This paper company had 39 VPP Sites in 2013 and today they were placed in OSHA’s SVEP for this incident. Here is a breakdown of the citations that took them from VPP to SVEP. A 57-year-old general mechanic was removing burned filter bags of combustible fly ash dust from a dust collector in the facility’s power plant and replacing them with new bags when the fly ash ignited. He sustained severe burns as a result and subsequently died.
Citation 1 Item 1
Type of Violation: Serious; $7,000
OSH ACT of 1970 Section (5)(a)(l): 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 were exposed to combustible dust deflagration, explosion, and other fire hazards from the deficient design and/or implementation of preventative and/or protective measures in the Power House fly ash conveying system:
a) Power House Fly Ash Conveying System – On or about January 23, 2015, the explosion relief lid of the fly ash silo was located inside and so that it would vent to an employee occupancy area. The explosion relief lid was below grated platforms, fixed ladders and below the material air separator that was being serviced by employees.
b) Power House Fly Ash Conveying System – On or about January 23, 2015, system components, including but not limited to, the Delta Ducon Perma Flo Rotary Feeder (P0#8900434467) located between the material air separator and the ash silo was not maintained as designed. The distance between the shoe and the rotor was approximately 0.23 inches. The manufacturer designed set clearance is 0.004 inches. Not maintaining the set manufacture distance allows for air involvement within the vessel and can provide the oxygen needed for fire.
c) Power House Fly Ash Conveying System – On or about January 23, 2105, system components, including but not limited to, the Knappco Vacuum Pressure Relief Vent (K-720AA) was not maintained as designed. Deficiencies of the vent, included but were not limited to, missing neoprene gasket(s), broken and missing bolts for the lid, and a deformed and dislodged internal plate. Not maintaining the set manufacture distance allows for air movement within the vessel and can provide the oxygen needed for fire.
d) Power House Fly Ash Conveying System – On or about January 23, 2105, the system components did not prevent an ignition source from entering the material air separator that contained a combustible fly ash dust. Burning fly ash and/or embers entered the system through the ash line from the upstream hoppers.
Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions of applicable consensus standards:
- Evaluate the impact zone for a deflagration and restrict personnel access to that area while the system is in operation.
- Establish and implement written procedures to allow access to the fly ash conveying system area for servicing.
- Refer to NFPA 654 Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing and Handling of Combustible Particulate Solids, 2013
- Chapter 7 Process Equipment requires compliance with NFPA 68 Standard on Explosion Protection by Deflagration Venting
- Section 7 .1.6.1 Where an explosion hazard exists, isolation devices shall be provided to prevent deflagration propagation between connected equipment in accordance with NFPA 69
- Chapter 12 Inspection and Maintenance requires the establishment of an inspection, testing and maintenance program to ensure that the fire m1d explosion protection systems and related process controls and equipment perform as designed, and this includes dust control equipment.
- Section 9 .1.3 Inherently ignitable process streams, means shall be provided to minimize the hazard as described in section 7 (process equipment) and 10 (fire protection).
- Chapter 7 Process Equipment requires compliance with NFPA 68 Standard on Explosion Protection by Deflagration Venting
- Refer to NFPA 68 Standard on Explosion Protection by Deflagration Venting, 2013
- Section 8.6.1 Vent existing explosion lid to a safe location outside.
- Section 8.9 Define unsafe areas by dimensionally characterizing the potential fireball and pressure wave employing the calculations in this section.
- Define by signage the unsafe area proximate to the explosion relief lid where employees could be exposed to venting hazards.
- Refer to NFPA 69 Standard on Explosion Prevention Systems, 2014
- Section 12.2.4.5.1 requires a clearance gap of 0.0079 inches between the valve body and the vanes of the rotary valve to prevent passage of flame through the rotary valve.
Citation 1 Item 2
Type of Violation: Serious; $7,000
29 CFR 1910.269(d)(2)(iv)(B): The energy control procedures did not include specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy:
a) Power House – On or about January 23, 2015, the procedure to control hazardous energy for “Fly Ash Bag House” did not include steps for, including but not limited to, the lock out the pneumatic slide gate, ash silo bin vibrator, and the control of the burning fly ash dust and filter bags as energy source. The hazards for this deficiency include, but are not limited to, release of combustible fly ash dust exposing employees to fire and explosion hazards.
