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Violation Detail
Standard Cited: 5A0001 OSH Act General Duty Paragraph
This violation item has been deleted.
Inspection Nr: 313498255
Citation: 01001
Citation Type: Serious
Abatement Status: X
Initial Penalty: $6,300.00
Current Penalty: $6,300.00
Issuance Date: 01/13/2011
Nr Instances: 1
Nr Exposed: 6
Abatement Date: 02/01/2011
Gravity: 10
Report ID: 0627500
Contest Date: 01/28/2011
Final Order: 09/30/2011
Related Event Code (REC):
Emphasis:
| Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
|---|---|---|---|---|---|---|
| Penalty | F: Formal Settlement | 09/30/2011 | $6,300.00 | 02/01/2011 | Serious | |
| Penalty | Z: Issued | 01/13/2011 | $6,300.00 | 02/01/2011 | Serious |
Text For Citation: 01 Item/Group: 001 Hazard: UNCLASS
Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or were likely to cause death or serious physical harm to employees in that employees were exposed to the condition(s) listed below: On or about June 18, 2010, employees were exposed to flammable vapors due to a hazardous release of flammable materials from the Vapor Recovery Unit, while switching vapor recovery unit pumps. The Vapor Recovery Unit system interlock was reset and this caused an increase in vapor pressure and caused the pressure relief valve from the vapor line system to release flammable vapors into the atmosphere: 1) The employer did not follow their established Switch Vacuum Pump at Vapor Recovery Unit Procedure (MKT-NP-4822), while switching vapor recovery unit pumps. 2) The employer did not identify the Vapor Recovery Unit interlock system in their Switch Vacuum Pump at Vapor Recovery Unit Procedure (MKT-NP-4822). The procedure does not include any instructions for the interlock system and what is expected of employees to reset or not reset the interlock system. 3) The employer did not train all operators on the Switch Vacuum Pump at Vapor Recovery Unit Procedure (MKT-NP-4822). 4) The employer did not evaluate mechanical and system design features in the Vapor Recovery Unit, that are likely to produce significant human error. 5) The employer did not update the Vapor Recovery Unit - Piping & Instrument Diagram (PD-53-45304-001), when mechanical changes were performed in the Vapor Recovery Unit. AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE METHOD TO CORRECT THIS HAZARD IS: 1) Ensure that operators and lead operators follow the established procedure Switch Vacuum Pump at Vapor Recovery Unit Procedure (MKT-NP-4822) when switching Vapor Recovery Unit pumps. 2) Include written procedures for the Vapor Recovery Unit interlock system in the Switch Vacuum Pump at Vapor Recovery Unit Procedure (MKT-NP-4822), for employees to follow when switching Vapor Recovery Unit pumps. 3) Ensure that all employees are properly and effectively trained on the Switch Vacuum Pump at Vapor Recovery Unit Procedure (MKT-NP-4822). 4) Conduct an evaluation of possible significant human errors that may occur when operators are switching pumps in the Vapor Recovery Unit and implement written procedures, training and system design to prevent human error from creating a possible catastrophic event. 5) Ensure that existing Piping & Instrument Diagrams are updated on a timely manner to ensure that P&ID's reflect the most current mechanical and system changes.