A poultry processing plant has been cited with 11 safety violations and proposed penalties totaling $170,000. The inspection, which began in January, was initiated under the agency’s PSM Covered Chemical Facilities NEP. A willful violation, with a $70,000 fine, was cited for failing to document that the emergency shutdown system for the engine room was designed to ensure that the mechanical ventilation system was activated by an ammonia leak. The nine serious violations, with a $61,500 fine, were cited for PSM deficiencies of the relief valves and failing to provide process hazard analysis, operating procedures, testing procedures and management of change procedures. The repeat violation, with a fine of $38,500, was cited for failing to ensure the adequate frequency of self-inspections and tests of ammonia refrigeration equipment and vessels. A similar violation was cited in 2011. Here is a breakdown of the citations:
Process Safety Information
Citation 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 1910.119(d)(3)(ii): The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices.
The employer does not ensure it documented that equipment in the process complied with recognized and generally accepted good engineering practices (RAGAGEP).
Instance A. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure that relief valves are replaced every five years in accordance with RAGAGEP such as HAR Bulletin 110. The following relief valves have been in place for greater than five years:
a. V-20 (B-1 PSV 01/02)
b. V-22 (B-2 PSV 01/02
c. HX-29 (PSV 01/02)
d. HS 1 Oil Separator
e. LS 1 Oil Separator
f. ACCI
Instance B. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure that relief valves are properly sized for relieving capacity, set pressure, and discharged to outdoor locations in accordance with RAGAGEP such as ANSI/HAR 2-2008. The following relief valves currently do not comply with ANSI/HAR 2-2008:
a. HS 1 Oil Separator
b. LSI Oil Separator
c. ACC 1 Oil Separator
d. ACC 1 Vessel
These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Process Hazards Analysis
Citation 1 Item 2
Type of Violation: Serious;$7,000
29 CFR 1910.119(e)(3)(iii): The process hazard analysis did not address the engineering and administrative controls applicable to the hazards and their interrelationship, such as, appropriate detection methodologies to provide early warning of releases.
The employer does not ensure that the process hazard analysis addressed the engineering and administrative controls applicable to the hazards and their interrelationship including appropriate methodologies to provide early warning of releases.
The employer failed to ensure that the 2009 process hazard analysis addressed engineering controls such as but not limited to ammonia detectors in the North and South Engine rooms to provide early warning of releases. This condition exposed employees to hazards of fire and explosion or inhalation of ammoma vapors.
Citation 1 Item 3
Type of Violation: Serious; $5,500
29 CPR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting.
The employer does not ensure the process hazard analysis addressed facility siting. The employer failed to ensure that the 2009 process hazard analysis addressed facility siting such as but not limited to the use of the south engine room as a maintenance shop/work area for production maintenance personnel. This condition exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Citation 1 Item 4
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(5): The employer did not establish a system to assure that the process hazard analysis team’s recommendations are resolved in a timely manner and that the resolution is documented.
The employers system does not promptly address the PHA team’s findings and recommendations; assuring that the resolution of the recommendations is completed in a timely manner, as soon as possible, and the resolutions are documented.
Instance A: employer did not ensure that the recommendations, Items 1-23, contained in the 2009 Process Hazard Analysis were resolved in a timely manner, completed as soon as possible, and the resolution for the recommendations were properly documented. These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Instance B: employer did not ensure that recommendations, Items 24, 27, 29, 30; contained in the 2009 Process Hazard Analysis were resolved in a timely manner, completed as soon as possible, or the resolutions were properly documented. These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Operating Procedures
Citation 1 Item 5
Type of Violation: Serious; $7,000
29 CFR 1910.119(f)(3): The employer did not certify annually that the operating procedures are current and accurate.
The employer does not ensure operating procedures are current and accurate and are certified annually.
Instance A: The violation occurred on or about January 22, 2013 and times prior to where the following operating procedures were not reviewed as often as necessary to assure that they reflect current operating procedures in the North and South engine rooms such as but not limited to:
a. N eek Chiller Exchanger (HX3)
b. Air Unit AU28
c. South System EC-6, EC-12, HPR-4, and Pilot Receiver.
