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On May 24,2012, EPA conducted a compliance inspection of Respondent's facility to determine compliance with the Risk Management Program ("RMP") regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Act. EPA found that the Respondent had violated regulations implementing Section 112(r) of the Act by failing to comply with the regulations. The Alleged Violations And Proposed Penalties are:
EPA RMP General Duty Clause citations @ diesel facility (Flammables; $30K - Piping Corrosion led to failure and VCE)
Respondent produces processes, handles, or stores, among other things, propane, hydrogen. isopentane, pentane, isobutane, and methane, which are all listed at 40 CFR Part 68 as extremely hazardous flammable chemicals. On August 3, 2014, there was a release of flammable substances from piping at the facility and a fire ensued. There were no injuries or fatalities; however, there was significant property damage to the facility's infrastructure. Respondent's investigation revealed that the fire resulted from a hole in process pipping at the facility allowing the release of flammable substances, which subsequently came in contact with an ignition source. The hole resulted from internal corrosion. Respondent failed to design and maintain a safe facility and did not take such necessary steps to prevent accidental releases by allowing internal corrosion on process piping that led to the release and subsequent fire. Respondent's failure constitutes a violation of the general duty clause in section 112(r)(1) of the CAA. Respondent is therefore subject to the assessment of penalties pursuant to sections 113(a)(3) and 113(d)(1)(B) of the CAA for violation of the general duty clause of section 112(r)(1) of the CAA. EPA and Respondent agree that an appropriate penalty to settle this matter is thirty thousand dollars ($30,000). CLICK HERE for the CAFO
A manufacturer of custom-sized resin balls used as flotation devices in the petroleum and fracking industries failed to protect its employees from the risk of death or serious injury from potential fires, explosions and other hazards by not providing and using mandatory safeguards. Officials from OSHA began inspecting the plant in October 2014, in response to complaints. Inspectors identified 48 violations of workplace safety and health standards, resulting in $105,200 in proposed fines. The ball manufacturing process requires the storage and use of up to 1,900 pounds of a flammable formaldehyde solution. In addition, inspectors found the presence of combustible resin dust; flammable liquids improperly stored and transferred; no audible fire alarm and fire-suppression system; and locked and obstructed exit routes.
You spend enough time working on Lockout/Tagout (LOTO) you are bound to come across some crazy situations. Luckily I have some world class clients who not only allow me to share my "interesting finds" but encourage me to share with all of you. This most recent find was at an OSHA VPP STAR site. We have been hired to do program specific audits each quarter, with an emphasis on energy control. This means even though I may be auditing flammable liquids this quarter, I am ALWAYS auditing LOTO and conducting "periodic inspections" (and yes I am an "authorized employee" within their LOTO program - I wrote it, wrote 99% of the machine specific control plans, and still do all the LOTO training at the facility). For the most part this facility KNOWS LOTO and LIVES IT DAILY; but we all have flaws - no one or no facility is perfect. Hence why we need LAYERS of PROTECTION in all our safety efforts. So today I was making my rounds talking with everyone and came across one of the safety committee members who was cleaning a piece of equipment. He knew I was there to do an audit, as he had participated in many audits with me before. He was PROUD and CONFIDENT of his ability to meet all LOTO requirements. But, the good will ended there. Here is the image of his electrical isolation - do you see anything wrong?
Fire Protection Deficiencies to incorporate into our inspection programs and internal audit programs
Anyone ever completed any type of safety audit and not ended up with at least one item related to your fire protection systems? Anyone? I know I never have and I am a fanatic about my fire protection systems. I was trained to treat them as “gold”. No one touches them - PERIOD! Yet in all my years I can not recall having completed a safety audit where someone found something wrong related to my fire protection systems. So here are a few items that we can use to raise awareness about code compliance for our fire protection systems.
OSHA has issued several PSM citations at a natural gas processing facility from an inspection that began in October 2014. This was an unannounced planned Chem NEP inspection. Of special note, these violations include issues with not having a Car Seal Program for valves within the relief path(s) of several relief devices. OSHA referenced ASME Section VIII, but did not specifically reference Appendix M-5 which contains the requirements for when a block valve is placed in the path of the relief system. PLEASE see my 2011 article, Car Seal Program and Relief Valves regarding how to comply with ASME Section VIII Appendix M- 5.
Most everyone has seen a bollard; they may have not realized what they were seeing at the time, but most have seen one. But this group of people who have seen one grows much smaller when we begin to ask “what makes a bollard a safety device?” A couple of years ago I shared an engineering standard for bollards and vehicle protection. That page has been viewed more than 200,000 times since 2012, so there must be some level of interest in these safety devices. I lost count of the number of e-mails I received asking if the post was a “joke”, as who in their right mind would have an engineering design for a post?!?! Well a well designed, constructed, chemical process that utilizes mobile equipment within their process battery limits… that's who! Just last year we issued several audit findings for either the lack of or improper design of bollards protecting bulk tanks and other "critical" process equipment. These were PSM audits… so what RAGAGEP did we reference?