OSHA has issued $206,945 in fines to a power plant, and one of its contractors after a hydrogen sulfide (H2S) gas leak killed two workers and injured four others inside a PRCS last August. The power company was fined $77,605, while the contractor that was performing maintenance at the plant was fined $129,340. OSHA says it found the power plant failed to properly communicate to its contractor the dangers that the workers faced in the vault (PRCS). It found that the contractor failed to provide the proper respiratory protection for the workers. A five-man contractor crew entered into the PRCS to remove an elbow joint from a pipe, while one power plant employee supervised from the top. At some point, the pipe burst, releasing H2S and likely a sludge of coal waste. Here are the OSHA citations for the contractor:
Citation 1 Item 1
Type of Violation: Serious; $12,934
29 CFR 1910.146(d)(2): Under the permit-required confined space program required by 29 CFR
1910.146(c)(4), the employer did not identify and evaluate the hazards of permit spaces before employees entered:
a) In the North Division Vault of the North LDS Pond, on or aboutAugust29, Z017 -The employer failed to identify and evaluate hazards of the vault before employees began to open the 24-inch LDS pipeline which introduced a water engulfment hazard, hydrogen sulfide atmospheric hazard, and hazards associated with oxygen fuel gas torch use into the space.
Citation 1 Item 2
Type of Violation: Serious; $12,934
29 CFR 1910.146(d)(3): Under the permit-required confined space program required by 29 CFR
1910.146(c)(4), the employer did not develop and implement the means, procedures, and practices necessary for safe permit space entry operations:
a) In the North Division Vault of the North LDS Pond, on or about August 29, 2017 -The employer failed to develop and implement the means, procedures, and practices necessary for safe permit space entry. The employer failed to specify acceptable entry conditions, purge or ventilate the space to control atmospheric hazards or verify that conditions in the permit space were acceptable for entry throughout the authorized entry.
Citation 1 Item 3
Type of Violation: Serious; $12,934
29 CFR 1910.146(d)(5): Permit-required confined space(s) were not evaluated as required under (d)(5)(i) through (d)(5)(vi) of this paragraph when entry operations were conducted:
a) In the North Division Vault of the North LDS Pond, on or about August 29, 2017 -The employer failed to continuously monitor the vault for hydrogen sulfide while employees opened the 24-inch LDS pipeline which contained hydrogen sulfide gas.
Citation 1 Item 4
Type of Violation: Serious; $12,934
29 CFR 1910.146(d)(6): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer did not provide at least one attendant outside the permit space into which entry was authorized for the duration of entry operations:
a) In the North Division Vault of the North LDS Pond, on or about August 29, 2017 – The employer failed to provide an attendant outside the vault while employees entered the vault to remove an elbow from a 24-inch pipeline which introduced a water engulfment hazard, hydrogen sulfide atmospheric hazard, and hazards associated with oxygen fuel gas torch use into the space.
Citation 1 Item 5
Type of Violation: Serious; $12,934
29 CFR 1910.146(d)(8): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer did not designate the persons who were to have active roles in entry operations, identify the duties of each such employee, and did not provide each such employee with the training required by paragraph (g) of this section:
a) In the North Division Vault of the North LDS Pond, on or about August 29, 2017 -The employer failed to designate the persons who were to have active roles in the entry of the vault to remove an elbow from a 24-inch pipeline which introduced a water engulfment hazard, hydrogen sulfide atmospheric hazard, and hazards associated with oxygen fuel gas torch use into the space.
Citation 1 Item 6
Type of Violation: Serious; $12,934
29 CFR 1910.146(d)(9): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer did not develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue:
a) In the North Division Vault of the North LDS Pond, on or about August 29, 2017 -The employer failed to implement procedures for rescuing employees inside the vault who were removing an elbow from a 24-inch pipeline which introduced a water engulfment hazard, hydrogen sulfide atmospheric hazard, and hazards associated with oxygen fuel gas torch use into the space.
Citation 1 Item 7
Type of Violation: Serious; $12,934
29 CFR 1910.146(e)(1): Before entry was authorized, the employer did not document the completion of measures required by 29 CFR 1910.146(d)(3) by preparing an entry permit:
a) In the North Division Vault of the North LDS Pond, on or about August 29, 2017 -The employer failed to prepare an entry permit before employees entered the vault to remove an elbow from a 24-inch LDS pipeline which introduced a water engulfment hazard, hydrogen sulfide atmospheric hazard, and hazards associated with oxygen fuel gas torch use into the space.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 8a
Type of Violation: Serious; $12,934
29 CFR 1910.146(g)(1): The employer did not provide training so that all employees whose work was regulated by 29 CFR 1910.146 (permit required confined spaces) acquired the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under 29 CFR 1910.146:
a) In the North Division Vault of the North LDS Pond, on or about August 29, 2017 – The employees who entered the vault to remove an elbow from a 24-inch LDS pipeline did not acquire the understanding, knowledge, and skills necessary to perform duties assigned under 29 CFR 1910.146.
Citation 1 Item 8b
Type of Violation: Serious; Grouped
29 CFR 1910.146(h)(1): The employer did not ensure that all authorized entrants knew the hazards that could be faced during entry, including information on the mode, sign or symptoms, and consequences of the exposure:
a) In the North Division Vault of the North LDS Pond, on or about August 29, 2017 -The employer failed to ensure that employees knew the signs or symptoms of exposures that could be faced during entry into the vault. Employees entered the vault to remove an elbow from a 24-inch pipeline which introduced a water engulfment hazard, hydrogen sulfide atmospheric hazard, and hazards associated with oxygen fuel gas torch cutting into the space.
