Citation 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 1910.119(c)(2): The employer did not consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard:
The employer did not consult with Ammonia Refrigeration Mechanics and Power Plant Operators on the development of the elements of process safety management.
Citation 1 Item 2
Type of Violation: Serious; $7,000
29 CFR 1910.119(d)(3)(i)(B): Process safety information pertaining to the equipment in the process did not include the piping and instrument diagrams (P&ID7S):
The P&IDs for the ammonia refrigeration system were not accurate to the as built condition of the system, including but not limited to:
- Frick #1 compressor, 1 1/2″ LIOC line;
- Frick #1 compressor, 1/2″ PO line;
- Frick #1 compressor, pressure relief valve on shell and tube oil cooler;
- Frick #1 compressor, pressure relief valve on receiver;
- Frick #1 compressor, check valve on 8″ HSS line;
- Frick #1 compressor, thermal expansion valve on LIOC;
- Frick #1 compressor, solenoid valve on 1 1/2″ LIOC;
- Frick #I compressor, globe valve on 1 1/2″ LIOC;
- Frick #1 compressor, globe valve on 5″ HSD;
- Frick #1 compressor, check valve on 5″ HSD;
- Frick #2 compressor, 1 1/2″ LIOC line;
- Frick #2 compressor, 1/2″ PO line;
- Frick #2 compressor, pressure relief valve on shell and tube oil cooler;
- Frick #2 compressor, pressure relief valve on receiver;
- Frick #2 compressor, check valve on 8″ HSS line;
- Frick #2 compressor, thermal expansion valve on LIOC;
- Frick #2 compressor, solenoid valve on 1 1/2″ LIOC;
- Frick #2 compressor, globe valve on 1 1/2″ LIOC;
- Frick #2 compressor, globe valve on 5″ HSD;
- Frick #2 compressor, check valve on 5″ HSD;
- Vilter #4 compressor, no oil separator;
- Vilter #4 compressor, check valve on 4″ HSD;
- Vilter #4 compressor, 3 glove valves on oil discharge line;
- vilter #4 compressor, 4″ HSD line.
Citation 1 Item 3
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 did not document that the equipment in process complied with recognized and generally accepted good engineering practices.
- Nameplates or labels were not affixed to the Vilter compressors.
- No provisions were provided for irrigation facilities for eyes near the rooftop condensers.
- Compressors and boilers are located in vicinity of each other.
Citation 1 Item 4
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team’s findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignment are in the process and who may be affected by the recommendations or actions:
The employer did not establish a system to promptly address the process hazard analysis team’s findings and recommendations; assure that the recommendations were resolved in a timely manner and that the resolution was documented; document what actions were taken; complete actions as soon as possible; developed a written schedule of when these actions were to be completed; communicated the actions to operating, maintenance and other employees whose work assignment are in the process and who may be affected by the recommendations or actions.
- 2006 Process Hazard Analysis Recommendations
- 2008 Process Hazard Analysis Recommendations
Citation 1 Item 5
Type of Violation: Serious; $5,000
29 CFR 1910.119(h)(2)(i): The empioyer, when selecting a contractor, did not obtain and evaluate information regarding the contract employer’s safety performance and’programs:
The employer did not obtain and evaluate information regarding Modern Mechanical, LLC, safety performance.
Citation 1 Item 6
Type of Violation: Serious; $7,000
29 CFR 1910.119(i)(1): The employer did not perform a pre-startup safety review for modified facilities when the modification was significant enough to require a change in the process safety information:
The employer did not perform a pre-startup safety review for modifications to the ammonia refrigeration system facilities that require a change to the process safety information.
- Installation of new flooded air handlers in government cellars
- Recirculation package and evaporator installed in #74 Cellar .
- Installation of Condensers #5 and #6.
- Glycol Chiller – Loop A – The replacement of the control group, float sensor replaced, backflow preventer installed, PLC installed, oil pot installed, new pressure relief valve installed.
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 did not establish written procedures to maintain the on-going mechanical integrity of the ammonia refrigeration system.
- Inspection, maintaining and replacing relief devices.
- Inspection and testing on the Vilter compressor safety cutout switches.
