osha citations against o&g for kleen energy accident

8/8/2019 OSHA citations against O&G for Kleen Energy accident

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U.S. Department of LaborOccupational Safety and Health Administration1057 Broad Street

Bridgeport, CT 06604

Phone: (203)579-5581 FAX: (203)579-5516

Citation and Notification of Penalty

To: Inspection Number: 109179937O&G Industries Inc. Inspection Date(s): 02/07/2010-08/02/2010and its successors Issuance Date: 08/03/2010112 Wall StreetTorrington, CT 06790

The violation(s) described in this Citation

and Notification of Penalty is (are) alleged tohave occurred on or about the day(s) the

inspection was made unless otherwise

Inspection Site:

1349 River RoadMiddletown, CT 06457

Citation and Notification of Penalty Page 1 of 83 OSHA-2(Rev. 6/93)

indicated within the description given below.

This Citation and Notification of Penalty (this Citation) describes violations of the Occupational Safety and Health Actof 1970. The penalty(ies) listed herein is (are) based on these violations. You must abate the violations referred to inthis Citation by the dates listed and pay the penalties proposed, unless within 15 working days (excluding weekendsand Federal holidays) from your receipt of this Citation and Notification of Penalty you mail a notice of contest to theU.S. Department of Labor Area Office at the address shown above. Please refer to the enclosed booklet (OSHA 3000)which outlines your rights and responsibilities and which should be read in conjunction with this form. Issuance ofthis Citation does not constitute a finding that a violation of the Act has occurred unless there is a failure to contest asprovided for in the Act or, if contested, unless this Citation is affirmed by the Review Commission or a court.

Posting - The law requires that a copy of this Citation and Notification of Penalty be posted immediately in aprominent place at or near the location of the violation(s) cited herein, or, if it is not practicable because of the natureof the employer's operations, where it will be readily observable by all affected employees. This Citation must remainposted until the violation(s) cited herein has (have) been abated, or for 3 working days (excluding weekends andFederal holidays), whichever is longer. The penalty dollar amounts need not be posted and may be marked outor covered up prior to posting.

Informal Conference - An informal conference is not required. However, if you wish to have such a conferenceyou may request one with the Area Director during the 15 working day contest period. During such an informal

conference you may present any evidence or views which you believe would support an adjustment to the citation(s)and/or penalty(ies).

If you are considering a request for an informal conference to discuss any issues related to this Citation andNotification of Penalty, you must take care to schedule it early enough to allow time to contest after the informalconference, should you decide to do so. Please keep in mind that a written letter of intent to contest must be submitted


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to the Area Director within 15 working days of your receipt of this Citation. The running of this contest period is notinterrupted by an informal conference.

If you decide to request an informal conference, please complete, remove and post the page 4 Notice to Employeesnext to this Citation and Notification of Penalty as soon as the time, date, and place of the informal conference havebeen determined. Be sure to bring to the conference any and all supporting documentation of existing conditions aswell as any abatement steps taken thus far. If conditions warrant, we can enter into an informal settlement agreement

which amicably resolves this matter without litigation or contest.

Right to Contest - You have the right to contest this Citation and Notification of Penalty. You may contest allcitation items or only individual items. You may also contest proposed penalties and/or abatement dates withoutcontesting the underlying violations. Unless you inform the Area Director in writing that you intend to contestthe citation(s) and/or proposed penalty(ies) within 15 working days after receipt, the citation(s) and the

proposed penalty(ies) will become a final order of the Occupational Safety and Health Review Commission and

may not be reviewed by any court or agency.

Penalty Payment - Penalties are due within 15 working days of receipt of this notification unless contested. (Seethe enclosed booklet and the additional information provided related to the Debt Collection Act of 1982.) Make yourcheck or money order payable to "DOL-OSHA". Please indicate the Inspection Number on the remittance.

OSHA does not agree to any restrictions or conditions or endorsements put on any check or money order for less thanthe full amount due, and will cash the check or money order as if these restrictions, conditions, or endorsements do notexist.

Notification of Corrective Action - For each violation which you do not contest, you must notify the AreaDirector of the Bridgeport OSHA Area Office, by letter, within 10 calendar days after each abatement date, that youhave taken appropriate corrective action within the time frame set forth on this Citation. Where the citation indicatesthat abatement certification is necessary, only the abatement method and date when abatement occurred are required.

Where the citation indicates that abatement documentation is necessary, evidence of the purchase or repair of

equipment, photographs or video, receipts, etc., verifying that abatement has occurred is required. The abatement

letter must be posted at the location where the violation appeared and the corrective action took place or employeesmust otherwise be effectively informed about abatement activities. A sample abatement certification letter is enclosedwith this Citation.

