NOTE: these are from the fatal 2014 NH3 Truck Unloading accident, where the “bleed tank” (which was a plastic IBC) catastrophically failed because a liquid NH3 valve was left open. I have no idea why this 5(a)(1) was not issued as a RAGAGEP citation using ANSI K61/CGA 2.1, which is where the facility siting requirements stated in the citation originate from.
OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees are exposed to crushing injuries, struck-by injuries, severe burns, tissue damage, or pulmonary edema from potential train derailment, flying debris, sparks, and gas and/or liquid anhydrous ammonia from release.
Four (4) permanent anhydrous ammonia storage tanks, ranging in capacity from 12,000 to 15,000 gallons, are each located closer than 100 feet to a Class 4 (per 49 CFR 213.9) mainline of a railroad.
Trucks transporting approximately 40,000 pounds of anhydrous ammonia also unload in the area between tank #4 (north end closest to tracks) and the railroad mainline.
AMONG OTHER METHODS, FEASIBLE AND ACCEPTABLE METHODS TO CORRECT THIS HAZARD ARE:
1) Relocate anhydrous ammonia storage tanks to a minimum 100 feet of separation between the tanks and the mainline of the adjacent railroad per ANSI K61.1 (1999)/CGA G-2.1 (1999) – Table 3 as adopted by Nebraska State Fire Marshal as Title 153, NAC Chapter 14.
2) Contact railroad about potential relocation of the adjacent mainline to a minimum separation distance of 100 feet between the anhydrous ammonia storage tanks and the railroad mainline.
3) Protect transport drivers, other workers, and tanker trucks during anhydrous ammonia transfer operations between the railroad tracks and ammonia storage tank #4.
Source: https://www.osha.gov/ords/imis/establishment.violation_detail?id=964263.015&citation_id=01004