Citation 1 Item 8
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(4)(i): Inspections and tests were not performed on process equipment to maintain its mechanical integrity:
Inspections and tests were not performed on the ammonia refrigeration process equipment to maintain its mechanical integrity.
- Vilter reciprocating compressor, high pressure safety cut outs
- Vilter reciprocating compressor, low suction safety cut out
- Inspection of external conditions including vent lines for pressure relief devices
- Testing of all solenoid valves
- Inspection of seats on normally open valves
- Inspection and cleaning of filters and strainers
- York vertical compressor inspection, per manufacturer’s service manual
Citation 1 Item 9
Type of Violation: Serious; $7,000
29 CFR 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 did not follow recognized and generally accepted good engineering practices when they pressure-tested the piping on the glycol chiller control unit piping with anhydrous ammonia gas.
Citation 1 Item 10
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (as defined by process information in 29 CFR 1910.1 19(d) before further use or in a safe and timely manner:
The employer did not correct deficiencies in the ammonia refrigeration equipment that were outside acceptable limits before further use or in a safe and timely manner.
- Rusted, pitted and corroded piping were in use in various areas including, but not limited to, Loop A Chiller, Loop B Chiller, Loop C Chiller, oil knock out pots for Vilter compressors, liquid ammonia line to the Keg Room.
- Pressure relief valves were not replaced at least every 5 years in various areas, including but not limited to, Beer Cooler 7 oil pot, Loop B Chiller oil pot, Loop C Chiller oil pot, Cooler 6 oil pot.
Citation 1 Item 11
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 did not conduct a management of change to manage changes to the ammonia refrigeration system.
- 8A Header removal
- Removal of Condenser #11
- Removal of two air handling units in Cellar 69
- Removal of Condenser #7, #8, #9 and #10
- Throughput changes for the system.
Citation 1 Item 12
Type of Violation: Serious; $7,000
29 CFR 1910.119(o)(1): The employer did not certify that they had evaluated compliance with the provisions of 29 CFR 1910.119 at least every three years to verify that the procedures and practices developed under this standard were adequate and are being followed:
The employer had not conducted a compliance audit on the ammonia refrigeration system.
Citation 1 Item 13
Type of Violation: Serious; $7,000
29 CFR 1910.120(q)(1): An emergency response plan was not developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations.
An emergency response plan was not implemented to handle anticipated emergencies involving the release of anhydrous ammonia.
Citation 1 Item 14
Type of Violation: Serious; $7,000
29 CFR 1910.120(q)(6)(iii)(A): Employees who participated or were expected to participate, as hazardous material technicians had not received at least 24 hours of training equal to the first responder operations level andlor had not been certified as having such training and/or in addition did not have competency to know how to implement the employer’s emergency response plan:
Employees who were expected to respond in an emergency response as hazardous material technicians had not received training nor could demonstrate competency.
Citation 1 Item 15
Type of Violation: Serious; $7,000
29 CFR 1910.120(q)(6)(v): The incident commander did not receive at least 24 hours of training equal to the first responder operations level and in addition have the competency specified in paragraphs (q)(6)(v)(A) through (q)(6)(v)(F):
Employees who were expected to respond in an emergency response as the incident commander had not received training nor could demonstrate competency.
Citation 1 Item 16
Type of Violation: Serious; $5,000
29 CFR 1910: 147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:
The employer did not develop machine specific lockout/tagout procedures for the ammonia refrigeration evaporators/cooling units.
Citation 2 Item 1
Type of Violation: Other; $0.00
29 CFR 1910.1001(j)(3)(v): At the entrance to mechanical rooms/areas in which employees reasonably can be expected to enter and which contain ACM and/or PACM, the building owner did not post signs which identify the material which is present, its location, and appropriate work practices which, if followed, will ensure that ACM and/or PACM will not be disturbed:
The employer did not post signage at the entrance of inechanical roomslareas which contain ACM andlor PACM.
- Glycol chiller Roondarea
- Compressor Roorntarea
Citation 2 Item 2
Type of Violation: Other; $0.00
29 CFR 1910.119(f)(3): The employer did not certify annually that the operating procedures are current and accurate:
The employer failed to certify on an annual basis that the Ammonia Refrigeration-Operating Procedures are current and accurate.
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