Instance B: The violation occurred on or about January 22, 2013 and times prior thereto, where the following operating procedures were not certified annually such as but not limited to:
a. High Stage Compressor C-1
b. Ammonia Unloading North System
c. High Temperature Re-circulator Pump RP-4
d. Low Stage Compressor B-1
These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Training
Citation 1 Item 6a
Type of Violation: Serious; $7,000
29 CFR 1910.119(g)(1)(i): Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks.
The employer does not ensure to provide employee training on the operating procedures for the ammonia refrigeration system. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure employees were trained on operating procedures for the ammonia refrigeration system. The operating procedures include, but are not limited to:
a. High Stage Compressor C-1
b. Ammonia Unloading North System
c. High temperature re-circulator Pump RP-4
d. Low stage compressor B-1.
These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Citation 1 Item 6b
Type of Violation: Serious; Grouped
29 CFR 1910.119(g)(3): The employer did not prepare a record, which contained the identity of the employee, and the date of training was completed.
The employer does not ensure that a record is prepared to identify the employee and that date training was completed. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed ensure a record was prepared identifying the name of the employee and date in which the employee was trained on the operation of the ammonia refrigeration system and its operating procedures. The operating procedures include but limited to:
a. High Stage Compressor C-1
b. Ammonia Unloading North System
c. High Temperature Re-circulator Pump RP-4
d. Low Stage Compressor B-1.
These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Mechanical Integrity
Citation 1 Item 7
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going mechanical integrity of process equipment.
The employer does not ensure written procedures are established and implemented to maintain the ongoing mechanical integrity of process equipment.
Instance A. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure detailed written procedures were established and implemented for testing of safety cutouts. Identified cutouts include but not limited to:
a. Compressor Discharge High/Low Pressure
b. Compressor High/Low Oil Pressure Differential
c. Compressor High Discharge Temperature
d. High/Low Vessel Levels.
Instance B. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure detailed written procedures were established and implemented for determining locations for conducting thickness measurements of piping and vessels. These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Instance C. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure detailed written procedures were established and implemented for the visual external inspections of insulated piping and vessels. These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Instance D. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure detailed written procedures were established and implemented for the inspection of relief valves and relief vent system(s). These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Citation 1 Item 8a
Type of Violation: Serious; $7,000
29 CPR 1910.119(j)(4)(ii): Inspections and testing procedures performed on process equipment to maintain its mechanical integrity did not follow recognized and generally accepted good engineering practices.
The employer does not ensure inspections and tests performed on process equipment to maintain its ongoing mechanical integrity followed recognized and generally accepted good engineering practices (RAGAGEP). The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure inspection and tests of ammonia refrigeration equipment cutouts followed RAGAGEP such as IIAR Bulletin 110. Identified cutouts include but are not limited to:
a. Compressor Discharge High/Low Pressure
b. Compressor High/Low Oil Pressure Differential
c. Compressor High Discharge Temperature,
d. High/Low Vessel Levels.
These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Citation 1 Item 8b
Type of Violation: Serious; Grouped
29 CPR 1910.119(j)(4)(iv): The documentation of the inspection or test that been performed on process equipment to maintain its mechanical integrity did not identify the date of 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, and the results of the inspection or test.
The employer does not ensure inspections and tests performed on process equipment are documented with the date, serial number or equipment identifier, a description, and the result(s) of the inspection or test. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure inspections and tests performed on ammonia refrigeration system cutouts were documented with the date, serial number or equipment identifier, a description of the test/inspection performed, and the result(s) of the inspection or test. Identified cutouts include but are not limited to:
a. Compressor Discharge High/Low Pressure
b. Compressor High/Low Oil Pressure Differential
c. Compressor High Discharge Temperature
d. High/Low Vessel Levels.
These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Citation 1 Item 9
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.
