Text For Citation: 01 Item/Group: 003 Hazard:

29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and did not document that deficiencies had been corrected: a) In the Facility, on or about January 18, 2023, the employer did not promptly document the corrections for deficiencies (items listed below) identified in their 2022 compliance audit, exposing employees to fire and toxic hazard posed by anhydrous ammonia in the event of an uncontrolled release. (a) Item 1: Update the maximum intended inventory to include new equipment (chiller and cooler evaporators) (b) Item 2: Update the materials of construction document to only include equipment currently in the process. (c) Item 3: Archive P&IDs of equipment no longer in service to prevent confusion. (d) Item 4: Update the Design Codes and Standard to replace Bulletin 109 with IIAR 6. Consider adding date of code (year) for others. (e) Item 5: Update the material and energy balance to include new equipment (chiller and evaporators). (f) Item 6: Update the Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) to replace B109 reference with IIAR 6. (g) Item 7: Ensure an operator level (hourly) employee is included on the PHA team for the 2024 PHA revalidation. (h) Item 8: Verify SOP Training refresher is completed for all operators. (i) Item 9: Complete a contractor qualification document for Woods Refrigeration on an annual basis. (j) Item 10: Verify all SOP refresher training is brought up to date. (k) Item 11: Verify annual inspection documents (B109 or IIAR 6) exist for last 5 years. If not, develop program to ensure annual inspections are performed and documented. This is an ongoing hazardous condition that can result in the release of ammonia causing serious injury to employees. (l) Item 12: Adopt IIAR 6 as a template for frequency of tests on covered equipment. This is an ongoing hazardous condition that can result in the release of ammonia causing serious injury to employees. (m) Item 13: Adopt IIAR 6 inspection templates to document tests and inspections. This is an ongoing hazardous condition that can result in the release of ammonia causing serious injury to employees. (n) Item 14: Verify hot work permit/program dictates a minimum 60-minute fire watch per NFPA 51B-2019. (o) Item 15: Ensure/verify procedures for inspection/testing/maintenance for respirators exist or are developed. (p) Item 16: Document annual coordinated training with local responders per the EAP (section M) 2. Document training on the EAP for all personnel in the plant. (q) Item 17: Engine Room 1 - Install NFPA (3-3-0) Placards and proper signage on machine room doors. 2. Install NFPA placard on door to receiver 1 (under condensers). (r) Item 18: Engine Room: Consider developing a plan to eliminate cut and capped equipment from the machine room to help with housekeeping measures. (s) Item 19: Roof Area (as applicable): Consider developing secondary egress from roof areas to prevent anyone from possibly being trapped on roof in an emergency. (t) Item 20: Roof Area (as applicable): Fill gap on condenser platform that could allow someone to fall. (u) Item 21: Roof Area (as applicable): 1. Install pipe labels on all uninsulated exterior piping around the chilled tanks. 2. Label surge drum and piping on vessel nearest compactors. 3. Install labels on ammonia vessels and piping on sweet water tanks. 4. Install labels on HSD piping and CD piping around both condensers. (v) Item 22: Roof Area (as applicable): Remove growth of weeds on roof under ammonia piping. (w) Item 23: Ammonia Alarms: 1. Install ammonia alarm audible and visual alarm at the Emergency Stop button box outside of the machine room. 2. Install manual ventilation control switch at the Emergency stop box. This is an ongoing hazardous condition that can result in the release of ammonia causing serious injury to employees. (x) Item 24: Remove the PRVs on the condenser (if appropriate). If they remain on condenser, the relief should be pointed straight up with a means to prevent water from entering