purpose, authorization, rules, and techniques:    a) procedures for isolating tanks throughout the facility did not specify the specific location of all energy isolating sources including, but not limited to, pump motors' disconnects and ammonia sparges that are to be used to de-energize the equipment.    b) procedures for isolating tanks throughout the facility did not clearly specify the location of the energy source to be used to test the equipment in order to ensure that it was de-energized.     c) Acid Plant Compressor Isolation procedure did not specify the location of the energy source to be used to test the equipment to ensure that it was de-energized.

Issued

2016-11-08 00:00:00

Abate by

2017-01-06 00:00:00

Penalty

Initial $6236.00 · Current $3118.00 Reduced

General-duty citation text

29 CFR 1910.147(c)(7)(i)(A): Each authorized employee had not received training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control:    a) For the Trademark Nitrogen facility, as observed on or about/between 07/07/2016 - 08/31/2016, authorized maintenance employees worked on equipment such as, but not limited to, pumps, motors, and ammonia vaporizers containing hazardous energy in the form of anhydrous ammonia, moving parts, 480VAC, and high temperature steam lines. Employees had not been trained on or seen specific procedures relating to their jobs, and it was common practice for a maintenance employee to work on equipment without applying a lock/tag to the energy isolating device.

Issued

2016-11-08 00:00:00

Abate by

2016-11-29 00:00:00

Penalty

Initial $6236.00 · Current $3118.00 Reduced

General-duty citation text

29 CFR 1910.147(d)(4)(i): Lockout or tagout devices were not affixed to each energy isolating device by authorized employees:    a) For the Trademark Nitrogen facility, as observed on or about/between 07/07/2016 - 08/31/2016, employees conducted maintenance work under the lockout/tagout of another employee/foreman and did not have their own locks and tags, and did not affix their own locks and tags to the energy isolating device for the equipment they were working on. Employees worked on equipment such as, but not limited to, pumps and motors. Employees were potentially exposed to hazardous energy in the form of anhydrous ammonia lines, 480VAC electricity, and moving parts.