Violation Detail
Standard Cited: 410
Inspection Nr: 314521733
Citation: 01003B
Citation Type: Serious
Abatement Status: X
Initial Penalty:
Current Penalty:
Issuance Date: 05/19/2011
Nr Instances: 1
Nr Exposed: 200
Abatement Date: 10/10/2011
Gravity:
Report ID: 1054195
Contest Date: 06/09/2011
Final Order: 08/12/2011
Related Event Code (REC): C
Emphasis:
Substance: 0170
| Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
|---|---|---|---|---|---|---|
| Penalty | P: Petition to Mod Abatement | 08/12/2011 | 10/10/2011 | Serious | ||
| Penalty | L: State Settlement | 08/12/2011 | 06/19/2011 | Serious | ||
| Penalty | Z: Issued | 05/19/2011 | 06/19/2011 | Serious |
Text For Citation: 01 Item/Group: 003B Hazard: ELECTRIC
ORS 654.010: The employer did not furnish a place of employment which was safe and healthful for employees, did not furnish and use such devices and safeguards, and did not adopt and use such practices, means, methods, operations and processes as was reasonably necessary to render such employment and places of employment safe and healthful, and did not do every other thing reasonably necessary to protect the life, safety, and health of the employees: a) As of the date of the inspection, the employer failed to furnish reasonably necessary devices and safeguards or did not adopt and use such practices, means, methods, operations and processes as stipulated in industry standards such as, but not limited to, the American National Standards Institute/American Society of Heating, Refrigerating and Air Conditioning Engineers (ANSI/ASHRAE) and the International Institute of Ammonia Refrigeration (IIAR). As observed by one or more of the following in the 2008 anhydrous ammonia refrigeration system: i) The presence of the air compressor system (with pump intake) in the 2008 ammonia engine room permits the passage of escaping refrigerant to other parts of the building including, but not limited to, the welding shop. A feasible method to address this would be to remove the compressed air system from the anhydrous ammonia engine room. (See: ANSI/ASHRAE Standard 15 - 2001 Safety Systems for Refrigeration Systems, Section 8.11.2 - General Requirements; See IIAR bulletin 2-2008: Equipment, Design and Installation of Closed Circuit Ammonia Refrigerating System, Section 13.2.3.10 - Ventilation) ii) The condensers servicing the 2008 ammonia refrigeration system did not have safe access to provide for inspection, service and emergency shut down. The access ladder for the units did not reach the ground level, thus requiring employees to jump 5 feet to access first rung of the ladder. The condenser units did not have catwalks to provide safe access to all sides of the units; thus, employees had to use portable ladders or straddle I-beams to access portions of the units. A feasible method to address this would be to install work platforms or catwalks with compliant stairs or fixed ladders in all areas where inspection and maintenance are required. (See ANSI/ASHRAE Standard 15 - 2001 Safety Systems for Refrigeration Systems, Section 8.3 - Safe Access or section 9.12.1 & 9.12.2 - Service Provisions) iii) The electrical systems installed in the 2008 ammonia engine room did not comply with the requirements of Class 1 - Division 2 of the National Electrical Code for hazardous locations. A feasible method to address this would be to evaluate the current ventilation system and system safety interlocks to verify if the system qualifies for the listed exemptions to this requirement. (See ANSI/ASHRAE Standard 15 - 2001 Safety Systems for Refrigeration Systems, Section 8.12(g) - Machinery Room Special Requirements See IIAR Bulletin 2-2008: Equipment, Design and Installation of Closed Circuit Ammonia Refrigerating System, Section 13.2.1.2 - Ventilation) iv) The observance of numerous isolation valves, servicing equipment in the 2008 ammonia system without any identification information. A feasible method to address this would be to install identification tags on all isolation valves. (See ANSI/ASHRAE Standard 15 - 2001 Safety Systems for Refrigeration Systems, Section 9.12.6 - service provisions) v) Lack of signage indicating the name and address of the installer, the refrigerant number and the maximum intended refrigerant load, the lubricant identity and amount, and the field test pressure applied. A feasible method to address this would be to install a permanent sign with the above-listed elements in the engine room. (See ANSI/ASHRAE Standard 15 - 2001 Safety Systems for Refrigeration Systems, Section 11.2 - General Requirements; See IIAR Bulletin 112: Ammonia Machinery Room Design, Section 4.3(f) - Mechanical) vi) The lack of drain plugs/stop valves on oil drain ports in the 2008 ammonia engine room. A feasible method to address this would be to install drain plugs on all oil drain ports. (See ANSI/ASHRAE Standard 15 - 2001 Safety Systems for Refrigeration Systems, Section 11.6.1 - General Requirements) vii) The lack of a ventilation system design, for the 2008 ammonia refrigeration system, to ensure that the current system is capable of providing the required airflow as required by the ASHRAE Standard. A feasible method to address this would be to develop a ventilation system design plan and verify that the current system is capable of delivering the required air flow during normal and emergency operations. (See ANSI/ASHRAE Standard 15 - 2001 Safety Systems for Refrigeration Systems, Section 8.11.5 - Machinery Room General Requirements; See IIAR Bulletin 2-2008: Equipment, Design and Installation of Closed Circuit Ammonia Refrigerating Systems, Section 13.2.3.3 - Ventilation) viii) The lack of a pressure relief design, for the 2008 ammonia refrigeration system, to ensure that the safety relief valves currently installed in the system are properly sized to adequately protect the system. A feasible method to address this would be to develop a pressure relief design plan to verify that the currently installed pressure relief valves and associated discharged piping are properly sized to adequately protect the equipment or piping systems. (See ANSI/ASHRAE Standard 15 - 2001 Safety Systems for Refrigeration Systems, Section 9.7.5 Pressure Relief Protection; See IIAR Bulletin 2-2008: Equipment, Design and Installation of Closed Circuit Ammonia Refrigerating Systems, Section 11.2.7 and 11.2.9 - Pressure Vessel Protection) ix) The lack of a schematic drawing or panel giving directions for the operation of the system at a location that is convenient to the operators. The lack of written emergency shutdown procedures (including shutdown instructions, contact information for obtaining system services, and the contact information for all required notifications in the event of a reportable incident) posted outside of the engine room and immediately adjacent to each door. A feasible method to address this would be to develop the schematic drawing with the above-listed information and post it immediately adjacent to each engine room door. (See ANSI/ASHRAE Standard 15 - 2001 Safety Systems for Refrigeration Systems, Section 11.7 - Responsibility for Operation and Emergency Shutdown) x) The lack of adequate safeguarding for piping on the roof servicing the 2008 ammonia system. Currently, employees have to cross over roof piping to inspect and access other portions of the system. There is no pedestrian bridge or catwalk over the piping system. This leaves the piping system vulnerable to physical damage due to employees "walking" crawling on pipes. There were numerous sections of the pipe support system that were subject to ice migration between the pipe and the protective sleeve. There was evidence that the expansion of the ice has compressed the pipe insulation system. A feasible method to address this would be to install a compliant pedestrian crossing ramp over the piping systems and to protect the pipe supports from ice migration. (See ANSI/ASHRAE Standard 15 - 2001 Safety Systems for Refrigeration Systems, Section 11.1 - General Requirements)
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