Text For Citation: 01 Item/Group: 009 Hazard:

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means were taken to assure safe operation: 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 Five Year Independent Mechanical Integrity Inspection Audit findings and recommendations since 2006 to 2015 have not been corrected. The employer failed to correct deficiencies in equipment that were outside acceptable limits. Identified findings and recommendations such as but not limited to the following: A) 2006 Mechanical Integrity Audit Action Register. 1. All accumulators and intercoolers equipped with high-level float switches that sound a high liquid alarm level 2. Field test pressure 3. Aisles in the machinery room clearly marked B) Updated MIA Tracking Report 2010. 1. Column 141 - Evaporators Grading Cooler Units (all) - Need to improve access to these units. 2. Column 143 - Evaporators Grading Cooler Units (all) - Some of the exposed piping at the valve stations is starting to rust and corrode. This should be sanded, cleaned, primed, and re-painted. 3. Column 144 - Evaporators Hall East of Offal Unit 21-1 - Need to improve unit protection from impacts by forklifts. This standard is covered in IIAR Bulletin 109, Section 4.4.2. 4. Column 147 - Evaporators Offal Units (all) - Some of the exposed piping at the valve stations is starting to rust and corrode. This should be sanded, cleaned, primed, and re-painted. 5. Column 150 - Evaporators Ground Beef Units Zone 23 (all) - Some of the exposed piping at the valve stations is starting to rust and corrode. This should be sanded, cleaned, primed, and re-painted. 6. Column 152 - Evaporators Offal Processing Units Zone 24 (all) - Some of the exposed piping at the valve stations is starting to rust and corrode. This should be sanded, cleaned, primed, and re-painted. Scheduled Completion Date 1/20/2016. 7. Columns 153 - 154 - 156 - 158 - 159 - 161 - 162 - 164 - Scheduled Completion Date 1/20/2016. 8. Columns 166 - 168 - 175 - 177 - 180 - 182 - 185 - 187 - 191 - 192 - 194 - 196 - 198 - 203 - 208 - 213 - 215 - 216 - 217 - 218 - 230 - 235 - 236 -- Scheduled Completion Date 2/20/2016; 2/21/2016; 2/15/2016; 2/2/2016; 2/1/2016. C) PSM corrective actions needed to close out 2010 MIA RR. PSM Compliance items needing completed to close out 2010 Mechanical Integrity Audit: 4 items listed, but no status updated. D) 2015 detailed MIA Tracking Report and 2015 MI short action item list. Many columns did not show a completion date, or status updated. E) 2015 MI short action item list. A lot of columns showed comments but there was not any completion date validated. F) 2015 Main Plant - Executive Summary 2015. Unknown status on the following recommendations: 1. Evaluate Evaporative Condenser ECD-3 for replacement. 2. Reattach the nameplate to Thermosyphon Vessel TSV-1 following ASME procedures. 3. Recommend nondestructive testing of piping and vessels. 4. Valves open to atmosphere must be capped or plugged when not in use. Seal caps should also be used whenever possible to prevent exposure of valve stems to the elements. 5. The exposed piping and valve trains need immediate attention to prevent further corrosion. Clean with a wire brush, prime, and apply preventive paint. At the same time, the small areas of broken insulation should be repaired to restore the vapor barrier. 6. Install identification labels on all piping and equipment in the system that conforms with the identification utilized on the P&IDs and IIAR Bulletin 114. 7. Evaluate all control wiring junction boxes for support and proper installation. 8. Lighting must be installed in all working areas to provide safe working conditions. The lighting on the roof was not adequate to afford safe access. 9. Ensure the sign currently outside the Engine Room door, setting forth the owner/installing or servicing contractors name, design pressure for the system, pounds of ammonia in the system, brand and type of lubricant used, and the quantity thereof is correct and provides the necessary information as require. 10. The upper catwalk for Evaporative Condensers EC-3 and EC-4 needs to be evaluated for load bearing mechanical strength. 11. Install guards to prevent forklift impact as necessary. 12. Ensure the Engine Room ventilation system is adequate for normal and emergency ventilation as well as temperature requirements. G) 2015 Main Plant - Relief Valves. Unknown status on the following recommendations: See Relief Valve Calculations report for recommendations. Consider corrected the valves found by the Lamb Group LLC on 2015, based on their relief system calculations for the existing relief valves and discharge piping for the Main Plant ammonia refrigeration system. H) 2015 Main Plant - Ventilation. Unknown status on the following recommendations: Recommend that a ventilation study be conducted based on current conditions to determine if the exhaust fans are adequate during normal and emergency situations. I) 2015 New Addition - Executive Summary 2015. Unknown status on the following recommendations: 1. Install panic hardware on the machinery room exit doors. 2. Install an audible and visual alarm for ammonia inside the Machinery Room and outside each entrance to the Machinery Room. Install signs to indicate the meaning of each alarm near each alarm. 3. Revised the system charge calculations and documentation to coincide with the actual amount of ammonia in the system. 29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is complete.