The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 2 Item 5 a
Type of Violation: Serious; $16,131
29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process.
On or about January 4, 2024, the employer failed to address the hazards of the process in the process hazard analysis (PHA) for a release going undetected in that employees operating the ammonia refrigeration process were exposed to undetected ammonia releases without the employer having adequate controls which could result in employees being exposed to a process with uncontrolled hazards which could result in contact with fire and explosion from an uncontrolled release of anhydrous ammonia and oil from the ammonia refrigeration equipment in the machine rooms.
Citation 2 Item 5 b
Type of Violation: Serious
29 CFR 1910.119(e)(5): The employer did not assure that PHA recommendations were resolved in a timely manner:
On or about January 4, 2024, the employer did not document resolutions to recommendations identified in the process hazard analysis (PHA) to assure the items were resolved in a timely manner and that the resolution was documented, develop a written schedule to complete actions as soon as possible, complete the actions as soon as possible, and communicate actions to operating/maintenance employees. Employees were exposed to hazards associated with anhydrous ammonia refrigeration systems such as, but not limited to, corrosive burns, eye damage, fire, and explosion.
Citation 2 Item 6
Type of Violation: Serious; $16,131
29 CFR 1910.119(g)(1)(i): The employer did not train each employee before being involved in operating a newly assigned process in the operating procedures as specified in paragraph (f) of this section:
On or about January 4, 2024, the employer did not ensure employees involved in operating a PSM covered process were provided with training in an overview of the process, operating procedures, specific safety and health hazards, emergency operations, and safe work practices. Employees performing walkaround inspections during normal operations, restarting compressors, and adjusting temperatures in the refrigeration bays were exposed to hazards associated with anhydrous ammonia refrigeration systems such as, but not limited to, corrosive burns, eye damage, fire, and explosion.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 2 Item 7a
Type of Violation: Serious; $16,131
29 CFR 1910.119(j)(2): The employer did not implement written procedures to maintain the on-going integrity of process equipment:
Instance A
On or about January 4, 2024, the employer did not establish written procedures to maintain the on-going integrity of process equipment. Procedures were not developed for the inspection and maintenance of ammonia gas sensors. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion in the ammonia sensors in the east engine room were nonfunctioning.
Instance B
On or about January 4, 2024, the employer did not establish written procedures to maintain the on-going integrity of process equipment. Procedures were not developed for the inspection and maintenance of dual safety pressure relief valves installed on the oil separators of the screw compressors. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion, in that the pressure relief valves of compressors in the west and east engine room were beyond their tagged replace by dates.
Instance C
On or about January 4, 2024, the employer did not establish written procedures to maintain the on-going integrity of process equipment. Procedures were not developed for the inspection and maintenance emergency shutdown buttons. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion, in that the emergency shutdown buttons on the east engine room were not operational.
Instance D
On or about January 4, 2024, the employer did not establish written procedures to maintain the on-going integrity of process equipment. Procedures were not developed for the inspection and maintenance of pressure vessels and piping associated with the ammonia refrigeration systems. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion, in that equipment such as but not limited to, the high stage accumulator located in the west engine room and the associated piping showed evidence of deterioration of insulation and surface pitting.
Citation 2 Item 7b
Type of Violation: Serious
29 CFR 1910.119(j)(4)(i): The employer did not perform inspections and tests on process equipment:
Instance A
On or about January 4, 2024, the employer did not perform inspections and testing on ammonia gas sensors in the east engine room. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion in the ammonia sensors in the east engine room were nonfunctioning.
Instance B
On or about January 4, 2024, the employer did not perform inspections and testing for the dual safety pressure relief valves installed on the oil separators of the screw compressors. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion, in that the pressure relief valves of compressors in the west and east engine room were beyond their tagged replace by dates.
Instance C
On or about January 4, 2024, the employer did not perform inspections and testing for emergency shutdown buttons associated with the ventilation systems of the east and west engine rooms. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion, in that the emergency shutdown buttons on the east engine room were not operational.
Instance D
On or about January 4, 2024, the employer did not perform inspections and testing of pressure vessels and piping associated with the ammonia refrigeration systems. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion, in that equipment such as but not limited to, the high stage accumulator located in the west engine room and the associated piping showed evidence of deterioration of insulation and surface pitting.
Citation 2 Item 7c
Type of Violation: Serious
29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) in a safe and timely manner when necessary means where taken to assure safe operation:
Instance A
On or about January 4, 2024, the employer did not ensure that the emergency shut down controls for the east engine room were functional, limiting the ability for employees to control ventilation of the room in the event of a release. Employees were exposed to hazards associated with anhydrous ammonia refrigeration systems such as, but not limited to, corrosive burns, eye damage, fire, and explosion.
Instance B
On or about January 4, 2024, the employer did not ensure that ammonia detection sensors in the engine rooms were functional, limiting the ability for employees to be warned of an ammonia release. Employees were exposed to hazards associated with anhydrous ammonia refrigeration systems such as, but not limited to, corrosive burns, eye damage, fire, and explosion.
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