Employer Discrimination Unlawful - The law prohibits discrimination by an employer against an employeefor filing a complaint or for exercising any rights under this Act. An employee who believes that he/she has beendiscriminated against may file a complaint no later than 30 days after the discrimination occurred with the U.S.Department of Labor Area Office at the address shown above.

Employer Rights and Responsibilities - The enclosed booklet (OSHA 3000) outlines additional employerrights and responsibilities and should be read in conjunction with this notification.


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Notice to Employees - The law gives an employee or his/her representative the opportunity to object to anyabatement date set for a violation if he/she believes the date to be unreasonable. The contest must be mailed to theU.S. Department of Labor Area Office at the address shown above and postmarked within 15 working days (excludingweekends and Federal holidays) of the receipt by the employer of this Citation and Notification of Penalty.

Inspection Activity Data - You should be aware that OSHA publishes information on its inspection and citationactivity on the Internet under the provisions of the Electronic Freedom of Information Act. The information related to

these alleged violations will be posted when our system indicates that you have received this citation, but not soonerthan 30 calendar days after the Citation Issuance Date. You are encouraged to review the information concerning yourestablishment at www.osha.gov. If you have any dispute with the accuracy of the information displayed, pleasecontact this office.


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U.S. Department of LaborOccupational Safety and Health Administration

NOTICE TO EMPLOYEES OF INFORMAL CONFERENCE

An informal conference has been scheduled with OSHA to discuss the citation(s) issued on

08/03/2010. The conference will be held at the OSHA office located at 1057 Broad Street,

Bridgeport, CT, 06604 on _____________ at _____________. Employees and/or representatives of

employees have a right to attend an informal conference.



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U.S. Department of Labor Inspection Number: 109179937Occupational Safety and Health Administration Inspection Dates: 02/07/2010 - 08/02/2010

Issuance Date: 08/03/2010


Company Name: O&G Industries Inc.

Inspection Site: 1349 River Road, Middletown, CT 06457

See pages 1 through 4 of this Citation and Notification of Penalty for information on employer and employee rights and responsibilities.

Citation and Notification of Penalty Page 5 of 83 OSHA-2 (Rev. 9/93)

Citation 1 Item 1 Type of Violation: Serious

29 CFR 1926.21(b)(6)(i): The employer did not comply with any specific regulations that apply to work in dangerousor potentially dangerous areas where employees were required to enter into confined or enclosed spaces.

a.Site - Employees required to enter into confined spaces were not instructed as to the nature of the hazards involved,the necessary precautions to be taken and in the use of protective and emergency equipment required.

ABATEMENT NOTE: For the purposes for paragraph (b)(6)(i) of this section, "confined or enclosed space" meansany space having limited means of egress, which is subject to the accumulation of toxic or flammable contaminants orhas oxygen deficient atmosphere. Confined or enclosed spaces include, but are not limited to, storage tanks, processvessels, bins, boilers, ventilation or exhaust ducts, sewers, underground utility vaults, tunnels, pipelines and open topspaces more than 4 feet in depth such as pits, tubes, vaults and vessels.

ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM

Date By Which Violation Must be Abated: 08/09/2010

Proposed Penalty: $ 7000.00


29 CFR 1926.24: The employer did not develop and maintain an effective fire protection and prevention programat the job site throughout all phases of the construction, repair, alteration, or demolition work:

a.Site - An effective fire protection and prevention program was not developed nor maintained.


Date By Which Violation Must be Abated: 08/09/2010Proposed Penalty: $ 7000.00


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The alleged violations below have been grouped because they involve similar or related hazards that may increasethe potential for injury resulting from an accident.

Citation 1 Item 3a Type of Violation: Serious

29 CFR 1926.28(a): Appropriate personal protective equipment was not worn by employee(s) in all operations

where there was exposure to hazardous conditions:

a.Site: Employees working in the HRSG #1 knockout tank sump area and exposed to drowning hazards were notwearing personal flotation devices.



Citation 1 Item 3b Type of Violation: Serious

29 CFR 1926.106(a): Employee(s) working over or near water where the danger of drowning existed, were notprovided with U.S. Coast Guard approved life jacket(s) or buoyant work vest(s):

a.Site: Employees working in the HRSG #1 knockout tank sump area and exposed to drowning hazards were notprovided with personal flotation devices.




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29 CFR 1926.65(q)(1): The employer did not develop and implement an emergency response plan to handleanticipated emergencies prior to the commencement of emergency response operations.

a.Site - An emergency response plan was not developed and implemented.




29 CFR 1926.150(e)(1): An alarm system was not established by the employer whereby employees on the sitecould be alerted for emergencies:

a.Site - An alarm system had not been established where employees onsite could be alerted for emergencies.




