Text For Citation: 01 Item/Group: 007 Hazard:

29 CFR 1910.119(f)(1)(ii)(B): The employer did not develop and implement written operating procedures that provide clear instructions for steps required to correct or avoid deviation from the operating limits in the covered process: At the Wichita facility the current standard operating procedures for ammonia process equipment did not fully address the steps required to correct or avoid the listed deviations for safely conducting activities involved in each covered process. Employees engaged in repair, replace, inspection and maintenance activities of covered process equipment at the engine rooms, roof top, and the warehouse, freezer areas were exposed to the hazards of inhalation of toxic ammonia, asphyxiation, chemical burns, and fire. Identified Standard Operating Procedures (SOP) such as but not limited to the following showing some deficiencies: a. The Ammonia Pumps #2 (PP2) Standard Operating Procedure (SOP) was deficient in that the employer did not develop the steps required to correct deviation or to bring back to normal conditions for the Ammonia Pumps #2 (PP2). What are the steps to correct the consequences of deviation, to bring back to normal condition if the system goes into the situation of "More Than 50 psig High pump discharge pressure or Less Than 8 psig"? Properly PM the equipment would only avoid, prevent but not to correct the consequences of deviation as the high pump discharge pressure gets more or less than the designed pressure. There needs to be specific steps by steps that the operator needs to take to correct the deviations. b. The Compressor Vilter #2 (CP2) Standard Operating Procedure (SOP) was deficient in that the employer did not develop the steps required to correct or avoid deviation or to bring back to normal conditions for the Compressor Vilter #2 (CP2). Operating Procedure, Normal Operations, Step #7, "Observe the compressor for 5 minutes to make sure it is operating within the operating limits specified above. If the compressor is running outside the limits specified, refer to the Consequences of Deviation chart located on this SOP and the PSM manual." Where and what are the operating limits specified above? It was not specified in this SOP; such instructions or values are not found anywhere in the SOP. The Compressor Vilter #2 (CP2) Standard Operating Procedure (SOP) was deficient in that the employer did not develop the steps required to correct or avoid deviation or to bring back to normal conditions for the Compressor Vilter #2 (CP2). Operating Procedure, Manual and Emergency Start, Instructions / Required Steps. Step #7, "Observe the compressor for 5 minutes to make sure it is operating within the operating limits specified on the Operational Limits Chart, located on this SOP. If the compressor is running outside the limits specified, refer to the Consequences of Deviation chart located on this SOP and in the PSM manual." Where exactly is the Operational Limits Chart located at? It was not stated Operational Limits Chart in this SOP. c. The Compressor Vilter #2 (CP2) Standard Operating Procedure (SOP) was deficient in that the employer did not develop the steps required to correct or avoid deviation or to bring back to normal conditions for the Compressor Vilter #2 (CP2). What are the steps to correct the consequences of deviation, to bring back to normal condition if the system goes into the situation of "Higher or lower oil pressure, or High lubrication oil temperature, or High discharge temperature"? Properly complete daily engine room round and PMs would only put the operator on notice as they make their daily rounds, or to avoid the situation if they conduct PM but not to correct the consequences of deviation. d. The Condenser #2 (C2) Standard Operating Procedure (SOP) was deficient in that the employer did not develop the steps required to correct or avoid deviation or to bring back to normal conditions for the Condenser #2 (C2). What are the steps to correct the consequences of deviation, to bring back to normal condition if the system goes into the situation of "High discharge pressure, or Over pressurization"? Daily checks and properly PM equipment would only put the operator on notice as they make their daily rounds, or to avoid the situation if they conduct PM, but not to correct the consequences of deviation. The employer developed, implemented, and certified Standard Operation Procedures for the condensers covering initial start-up, normal operation, normal shut-down, and emergency shut down. However, the SOP did not address the specific steps by steps that the operator needs to take to correct the deviations, the consequences on uncontrolled/manual operation, and the appropriate measures to take to ensure that temperature and pressure will remain or return within safe limits. An overpressure/overtemperature could lead to the opening of emergency relief devices and the accidental release of ammonia in the air. There are no clear warnings on the consequences of operation under uncontrolled/manual mode, and the necessary response to control a disturbance. e. The Exhaust Fan #2 Standard Operating Procedure (SOP) was deficient in that the employer did not develop the steps required to correct or avoid deviation or to bring back to normal conditions for the Exhaust Fan #2. What are the steps to correct the consequences of deviation, to bring back to normal condition if the system goes into the situation of "Temperature gets high in Engine room NH3 Levels get to dangerous levels"? Properly PM and maintain equipment would only avoid the situation, but not to correct the consequences of deviation, if the temperature gets high in the engine room, then what would you do to bring it down to the normal condition?