OSHA has cited the company contracted to clean lines and vessels at the plant and the processing plant for serious safety violations after a fatal fire at a natural gas processing plant in Pennsylvania. OSHA inspected the company contracted to clean lines and vessels at the plant after four contractors suffered burns and needed hospitalization. One of them later died. OSHA cited the contractor for violations of the process safety management (PSM) standard and exposing employees to flammable vapor and liquid while they off-loaded waste material from a vessel into a mobile “frac” tank.
OSHA also inspected the host employer that operates the natural gas processing plant and cited the company for PSM violations and for failing to inspect the facility’s energy control procedures at least annually.
The contractor faces penalties totaling $51,148. The facility faces $47,360 in penalties.
Here is a breakdown of the citations:
SAFTENG NOTE: Not sure how this one will work out, as I have never seen a contractor working at a host facility be cited for these items since the process is NOT theirs. Very interesting and tragic case.
Facility Citations
Citation 1 Item 1
Type of Violation: Serious; $9,472
29 CFR 1910.119(f)(1): 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 and addressing at least steps for each operating phase, safe operating limits, safety and health considerations, and safety systems and their functions as outlined by this paragraph:
(a) Facility – On or about December 13, 2018, the employer did not establish written operating procedures that address switching from automatic control to manual mode operations for vessels such as but not limited to the Stabilizer Column.
(b) Facility – On or about December 13, 2018, the employer failed to establish written procedures for the cleaning of the slug catchers, stabilizer column and reboiler.
Citation 1 Item 2
Type of Violation: Serious; $9,472
29 CFR 1910.119(h)(2)(ii): The employer did not inform contract employees of potential fire, explosion or toxic release hazards related to working on or near a covered process.
(a) Process Area – On or about December 13, 2018, all contract employees working in the process area were not informed or aware of the contents they were working with, such as but not limited to multiple flammables that may cause explosions, fires, deflagration, and toxic release.
Citation 1 Item 3
Type of Violation: Serious; $9,472
29 CFR 1910.119(h)(2)(iii): The employer did not explain the applicable provisions of the emergency action plan to contract employees who work on or adjacent to a covered process.
(a) Facility – On or about December 13, 2018, the Employer did not explain the applicable provisions of the emergency action plan to all the contract employees who worked on or near the covered process.
Citation 1 Item 4
Type of Violation: Serious; $9,472
29 CFR 191O.119(h)(2)(iv): The employer did not develop and implement safe work practices consistent with paragraph (f)(4) of this section to control the entrance, presence, and exit of contract employers and contract employees in the covered process areas.
(a) Facility – On or about December 13, 2018, the employer failed to develop safe work practices to control hazards present that were associated with the contract employees work in the covered process areas.
Citation 1 Item 5
Type of Violation: Serious; $9,472
29 CFR 1910.119(h)(2)(v): The employer did not periodically evaluate the performance of contract employers to ensure they are fulfilling their obligations as specified in 29 CFR 1910.119(h)(3).
(a) Facility- On or about December 13, 2018, the employer did not periodically evaluate the performance of their contract employer while performing cleaning operations of the Slug Catchers and Stabilizer Column.
Citation 2 Item 1
Type of Violation: Other-than-Serious; $0.00
29 CFR 1910.147(c)(6)(i): The employer did not conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirement of this standard were being followed.
(a) Facility – On or about December 13, 2018, the employer failed to conduct a periodic inspection of the facilities energy control procedure at least annually.
Contractor Citations
Citation 1 Item 1
Type of Violation: Serious; $9,472
29 CFR 1910.119(h)(3)(i): The contract employer did not assure that each contract employee is trained in the work practices necessary to safely perform his/her job.
(a) Process Area – On or about December 13, 2018, the contract employer did not assure each contract employee was trained in the work practices to safely perform his job in the process area while conducting cleaning activities of the slug catchers, stabilizer column, and reboiler.
Citation 1 Item 2
Type of Violation: Serious; $9,472
29 CFR 1910.119(h)(3)(ii): The contract employer did not assure that each contract employee was instructed in the known fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan.
