OSHA has found that the U.S. Department of Interior’s Bureau of Land Management violated procedures for safe handling of chemical materials at its Helium Enrichment Unit, a federal chemical producing plant that refines and sells helium products to private entities. OSHA issued the facility 21 notices of unsafe working conditions. This is OSHA’s first use of the egregious violation policy in citing unsafe working conditions at a federal facility. The violations of process safety management procedures would carry a private sector penalty of $1,023,987. The Department of Interior’s Office of the Inspector General initiated the June 8, 2021, inspection after the OIG received serious safety and health allegations from workers at the facility.
Notice I Item 1
Type of Violation: Serious
29 CFR 1910.119(d)(3)(i)(D): The employer did not include, in the process safety information compilation, the relief system design and the design basis:
(a) On June 8, 2021, and at times prior the Bureau of Land Management failed to include in the process system information compilation, the relief system design and the design basis such as but not limited to:
– All applicable overpressure scenarios
– All applicable relief load calculations
– PRD Documentation – PRD make/model, and materials of construction
– Installation Documentation – Relief piping isometrics , inlet, and outlet pressure drop calculations including PRY stability (engineering analysis), and piping stress and reaction force analysis.
This condition exposed employees to struck-by hazards.
Notice I Item 2
Type of Violation: Serious
29 CFR 1910.119(e)(2)(iv): Hazard and Operability Study (HAZOP);
(a) On June 8, 2021, and at times prior, the Bureau of Land Management’s Hazard and Operability Study did not include information in the severity, likelihood, or risk columns. This condition exposes employees to struck-by hazards.
Notice I Item 3
Type of Violation: Serious
29 CFR 1910.119(e)(3)(v): Facility siting;
(a) On June 8, 2021, and at times prior, the Bureau of Land Management did not adequately address the facility siting of the control room in the Process Hazard Analysis. This condition exposed employees to struck-by hazards.
Notice I Item 4
Type of Violation: Serious
29 CFR 1910.119(e)(3)(vi): Human factors;
(a) On June 8, 2021, and at times prior, the Bureau of Land Management’s Process Hazard Analysis did not address human factors related to hiring and retaining experienced personnel. This condition exposed employees to struck-by hazards.
Notice I Item 5
Type of Violation: Serious
29 CFR 1910.119(f)(1)(ii)(A): The employer did not develop and implement written operating procedures that addressed the consequences of deviations from the operating limits in the covered process;
a) On June 8, 2021, and at times prior, the Bureau of Land Management’s operating procedures did not include the consequences of deviations from the operating limits including but not limited to:
Phase I Procedures:
- DGA System start-up and shutdown TSA system start-up and shutdown
- KI 00 feed gas compressor start-up and shutdown Cold plant restart
- G200 A/B Pump start-up and shutdown
Phase II Procedures:
- Hazards of the Helium Enrichment Unit, Lower pressure operation,
- Alarm response Purging procedures Locked valve checklist
Phase III Procedures :
- Emergency plant shutdown Routine plant shutdown
- Nitrogen system startup and shutdown Waukesha compressor startup and shutdown
This condition exposed employees to struck-by hazards.
Notice I Item 6
Type of Violation: Serious
29 CFR 1910.119(g)(1)(i): The employer did not train each employee in the operating procedures as specified in paragraph (f) of 29 CFR 1910.119.
(a) On June 8, 2021, and at times prior, the Bureau of Land Management did not train each employee in the operating procedures including but not limited to:
Phase I Procedures
- DGA System start-up and shutdown TSA system start-up and shutdown
- KI 00 feed gas compressor start-up and shutdown Cold plant restart
- G200 A/B Pump start-up and shutdown
Phase II Procedures:
- Hazards of the Helium Enrichment Unit, Lower pressure operation,
- Alarm response Locked valve checklist
Phase III Procedures:
- Emergency plant shutdown Routine plant shutdown
This condition exposed employees to struck-by hazards.
Notice I Item 7
Type of Violation: Serious
29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the ongoing integrity of process equipment.
(a) On June 8, 2021, and at times prior, the Bureau of Land Management did not establish written procedures to maintain the ongoing integrity of the process equipment including for all pressure vessels, relief and vent systems, emergency shutdown systems, and controls. This condition exposed employees to struck-by hazards.
