Text For Citation: 01 Item/Group: 004A 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: Employees engaged in operating, inspecting, testing, and maintaining activities or performing other critical operations before evacuating such as turning valves on the roof to isolate leaks on the floor at the covered process equipment on the roof top and the engine rooms were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injury to persons in and near the facility in that the standard operating procedures for Ammonia process equipment did not fully address the steps required to correct or avoid the listed deviations. Identified operating procedures such as but not limited to the following: a) SOP ACC-5 - OPERATION OF AMMONIA RECIRCULATOR AND PUMPS - 20°F Recirculator, Oil Pot and Ammonia Liquid Pumps. - Revision 0 June 2014. DEVIATIONS/CONSEQUENCES - High pump discharge pressure will reduce flow and reduce BHP required for pump. Employer did not develop the steps required to correct or avoid deviation or to bring back to normal conditions for the Ammonia Pumps. b) SOP HS-8 - OPERATION OF AMMONIA SCREW COMPRESSOR - For Frick RWFII-134H High Stage Compressor with thermosyphon oil cooling - Revision 0 June 2014. There were no Safety Cutouts of the limit pressure set-point (PSIG) for Low Suction Alarm Pressure; and for Low Suction Cutout Pressure. Deviation: High discharge pressures - Steps required to correct or avoid deviation: Operate compressor at 185 psig maximum. Employer did not develop the steps required to correct or avoid deviation or to bring back to normal conditions if it gets above 185 psig but less than the set-point of 215 psig. c) SOP HS-9 - OPERATION OF AMMONIA SCREW COMPRESSOR - For Frick RWFII-134H High Stage Compressor with thermosyphon oil cooling - Revision 0 June 2014. There were no Safety Cutouts of the limit pressure set-point (PSIG) for Low Suction Alarm Pressure; and for Low Suction Cutout Pressure. Deviation: High discharge pressures - Steps required to correct or avoid deviation: Operate compressor at 185 psig maximum. Employer did not develop the steps required to correct or avoid deviation or to bring back to normal conditions if it gets above 185 psig but less than the set-point of 215 psig. d) SOP HS-10 - OPERATION OF AMMONIA SCREW COMPRESSOR - For Frick RWFII-134H High Stage Compressor with thermosyphon oil cooling - Revision 0 June 2014. There were no Safety Cutouts of the limit pressure set-point (PSIG) for Low Suction Alarm Pressure; and for Low Suction Cutout Pressure. Deviation: High discharge pressures - Steps required to correct or avoid deviation: Operate compressor at 185 psig maximum. Employer did not develop the steps required to correct or avoid deviation or to bring back to normal conditions if it gets above 185 psig but less than the set-point of 215 psig. e) SOP- ANHYDRATOR - OPERATION OF ANHYDRATOR - Revision 4 June 2012. Employer did not fully complete this SOP to provide a description of the anhydrator and controls defining its functions, operating conditions and limits, consequences of deviations from operating limits, describing its controls, instrumentation and safety systems and setting its operating limits. f) SOP HPR-2 - OPERATION OF HIGH PRESSURE / THERMOSYPHON RECEIVER - Revision 0 June 2014 - Employer had developed the task and steps for the Normal shut down (Maintenance) and the Emergency shut down but did not include the operating phase task procedure for the startup after a normal or an emergency shutdown. 29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is complete.