OSHA has issued $77,605 in fines to a power plant after a hydrogen sulfide (H2S) gas leak killed two contractors 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.
At 12:40 a.m. on August 30, 2017, six employees were working inside the North LDS Pond Vault and were removing an elbow from a 24 inch LDS Pond pipe located approximately 10 feet from the bottom of the vault. Employee #1 and Employee #2 were removing the last bolts in the top flange when the elbow shifted. Hydrogen sulfide gas and ash slurry escaped from the pipe and began to fill the vault. Employees #1 and #2 were unable to escape the vault and drowned in coal ash slurry. Employees #3 through #6 escaped the vault and were hospitalized due to their exposure to the Hydrogen Sulfide.
Here are the OSHA citations for the contractor:
Citation 1 Item 1
Type of Violation: Serious; $12,934
29 CFR 1910.146(c)(6): When there were changes in the use or configuration of anon-permit confined space that could increase the hazards to entrants, the employer did not reevaluate that space and, when necessary, reclassify it as a permit-required confined space:
a)In the North Division Vault of the North LDS Pond, on or about August 29, 2017 -The employer failed to reevaluate and reclassify the vault as a permit-required confined space before mechanical contractors 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.
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 2a
Type of Violation: Serious; $12,934
29 CFR 1910.146(c)(8)(i): When an employer arranged to have employees of another employer (contractor) perform work that involved permit space entry, the host employer did not inform the contractor that the workplace contained permit spaces and that permit space entry is allowed only through compliance with a permit space program meeting the requirements of this section:
a) In the North Division Vault of the North, LDS Pond, on or about August 29, 2017 – The employer failed to inform the mechanical contractor that the vault was a permit-required confined space prior to entry by mechanical contractor employees.
Citation 1 Item 2b
Type of Violation: Serious
29 CFR 1910.146(c)(8)(ii): When an employer arranged to have employees of another employer (contractor) perform work that involved permit space entry, the host employer did not apprise the contractor of the elements, including the hazards identified and the host employer’s experience with the space, that makes the space in question a permit space:
a) In the North Division Vault of the North LDS Pond, on or about August 29, 2017 -The employer failed to apprise the mechanical contractor of the engulfment hazard, dangerous atmosphere hazards, and hazards associated with the use of oxygen-fuel gas torch cutting hazard during entry into the vault.
Citation 1 Item 3
Type of Violation: Serious; $12,934
29 CFR 1910.146(d)(5)(ii): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer did not evaluate permit space conditions when entry operations were conducted by testing or monitoring the permit space as necessary to determine if acceptable entry conditions are being maintained during the course of entry operations:
a) In the North Division Vault of the North LDS Pond, on or about August 29, 2017 -The employer failed to monitor the vault for acceptable entry conditions while mechanical contractor employees were inside the vault conducting operations which could introduce hydrogen sulfide gas including removing a 24-inch LDS pipe elbow.
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 4a
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 entry supervisor/lead did not acquire understanding, knowledge, and skills necessary to perform duties assigned under 29 CFR 1910.146.
Citation 1 Item 4b
Type of Violation: Serious; Grouped
29 CFR 1910.146(g)(3): The employer did not provide training that established employee proficiency in the duties required by 29 CFR 1910.146, Permit-required confined spaces, and did not introduce new or revised procedures, as necessary, for compliance with this section:
a) In the North Division Vault of the North LDS Pond, on or about August 29, 2017 -The employer failed to provide training that established the entry supervisor/lead’s proficiency in the duties required by 29 CFR 1910.146.
Citation 1 Item 5
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 the entry supervisor/lead 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 6a
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 of20 ppm:
a) In the North Division Vault of the North LDS Pond, on or about August 30, 2017 -A Power Plant employee was hospitalized as a result of exposure to hydrogen sulfide gas above the ceiling concentration of 20 ppm while the Power Plant employee was at the top of the vault as contractors removed an elbow from the 24-inch LDS pipeline.
Citation 1 Item 6b
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 NorthLDS 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 a Power Plant employee was working at the top of the vault and, at the same time, contractors removed an elbow from the 24-inch LD pipeline.
Citation 1 Item 6c
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 an employee who was exposed to hydrogen sulfide above the permissible exposure and ceiling limits while contractors were inside the vault removing an elbow from a 24-inch line that contained water, hydrogen sulfide gas, and ash slurry.
Citation 1 Item 6d
Type of Violation: Serious; Grouped
29 CFR 1910.134(d)(1)(i): An appropriate respirator was not selected and provided based on the respiratory hazard(s) to which the workers 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 an employee who was exposed to hydrogen sulfide gas above the permissible exposure limit.
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