Notice I Item 8
Type of Violation: Serious
29 CFR 1910.119(j)(4)(iv): The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.
(a) On June 8, 2021, and at times prior, the Bureau of Land Management did not document each inspection and test that was performed on Piping systems, Emergency shutdown systems, and controls. This condition exposed employees to struck-by hazards.
Notice I Item 9
Type of Violation: Serious
29 CFR 1910.119(m)(1): The employer shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace.
(a) On June 8, 2021, and at times prior, the Bureau of Land Management failed to investigate each incident that resulted in, or could reasonably have resulted in a catastrophic release of HHC in the workplace. This condition exposed employees to struck-by hazards.
Notice I Item 10
Type of Violation: Serious
29 CFR 1910.119(o)(1): The employer did not verify that the procedures and practices developed under the standard were being followed:
(a) On June 8, 2021, and at times prior, the Bureau of Land Management did not conduct compliance audits to verify that the procedures and practices under the process safety management were adequate and being followed.
Notice I Item 11
Type of Violation: Serious
29 CFR 1910.147(d)(3): All energy isolating devices that were needed to control the energy to the machine or equipment were not physically located and operated in such a manner as to isolate the machine or equipment from the energy source(s):
(a) On July 7, 2021, the Bureau of Land Management failed to ensure that all energy isolating devices that were needed to control the energy on the K610 compressor piping were physically located and operated in such a manner as to isolate the equipment from the energy source. This condition exposed employees to struck-by hazards.
Notice I Item 12
Type of Violation: Serious
29 CFR 1960.26(b)(5): The Agency official did not promptly contact the Designated Agency Safety and Health Official and other responsible agency officials when the official in charge of the workplace needed assistance to undertake full abatement:
(a) On or about June 8, 2021, the Bureau of Land Management failed to address deficiencies in assuring the mechanical integrity of the unit’s process equipment and the control of hazardous energy during service and maintenance of machinery and equipment identified through the course of the agency’s inspection program allowing these hazards to persist unabated exposing employees responsible for the operation and maintenance of the unit to potentially serious harm or death.
Notice 2 Item 1
Type of Violation: Willful – Serious
29 CFR 1910.1190)(4)(i): The employer did not perform inspection and tests on process equipment:
(a) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 4″x6″ relief valve PSV-200 (SIN 1101-1705-084474) with a set pressure of 225 psig
(b) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 4″x6″ relief valve PSV-300 (SIN 1 IO1-1806-143074) with a set pressure of 325 psig
(c) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 3″x4″ relief valve PSV-7123 with a set pressure of275 psig
(d) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 0.75xl relief valve PSV-7137 with a set pressure of275 psig
(e) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 4″x6″ relief valve PSV-7124A (SIN 458835-3-VI 0-T2) with a set pressure of 250 psig
(f) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 4″x6″ relief valve PSV-71248 (SIN 458835-3-V10-T2) with a set pressure of260 psig.
This condition exposed employees to struck-by hazards.
Notice 2 Item 2
Type of Violation: Willful – Serious
29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:
(a) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the critical Shutdown Valve NV-41 06
(b) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the critical Level Controller LIC-4111 A
(c) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the critical Level Switch High High LSHH-4111 B
(d) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the critical Pressure Switch Low Low PSLL-4153
(e) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the critical Temperature Switch Low Low TSLL-4156
(f) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the critical Temperature Switch High High TSHH-4161
(g) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the critical Pressure Differential Switch Low Low PDSLL-4163
(h) On June 8, 2021, and at times prior, the employer did not pe1form inspection and tests on the critical Pressure Switch High High PSHH-4146
(I) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the critical High Level Switch LSHH-7131
U) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the critical Accuload Emergency shutdown UA-7136
This condition exposed employees to struck-by hazards.
Notice 2 Item 3
Type of Violation: Willful – Serious
29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:
(a) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the S-100 Suction bottle (SIN 2200-1) pressure vessel.
