OSHA has issued several PSM citations at a natural gas processing facility from an inspection that began in October 2014. This was an unannounced planned Chem NEP inspection. Of special note, these violations include issues with not having a Car Seal Program for valves within the relief path(s) of several relief devices. OSHA referenced ASME Section VIII, but did not specifically reference Appendix M-5 which contains the requirements for when a block valve is placed in the path of the relief system. PLEASE see my 2011 article, Car Seal Program and Relief Valves regarding how to comply with ASME Section VIII Appendix M- 5.
Note: The following inspection has not been indicated as closed. Please be aware that the information shown may change, e.g. violations may be added or deleted.
Citation 1 Item 1
Type of Violation: Serious; $7,000
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 toe-boards: Note: Toe-boards are required when persons can pass, there is moving equipment or there is equipment with which falling materials could create a hazard.
On or about October 9, 2014, and times prior thereto, at the amine TK-36 tank, the employer did not provide a standard guard railing system and toe-boards on the upper work platform exposing employees to a fall hazard approximately 10 feet to the ground level.
Citation 1 Item 2a
Type of Violation: Serious; $4,250
29 CFR 1910.253(b)(2)(ii): Assigned storage spaces for cylinders were not located where cylinders could not be !mocked over or damaged by passing or falling objects, or subject to tampering by unauthorized persons:
On or about October 9, 2014, and times prior thereto, inside the #1 and #2 plant skids building, nitrogen compressed air cylinders were not chained or secured to prevent them from falling, exposing employees to struck-by hazards.
Citation 1 Item 2b
Type of Violation: Serious; Grouped
29 CFR 1910.253(b)(2)(iv): Valve protection caps, where cylinders were designed to accept caps, were not always in place, hand-tight, except when cylinders were in use or connected for use.
On or about October 9, 2014, and times prior thereto, inside the #1 and #2 plant skids building, unused nitrogen compressed gas cylinders were stored without the protective cap exposing employees to struck-by hazards.
Citation 1 Item 3
Type of Violation: Serious; $,4000
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 had been corrected.
The employer does not ensure that the findings of the compliance audit promptly have been corrected. The violation occurred in the Facility on or about October 9, 2014 and times prior thereto where employees were exposed to inhalation, fire, and explosion hazards from potential releases of hazardous materials when the employer failed to ensure the 2011 PSM compliance audit findings had been corrected such as but not limited to:
- Spring-20110824-04
- Spring-20110824-15
- Spring-20110824-21
Citation 1 Item 4
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team’s findings and recommendations; assure t11at 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 tl1e recommendations or actions.
The employer does not ensure that the PHA recommendations are resolved in a timely manner. The violation occurred in the Facility on or about October 9, 2014 and at times prior thereto where employees were exposed to inhalation, fire, and explosion hazards from potential releases of hazardous materials when the employer failed to ensure the 2013 PHA recommendation for providing an Emergency Shutdown (ESD) system for the process was resolved in a timely manner.
Citation 1 Item 5
Type of Violation: Serious; $5,000
29 CPR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices.
The employer does not ensure that equipment in the process complies with recognized and generally accepted good engineering practices (RAGAGEP):
- The violation occurred in the Facility on or about October 9, 2014 and at times prior thereto where the employer failed to ensure pressure-relief-valve stacks complied with the American Petroleum Institute (API) 521 such as but not limited to:
- Pressure-relief-valve stack for Amine Storage Tank (TK-36) on P&ID SPR-M0-1-542A Rev. 3
- Pressure-relief-valve stack for Air Instrument Receiver (TK-IAl) on P&ID SPR-M0-1-701 Rev. 3
This condition exposed employees to inhalation, fire, and explosion hazards from releases of hazardous materials.
- This violation occurred in the Facility on or about October 9, 2014 and at times prior thereto where the employer failed to ensure car seals on block/stop valves of relief devices complied with the American Standard Mechanical Engineer (ASME) Boiler and Pressure Vessel Code Section VIII for the flowing pressure relief valves such as but not limited to:
- Block valve for PSV-IAl on P&ID SPR-M0-1-701 Rev.3
- Block valve for PSV-JA3 on P&ID SPR-M0-1-701 Rev.3
- Block valve for PSV-6335 (717A) on P&ID SPR-M0-1-405 Rev. 25
- Block valve for PSV-3367 (718) on P&ID SPR-M0-1-405 Rev. 25
Citation 1 Item 6
Type of Violation: Serious; $7,000
29 CFR 191O.119(j)(4)(i): The employer did not perform inspection and tests on process equipment. The employer does not perform inspections and tests on process equipment.
The violation occurred in the Facility on or about October 9, 2014 and at times prior thereto where employees were exposed to fire and inhalation hazards when the employer failed to perform testing and inspections of controls designated as safeguards such as but not limited to:
- Temperature Alarm High (TAH) and Temperature Alarm High High (TAHH)-1111 A on P&ID SPR-M0-1-303 rev.3
- Temperature Alarm High (TAH) and Temperature Alarm High High (TAHH)-1211 A on P&ID SPR-M0-1-304 rev.3
- Temperature Alarm High (TAH) and Temperature Alarm High High (TAHH)-1111 on P&ID SPR-M0-1-303 rev.3
- Temperature Alarm High (TAH) and Temperature Alarm High High (TAHH)-121 on P&ID SPR-MO-l-304rev.3
- Temperature Alarm Low Low (TALL)-1 on P&ID SPR-M0-1-311 rev.0
- Level Switch High High (LSHH)-B0-006 on P&IDSPR-MOcJ-102 rev.10
- Shutdown Valve (DV)-1366 on P&ID SPR-M0-1-102 rev.10
- Pressure Safety Valve (PSV)-244 onP&ID SPR-M0-1-356 rev.5
Citation 1 Item 7
Type of Violation: Serious; $7,000
29 CFR 1910.119 (j)(2): The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment.
The employer does not ensure written procedures are established and implemented to maintain the ongoing mechanical integrity of the process equipment.
The violation occurred in the Facility on or about October 9, 2014 and at times prior thereto where the employer failed to ensure written procedures were established and implemented for block/stop valves of pressure relief devices. This condition exposed employees to inhalation, fire, and explosion hazards from potential releases of hazardous materials.
CLICK HERE (pdf) for the citations