Citation 1 Item 9
Type of Violation: Serious; $12,934
29 CFR 1910.1200(h)(3): The employee training did not include the requirements of 29 CFR
1910.1200(h)(3)(i) through (h)(3)(iv):
a) In the North Division Vault of the North LDS Pond, on or about August 29, 2017 -The employer failed to provide training to employees who entered the vault on the methods and observations used to detect the presence or release of hydrogen sulfide in the vault, health hazards of hydrogen sulfide in the vault, and measures employees can take to protect themselves from hydrogen sulfide in the vault.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 10a
Type of Violation: Serious; $12,934
29 CFR 1910.1000(b)(2): Employee(s) were exposed to an airborne concentration of hydrogen sulfide listed in Table Z-2 in excess of the ceiling concentration of 20 ppm:
a) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 -A Boilermaker died as a result of drowning due to hydrogen sulfide gas exposure above the ceiling concentration of 20 ppm while removing an elbow in the 24-inch LDS pipeline.
b) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 -A Boilermaker died as a result of drowning due to hydrogen sulfide gas exposure above the ceiling concentration of 20 ppm while removing an elbow in the 24-inch LDS pipeline.
c) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 -A Boilermaker was hospitalized as a result of hydrogen sulfide gas exposure above the ceiling concentration of 20 ppm while removing an elbow in the 24-inch LDS pipeline.
d) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 -A Boilermaker was hospitalized as a result of hydrogen sulfide gas exposure above the ceiling concentration of 20 ppm while on the top deck at the vault while other Boilermakers were removing an elbow in the 24-inch LDS pipeline.
e) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 -A Boilermaker was hospitalized as a result of hydrogen sulfide gas exposure above the ceiling concentration of 20 ppm while inside the vault while other Boilermakers were removing an elbow in the 24-inch LDS pipeline.
Citation 1 Item 10b
Type of Violation: Serious; Grouped
29 CFR 1910.1000(e): Feasible administrative or engineering controls were not determined and implemented to achieve compliance with the limits prescribed in 29 CFR 1910.1000(a) through (d):
a) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 -The employer failed to determine and implement feasible administrative or engineering controls’ to achieve compliance with the permissible exposure and ceiling limits for hydrogen sulfide while employees removed an elbow in the 24-inch LDS pipeline.
Citation 1 Item 10c
Type of Violation: Serious; Grouped
29 CFR 1910.134(c)(1): A written respiratory protection program that included the provisions in 29 CFR 1910.134(c)(1)(i) – (ix) with worksite-specific procedures were not established and implemented for required respirator use:
a) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 -The employer failed to implement the respiratory protection program for a boilermaker who was exposed to hydrogen sulfide above the permissible exposure and ceiling limits while inside the vault removing an elbow from a 24-inch line that contained water, hydrogen sulfide gas, and ash slurry.
b) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 – The employer failed to implement the respiratory protection program for a boilermaker who was exposed to hydrogen sulfide above the permissible exposure and ceiling limits while inside the vault removing an elbow from a 24-inch line that contained water, hydrogen sulfide gas, and ash slurry.
c) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 -The employer failed to implement the respiratory protection program for a boilermaker who was exposed to hydrogen sulfide above the permissible exposure and ceiling limits while inside the vault removing an elbow from a 24-inch line that contained water, hydrogen sulfide gas, and ash slurry.
d) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 -The employer failed to implement the respiratory protection program for a boilermaker who was exposed to hydrogen sulfide above the permissible exposure and ceiling limits while on the top deck at the vault while other employees were removing an elbow from a 24-inch line that contained water, hydrogen sulfide gas, and ash slurry.
e) In the North Division Vault of the NorthLDS Pond, on or about August 30, 2017 -The employer failed to implement the respiratory protection program for a boilermaker who was exposed to hydrogen sulfide above the permissible exposure ceiling limits while inside the vault removing an elbow from a 24-inch line that contained water, hydrogen sulfide gas, and ash slurry.
Citation 1 Item 10d
Type of Violation: Serious
29 CFR 1910.134(d)(1)(i): An appropriate respirator was not selected and provided based on the respiratory hazard(s) to which the worker is exposed and workplace and user factors that affect respirator performance and reliability:
a) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 – The employer failed to select and provide appropriate respiratory protection to a boilermaker who was exposed to hydrogen sulfide gas above the permissible exposure limit.
b) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 -The employer failed to select and provide appropriate respiratory protection to a boilermaker who was exposed to hydrogen sulfide gas above the permissible exposure limit.
c) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 -The employer failed to select and provide appropriate respiratory protection a boilermaker who was exposed to hydrogen sulfide gas above the permissible exposure limit.
d) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 – The employer failed to select and provide appropriate respiratory protection to a boilermaker who was exposed to hydrogen sulfide gas above the permissible exposure limit.
e) In the North Division Vault of the North LDS Pond, on or aboutAugust 30, 2017 -The employer failed to select and provide appropriate respiratory protection to a boilermaker who was exposed to hydrogen sulfide gas above the permissible exposure limit.
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