On Jan. 20, a pressure-relief device released flammable gas and liquid into the atmosphere; it burned for more than two hours. OSHA investigated the facility and cited the employer for one willful and six serious safety violations. The violations included failing to train operators, update operating procedures, conduct a management of change analysis when changing software and hardware, conduct periodic inspections and document inspections on emergency shutdown devices.
Citation 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 191O.119(g)(1)(i): The employer did not train each employee before being involved in operating a newly assigned process in the operating procedures as specified in paragraph (f) of this section:
At this workplace, the employer did not provide adequate training to ensure facility operators were aware of the Human Machine Interface (HMI) software control and data communication changes from the old Wonderware to the new Rockwell systems.
Citation 1 Item 2
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(2): The employer did not implement written procedures to maintain the on-going integrity of process equipment:
At this workplace, the employer did not adequately implement written procedures to maintain the integrity of process equipment, such as, but not limited to, the Emergency Shut Down (EDS) valves at:
- the Stedman discharge pipelines,
- the Copano discharge pipelines, and
- the Recompressor discharge pipelines.
Citation 1 Item 3
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(4)(i): The employer did not perform inspections and tests on process equipment:
At this workplace, the employer did not inspect and test critical process equipment, such as, but not limited to, Emergency Shut Down (ESD) valves, and pressure relief and control valves. Employees at this facility were exposed to fire and explosion hazards and to catastrophic release of flammable gases.
Citation 1 Item 4
Type of Violation: Serious; $7,000
29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process:
Facility did not prepare management of change documents addressing the following changes which were not evaluated or documented prior to installation and operation:
- Human Management Interface (HMI) system change from the Wonderware to the Rockwell FaceTalk software/hardware system.
- Valve replacement at the Stedman pipeline, Copano pipeline and the Recompressor discharge pipeline.
Citation 1 Item 5
Type of Violation: Serious; $7,000
29 CFR 1910.119(l)(5): A change covered by this paragraph resulted in a change in the operating procedures or practices required by paragraph (f) of this section, and such procedures or practices were not updated accordingly:
At this workplace, the employer did not establish or update operating procedures to ensure employees safely and accurately performed required procedures such as:
- Normal operations
- Emergency operations
Citation 1 Item 6
Type of Violation: Serious; $7,000
29 CFR 1910.119(m)(5): The employer did not establish a system to promptly address and resolve incident report findings and recommendations. Resolutions and corrective actions were not documented:
At this workplace, the employer did not promptly address the incident report corrective actions recommendations for the natural gas liquids vapor released occurring on or about December 14, 2014 at Plant number one.
Citation 2 Item 1
Type of Violation: Willful; $70,000
29 CFR 1910.119(f)(1)(i)(D): The employer did not develop and implement written operating procedures that provide clear instructions for emergency shutdown, including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner:
The employer did not develop and implement written operating procedures that provided clear instructions for performing an emergency shutdown of the facility in the event of an emergency at the Gregory Plant. The operating procedures failed to properly address the shutdown of the Steadman, Copano, and Recompressor inlet valves using the HMI system located in the control room.
Operating Procedure 005-SOP-GGPF does not include procedures for shutting down the inlet valves for the Steadman, Copano, and Recompressor. This exposed employees to fire and explosion hazards from catastrophic release of flammable gas.
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