Text For Citation: 01 Item/Group: 002 Hazard:

29 CFR 1910.119(d)(3)(i)(B): The employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. This process safety information shall include information pertaining to the equipment in the process including piping and instrument diagrams (P&ID's): At a facility located at N3620 County Road D, New London, WI 54961; the employer did complete a compilation of process safety information including information pertaining to the equipment in the process. The P&ID's were incomplete in the instances such as, but not limited to: a) At Vessel 2, the P&ID misrepresented the locations of the pipes for valves 291781 and 290858. The P&ID depicted two pipes, one for each of the aforementioned valves, teeing off the pipe below valve 290708. On the system, only one pipe teed off the pipe below valve 290708. Then the pipe teed again towards the pipes for valves 291781 and 290858. b) c) The relief vents for equipment including, but not limited to Vessel 4 and Vessel 5 were misrepresented on the P&IDs. All three vessels connected to the same vent system inside the building before a single pipe exiting the building and directed upwards to a relief stack above the roof of the building. The P&IDs for each of the vessels did not identify the shared relief system, did not indicate that the relief vents joined a relief pipe system and did not indicate where the pressure relief of the individual vessels terminated. d) On the system, multiple valves were not labeled or tagged, including but not limited to; at Vessel 4 valves 290166, 290127, 291519, 21520; at Vessel 5 valves 291337, 291521, 291522; at Compressor 29 valve 291227; and at the Pump Out vessel valve 290734. e) On the system, some labels or tags for valves were not visible due to ice buildup, including but not limited to; at Vessel 5 valve 290999. f) At Compressor 7, the P&ID misrepresented the location of piping and valves. The P&ID appeared to show the dual pressure relief-valve setup (291143, 291107, 291108) exiting the compressor's overhead oil separator or as a continuation of one of the other pipes behind the oil separator. On the system, the 3/4" piping for the dual pressure relief-valve setup teed off the 3" pipe just after valve 290099 and before the oil separator. g) At Compressor 29, the P&ID misrepresented piping and valves below the compressor adjacent to its oil pump. The P&ID represented a pipe exiting the compressor, flowing to valve 291185, then to a strainer and then to the oil pump. On the system, another pipe with check valve teed off the pipe between the strainer and the oil pump and then teed into the pipe exiting the oil pump. h) At Compressor 29, the P&ID misrepresented piping and valves. The pipe for valve 291227 was drawn teeing off the pipe before valve 290395. On the system, that tee occurred after valve 290395. i) j) At Shell and Tube Heat Exchanger R55, the P&ID misrepresented piping and valves. The P&ID represented the float switch, near valve 630299, in line with that pipe. On the system, the float switch was connected to the pipe for valve 630299 via a bypass pipe. k) P&IDs misrepresented the existence of some equipment, including but not limited to; at Compressor 29 a pressure indicator between the compressor and strainer 291219; and at Plate and Frame Heat Exchanger DR133 valve 630238 on the 2-1/2" return suction pipe. l) The P&IDs misrepresented the identification of pipes, including but not limited to Plate and Frame Heat Exchanger DR133; the HTRL and HTRS pipes were identified on the P&ID as MTRL and MTRS respectively. m) Portions of piping associated with anhydrous ammonia refrigeration system: Constant Pressure Receiver (Vessel 2), Medium Temperature Accumulator (Vessel 4), Low Temperature Accumulator (Vessel 5), Plate and Frame Heat Exchanger (DR133), Shell and Tube Heat Exchanger (R55). The employer failed to document compliance with employer's chosen RAGAGEP, IIAR Bulletin 114 (2014) - Identification of Ammonia Refrigeration Piping and System Components, Sections 4.1, 4.1.2, 4.1.3, and 4.1.5 when portions of piping used in the anhydrous ammonia refrigeration system were not labeled or identified with the physical state (e.g. liquid or vapor), pressure level (e.g. high or low) or direction arrow indicating direction of low. This hazardous condition exposed employees to the hazard of inhalation and burns from ammonia liquid and vapors.