(b) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the B-100 Suction bottle (SIN 2200-2) pressure vessel
(c) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the B-100 Discharge Bottle (SIN 2200-3) pressure vessel
(d) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the E-447A Gas/Gas Exchanger (SIN C23004966-1) pressure vessel
(e) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the E-447B Gas/Gas Exchanger (SIN C23004966-2) pressure vessel
(f) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the E-445 Process Gas Chiller (SIN 0230496A-l) pressure vessel
(g) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the S-200 Stage 2 Suction scrubber (SIN 2200-4) pressure vessel
(h) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the B-200 Suction bottle (SIN 2200-5) pressure vessel
(I) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the E-445 Surge Drum (SIN 023049613-1) pressure vessel
(j) On June 8, 2021, and at times prior, the employer did not pe1form inspection and tests on the C-445 Primary Gas Separator (SIN 22703-405) pressure vessel
(k) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the C-446 Secondary Gas Separator (SIN 22703-406) pressure vessel
(l) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the C-442 Chiller Receiver (SIN 22703-404) pressure vessel
(m) On June 8, 2021 , and at times prior, the employer did not perform inspection and tests on the C-443 Bulk Oil Separator (SIN 0230508A-1) pressure vessel
This condition exposed employees to struck-by hazards.
Notice 2 Item 4
Type of Violation: Willful – Serious
29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:
On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 250 psig NG L storage tank T-710. This condition exposed employees to struck-by hazards.
Notice 2 Item 5
Type of Violation: Willful – Serious
29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:
(a) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 12″ – 300 PSIG carbon steel process piping from the 1st Stage Discharge- S-200 to K-200
(b) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 1.5″ – 300 PSIG residue liquid carbon steel process piping from separator C-445 to exchanger E-448B
(c) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 1.5″ – 300 PSIG residue liquid carbon steel process piping from exchanger E448A to separator C-446
(d) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 1.5″ – 300 PSIG Residue Liquid/NGL carbon steel process piping from separator C-446 to G-445A/B
(e) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 1.5″ – 300 PSIG Residue Liquid carbon steel process piping G-445A/B to Chiller 8/L
(f) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 1″ – 300 PSIG NGL carbon steel process piping from separator C446 to tank T-710
(g) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 4″ – 300 PSIG NGL carbon steel process piping from tank T-710 to pump G-710
(h) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 3″ – 300 PSIG NGL carbon steel process piping from pump G-710 to the truck loading nozzle
(i) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 4″ – 300 PSIG NGL carbon steel process piping from pump G-710 PSV to tank T-710
(j) On June 8, 2021, and at times prior, the employer did not perform inspection and tests on the 2″ – 300 PSIG vapor return carbon steel process piping from truck loading to tank T-710
This condition exposed employees to struck-by hazards.
Notice 2 Item 6
Type of Violation: Willful – Serious
29 CFR 1910.147(c)(7)(i): The employer did not provide adequate training to ensure that the purpose and function of the energy control program were understood by employees:
(a) On June 8, 2021, and at times prior, the employer did not train operators on the facility’s energy control program. This condition exposed employees to struck-by hazards.
Notice 3 Item 1
Type of Violation: Other-than-Serious
29 CFR 1960.25(c): The Agency did not inspect annually, all areas in each workplace, including office operations:
(a) On June 8 and at times prior, the Bureau of Land Management failed to inspect annually, all areas in each workplace, including office operations to identify safety and health hazards, routinely exposing employees to potential chemical and physical hazards associated with the operation of the crude helium enrichment plant.
Notice 3 Item 2
Type of Violation: Other-than-Serious
29 CFR 1960.26(c)(3): The Agency’s official in charge of the workplace did not immediately post notice of an unsafe or unhealthful working condition, or copy thereof, unedited, at or near each place where the unsafe or unhealthful working condition existed:
(a) On June 8, 2021, and at times prior, the Bureau of Land Management failed to post notices of violations identified in the audits at or near each place of an unsafe or unhealthful working condition. Audits identified hazardous conditions in that pressure vessels were not adequately tested and maintenance records were not adequately maintained, yet these findings were not posted in the facility until the hazard was abated.
Notice 3 Item 3
Type of Violation: Other-than-Serious
29 CFR 1960.72: The Bureau of Land Management failed to submit to the Secretary by May 1 of each year the information included on its previous calendar year’s occupational injury and illness recordkeeping forms.
(a) On June 8, 2021, and at times prior, the Bureau of Land Management failed to submit to the Secretary by May 1 of each year the information included on its previous calendar year’s occupational injury and illness recordkeeping forms. The entire Department of Interior failed to submit any of its required injury and illness data for the calendar year 2020, including for this BLM facility.
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