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Violation Detail
Standard Cited: 19100119 D03 I B Process safety management of highly hazardous chemicals.
Inspection Nr: 1498785.015
Citation: 01008
Citation Type: Serious
Abatement Status: Abatement Completed
Initial Penalty: $13,516.00
Current Penalty: $7,433.80
Issuance Date: 04/06/2021
Nr Instances: 1
Nr Exposed: 115
Abatement Date: 09/21/2021
Gravity: 10
Report ID: 0729700
Contest Date:
Final Order: 04/29/2021
Related Event Code (REC):
Emphasis:
| Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
|---|---|---|---|---|---|---|
| Penalty | P: Petition to Mod Abatement | 06/18/2021 | $7,433.80 | 09/21/2021 | Serious | |
| Penalty | I: Informal Settlement | 04/29/2021 | $7,433.80 | 09/21/2021 | Serious | |
| Penalty | Z: Issued | 04/06/2021 | $13,516.00 | 05/21/2021 | Serious |
Text For Citation: 01 Item/Group: 008 Hazard:
29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process. On or about October 14, 2020, the employer failed to develop accurate piping and instrument diagrams (P&IDs) and did not represent the equipment in the aerosol filling process. The P&IDs were mislabeled in that tag numbers of equipment did not match the P&ID legends for the equipment in the tank farm, the gashouse, and the manifold system the following instances: a ) The equipment identified in the tank farm P&ID and legend as numbers 4b, 11, 16, 25, 41, and 42 are not tagged. The P&ID and the legend use a tagging system with numbers to identify the equipment. b) A gauge and a valve are tagged with the same number (29) in the tank farm. c) Two valves were tagged with the same number (30) in the tank farm. d) Valve number 9 of the north pump skid is identified in the P&ID as an electrical switch but the north pump skid has a valve tagged with the number 9. e) The tags on the north pump skid, the aerosol line, and the manifold did not match the legend and the P&IDs. f) Valve number 32 of the tank farm is a shut-off for tank number 6, which is a tank that contains isobutane, and it connects to the north pump skid. The P&ID shows valve number 32 as an emergency pop-off auto valve located on top of tank 7, which is a propane tank. g) P&IDs do not include pipe size or length. h) The north pump skid P&ID and legend indicate that tag number 17 is a 2" XH Nipple- Close, but there is a ball valve tagged number 17 instead. i) The valve types was inaccurate in the P&IDs for the north pump skid. The legend indicated that there were globe-type valves installed in the system but the valves were ball valves. j) The P&IDs and legend indicated that valve number 17 is a valve to tank 12 but the valve is not tagged. A valve tagged number 17 was found on the north pump skid. k) The pump skid P&ID and legend indicated that tag number 10 is a fisher 2" globe valve but there was a ball valve that was tagged number 9 in the same place and no valves tagged number 10. This exposed employees to fire and explosion hazards from the release of flammable liquids and gases in aerosol filling operations.