Note: Lockout and tagging procedures that comply with paragraphs (c) through (f) of 1910.147 will also be deemed to comply with paragraph ( d) of this section if the procedures address the hazards covered by paragraph (d) of this section.
Citation 1 Item 3
Type of Violation: Serious; $7,000
29 CFR 1910.261 (a)(3)(ix): Installation of blower and exhaust systems for dust, stock, and vapor removal or conveying was not in accordance with American Standards Association Z33.1 – 1961 (National Fire Protection Association 91), which is incorporated by reference as specified in 29 CFR 1910.6:
a) Power House Fly Ash Conveying System – On or about January 23, 2015, the system containing combustible fly ash dust did not have an automatic fire suppression protection.
b) Power House Fly Ash Conveying System – On or about January 23, 2015, the material air separator (baghouse) and ash cyclone containing combustible fly ash dust did not have explosion venting.
c) Power House Fly Ash Conveying System – On or about January 23, 2015, the room for the fly ash conveying system, containing combustible fly ash, did not have automatic fire suppression.
d) Cyclone Room Paper Dust Collection System – On or about March 24, 2015, the green cyclone containing combustible paper dust did not have explosion venting that directed to the outside.
e) Cyclone Room Paper Dust Collection System – On or about March 24, 2015, the amber cyclone containing combustible paper dust did not have explosion venting that directed to the outside.
f) Cyclone Room Paper Dust Collection System – On or about March 24, 2015, the red cyclone containing combustible paper dust did not have explosion venting that directed to the outside.
Abatement:
- National Fire Protection Association 91/American Standards Association Z33.1 1961: Blower Exhaust Systems 1961
- See part 463 for the requirement for automatic extinguishing system for the fly ash conveying system
- See part 453 for the requirement for explosion venting on air material separator and ash cyclone
- See part 461 for the requirement for fire suppression system in the room for the fly ash conveying system
Citation 2 Item 1
Type of Violation: Willful; $70,000
29 CFR 1910.132(a): Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, were not provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact:
a) Power House – On and prior to January 23, 2015, the employer did not provide fire resistant clothing for the task of removing burned filter bags in the fly ash dust collector to replace them with new filter bags. The task involved opening a dust collector containing combustible fly ash dust, handling the filter bag steel ring frame that could be in excess of 375 degrees Farienheit, and handling filter bags that were on fire or smoldering.
Citation 2 Item 2
Type of Violation: Willful; $70,000
29 CFR 1910.1200(h)(3)(ii): Employee training did not include the physical and health hazards of the chemicals in the work area:
a) Power House – On or about January 23, 2015, the employer did not provide training on the specific hazards associated with fly ash (combustible dust) for the maintenance employees replacing burned filter bags that were smoldering in the fly ash conveying system. International Paper safety data sheet for “Boiler Ashes” states the following:
– NFPA Flammability 1
– Dust/air mixture may ignite or explode
-Avoid heat, flames, sparks and other sources of ignition
Citation 3 Item 1
Type of Violation: Repeat; $50,000
29 CFR 1910.269(d)(2)(v): The employer did not conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the provisions of paragraph (d) of this section are being followed:
a) Power House – On or about January 23, 2015, the employer did not conduct the annual inspection of the procedure to control hazardous energy for “Fly Ash Bag House”. The most recent inspection was on April 4, 2013. Hazardous energy sources include electric, steam, air and combustible fly ash dust.
Hazards for the service and maintenance of the “FlyAsh Bag House” include, but are not limited to, release of combustible fly ash dust exposing employees to fire and explosion hazards.
Company was previously cited for a violation of this equivalent occupational safety and health standard which was contained in OSHA inspection number 315156059, citation number 1, item number 3, and was affirmed as a final order on July 25, 2011, with respect to a workplace located in IL.
Company was previously cited for a violation of this equivalent occupational safety and health standard which was contained in OSHA inspection number 314593484, citation number 1, item number 3, and was affirmed as a final order on May 27, 2011, with respect to a workplace located in OH.
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