(a) Facility – On or about December 13, 2018, the contract employer did not assure each contract employee was instructed in the known fire, explosion, or toxic release hazards related to the process while working in and near the process area.
Citation 1 Item 3
Type of Violation: Serious; $9,472
29 CFR 1910.119(h)(3)(iv): The contract employer did not assure that each contract employee follows the safety rules of the facility including the safe work practices required by paragraph (f)(4) of this section.
Stabilizer Column – On or about December 13, 2018, the contract employer failed to follow the host employers safety rules including the safe work practices of the lockout/tagout program. All of the Authorized Employees conducting cleaning activities of the Stabilizer Column did not participate in group lockout/tagout.
Citation 1 Item 4
Type of Violation: Serious; $9,472
29 CFR 1910.119(h)(3)(v): The contract employer did not advise the employer of any unique hazards presented by the contract employer’s work, or of any hazards found by the contract employer’s work.
(a) Stabilizer – On or about December 13, 2018, while contract employees were working to clean out the Stabilizer Column they encountered LEL alarms on their personal 4 gas meters and did not advise the host employer of the hazards found during their work.
Citation 1 Item 1
Type of Violation: Serious; $13,260
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:
a) At the De-Ethanizer Pad, on or about December 13, 2018 – Employees pumped a solution of heated water and descaler into Stabilizer Tower T-511 with a vacuum tanker truck. A vacuum tanker truck removed a load of waste material from Stabilizer Tower T-511 after the solution soaked in Stabilizer Tower T-511. Stabilizer Tower T-511 waste material was moved by the vacuum tanker truck to the DeEthanizer Pad where Frac Tank A2363 was staged. Prior to off-loading Stabilizer Tower T-511 waste material into Frac Tank A2363, 405 barrels of “A” slug catcher liquid was taken out of Frac Tank A2363 leaving a residual amount of “A” slug catcher liquid leftover in Frac Tank A2363. While offloading Stabilizer Tower T-511 waste material into Frac Tank A2363, vapors escaped Frac Tank A2363 through an opened manway cover and the vacuum tanker truck through the pump exhaust. Employees were exposed to these vapors with sources of ignition including, but not limited to, static electricity, running propane heater trucks, a running vacuum tanker truck, hot heater coils on the propane heater trucks, heater exhaust on the propane heater truck, hot water outlet pipe on the propane heater truck, and an air heater in the area surrounding Frac Tank A2363.
Among other methods, feasible abatement methods to correct this hazard would be to comply with API Recommended Practice 2219 Safe Operation of Vacuum Trucks Handling Flammable and Combustible Liquids in Petroleum Service Fourth Edition, June 2016 and to operate equipment in accordance with the manufacturer’s instructions, including, but not limited to:
- Closing the system by ensuring openings to the frac tank are shut or using ventilation to properly control vapors when off-loading flammable material in accordance with section 5.8.3.1 Off-Loading of API 2219,
- Eliminate potential ignition sources by properly grounding and bonding the receiving container and the vacuum truck in accordance with section 5. 8. 3 .1 Off-Loading of API 2219,
- Consider the wind direction when placing trucks for off-loading and control of vapors released by the off-loading process in accordance with section 5. 8 .3 .1 Off-Loading of API 2219,
- Off-load flammable liquids by gravity or an inert gas pressure blanket in accordance with section 5.8.3.2 Off-Loading of API 2219,
- Do not permit sources of ignition, such as running propane heater trucks, running vacuum tanker truck, hot heater coils on the propane heater trucks, heater exhaust on the propane heater truck, hot water outlet pipe on the propane heater truck, and an air heater within at least 100 ft ( depending on local procedures and atmospheric conditions) of the vacuum tanker truck, the discharge of the vacuum pump, or any other vapor source in accordance with section 5.13.6 Personnel Safety of API 2219,
- Follow the Houston Facility’s hot work policies in accordance with section 5.13.6 of Personnel Safety of API 2219,
- Operate the Masport Vacuum Pump System in accordance with the manufacturer’s instructions, which states that Masport pumps must not be used to move flammable or highly caustic material.