The employer does not ensure written procedures are established and implemented to manage changes to the equipment, procedures, and changes to the facilities in the covered process. The violation occurred in the South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure that written management of change procedures were established and implemented for removing equipment from ammonia refrigeration service. Identified out of service equipment still in place include but not limited to:
a. Compressor RC-13
b. Compressor RC-17
c. Oil Separator OS-1
d. Oil Separator OS-3
e. Oil Separator OS-10
f. Oil Separator OS-13.
These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Process Safety Information
Citation 2 Item 1a
Type of Violation: Willful; $70,000
29 CFR 1910.119(d)(3)(ii): The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices.
The employer does not ensure it documented that equipment in the process complied with recognized and generally accepted good engineering practices.
Instance A. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure that an emergency shutdown system was installed for the North and South engine rooms in accordance with recognized and generally accepted good engineering principles such as ANSI/IIAR 2, IIAR 111, and ANSI/ASHRAE 15. These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Instance B. The violation occurred in the South engine room where the employer failed to ensure that the emergency mechanical ventilation system in the South engine room is either activated by an ammonia detector or run continuously and has a supervisory alarm to detect failures or shutdown of the system; in accordance with RAGAGEP such as ANSI/ASHRAE 15. These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Mechanical Integrity
Citation 2 Item 1b
Type of Violation: Willful; Grouped
29 CPR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (as defined by process information in 29 CPR 1910.119(d) before further use or in a safe and timely manner.
The employer does not ensure deficiencies are corrected in equipment that is outside acceptable limits before further use or in a safe and timely manner.
Instance A. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure that an emergency shutdown system was installed for the North and South engine rooms. These conditions exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Instance B. The violation occurred in the South engine room where the employer failed to ensure that the emergency mechanical ventilation system in the South engine room is either activated by an ammonia detector or run continuously and has a supervisory alarm to detect failures or shutdown of the system. This condition exposed employees to fire, explosion hazards and/or inhalation hazards.
Instance C: The violation occurred in the South engine room on or about January 22, 2013 and at times prior thereto where the employer failed to ensure the ammonia detector that was used to shut down the boiler(s) in the event of a release was repaired and returned to service in a timely manner. This condition exposed employees to fire, explosion hazards and/or inhalation hazards.
Citation 3 Item 1
Type of Violation: Repeat; $38,500
29 CPR 1910.1190(j)(4)(iii): The frequency of inspections and tests of process equipment to maintain its mechanical integrity, was not consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.
The employer does not ensure the frequency of tests and inspections are consistent with recognized and generally accepted good engineering practices (RAGAGEP) or the manufacturers’ recommendations.
Instance A. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure the frequency of inspection and tests of ammonia refrigeration equipment cutouts were inspected and tested annually in accordance with RAGAGEP such as IIAR Bulletin 110. Identified cutouts include but not limited to:
a. Compressor Discharge High/Low Pressure
b. Compressor High/Low Oil Pressure Differential
c. Compressor High Discharge Temperature
d. High/Low Vessel Levels.
Instance B. The violation occurred in the North and South engine rooms on or about January 22, 2013 and at times prior thereto where the employer failed to ensure the external visual inspection of vessels and piping were conducted annually in accordance with RAGAGEP such as IIAR Bulletin 110. Identified vessels include but not limited to:
a. Temperature Accumulator (V-2)
b. High Temperature Accumulator (V-1)
c. SC2
d. North High Pressure Receiver
e. South High Pressure Receiver
f. North Reserve Vessel
g. Exchanger HX-1
h. Intercooler V-3
I. Exchanger HX-8
J. V-11 Surge Drum
Employer WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD OR ITS EQUIVALENT STANDARD, 29 CFR 1910.119(G)(4)(iii), WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER #313880775, CITATION NUMBER #1, ITEM 1, ISSUED ON APRIL 8, 2011, WITH RESPECT TO A WORKPLACE LOCATED AT 19740 US 90 WEST, LIVE OAK FL 32064. THIS FILE BECAME A FINAL ORDER ON MAY 4, 2011.
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