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29 CFR 1926.150(e)(2): The alarm code or reporting instructions were not conspicuously posted at phones or atemployee entrances:

a.Site - Alarm codes were not posted.




29 CFR 1926.153(j): Container(s) of liquefied petroleum gas (LPG) were stored within building(s):

a.Throughout the Site - Three LPG cylinders were stored indoors.




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29 CFR 1926.405(a)(2)(ii)(C): Receptacles for uses other than temporary lighting were installed on branch circuitswhich supplied temporary lighting:

a.Gas Compressor Building: Receptacles for temporary power and temporary lighting were installed on the samebranch circuit.




29 CFR 1926.453(b)(2)(v): A Safety Harness was not worn and a lanyard attached to the boom or basket whenworking from an aerial lift.

a.Power Generation Building, Between CT#1 and CT#2 @ Column G-4: An employee who was working in anaerial lift was not tied off with a full body harness and lanyard attached.




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29 CFR 1926.501(b)(4)(i): Each employee on walking/working surfaces were not protected from falling throughholes more than 6 feet above lower levels, by personal fall arrest systems, covers, or guardrail systems erectedaround such holes:

a.Power Generation Building, Alongside CT#1: Employees were not protected from stepping into holes by the use

of covers.

b.Power Generation Building, Alongside CT#2: Employees were not protected from stepping into holes by the useof covers.




29 CFR 1926.502(i)(4): All covers were not secured when installed so as to prevent accidental displacement by thewind, equipment, or employees:

a.Between HRSG 1 and HRSG2 - Floor hole covers were not secured.

b.Near Water Treatment Building - Floor hole covers were not secured.

c.East side of HRSG #1 - Floor hole covers were not secured.




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29 CFR 1926.502(i)(4): All covers were not color coded or marked with the word "HOLE" or "COVER" toprovide warning of the hazard:

a.Between HRSG 1 and HRSG2 - Floor hole covers were not color coded nor marked.

b.Near Water Treatment Building - Floor hole covers were not color coded nor marked.

c.East side of HRSG #1 - Floor hole covers were not color coded nor marked.




29 CFR 1926.602(c)(1)(ii): Modifications or additions which will affect the capacity or safe operations of the

equipment or reduce the orginial safety factor were made without the manufacturer's written approval.

a.Outside of Power Generation Building Fork extensions were used on a JLG forklift without the manufacturer'swritten approval. Also the capacity tags on the unit had not been updated to reflect the added pieceof equipment.




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29 CFR 1926.1053(b)(1): When the side rails of portable ladder(s) were unable to extend at least 3 feet above thelanding because of the portable ladder's length, the ladder(s) were not secured at top to rigid support(s) andgrasping devices, such as a grabrail were not provided:

a.Power Generation Building - Where the side rails of a stepladder could not extend above the electrical cabinets,the ladder was not secured at top to rigid support(s) and a grasping device, such as a grabrail, was

not provided.




29 CFR 1926.1053(b)(13): The top or top step of a stepladder was used as a step:

a.Power Generation Building - When accessing the top of an electrical cabinet, workers were using the top step andtop of the stepladder.




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Citation 2 Item 1 Type of Violation: Willful

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employmnentand a place of employment which were free from recognized hazards that were causing or likely to cause death orserious physical harm to employees in that employees were exposed to the hazards of falls, drowning and/orasphyxiation:

a.Site: Workers were exposed to the hazards of falls, drowning and asphyxiation when they were allowed to enterconfined spaces without benefit of air monitoring, fall protection and/or protection from drowning.

ABATEMENT NOTE: Among other methods, one feasible and acceptable means of abatement is to followANSI/ASSE Z117.1-2009, entitled Safety Requirements for Confined Spaces.




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Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment anda place of employment which were free from recognized hazards that were causing or likely to cause death orserious physical harm in that the method used to clean the 561 main fuel gas line pipes - blowing natural gasthrough them at high velocity - was not implemented in such a way as to protect employees from the hazard of anexplosion caused by venting large amounts of natural gas into areas where it could accumulate and where, or inclose proximity to where, ignition sources existed. The following conditions and practices contributed to the

existence of this hazard: the vent pipe configured close to and below scaffolding, in close proximity to the PowerGeneration Building, in between two approximately 115 foot tall Heat Recovery Steam Generators (HRSGs) andwell below the tops of all of those structures; the failure to eliminate open flame ignition sources, including but notlimited to propane heaters; construction work occurring during the gas blow process; individuals other than thoseessential to conducting the gas blows working in the area during the gas blow process; and the inability to readilycontrol the amount of gas and pressure flowing through the main gas fuel line.

On February 7, 2010, employees were exposed to serious or fatal impact and other injuries from an explosionhazard created when a large amount of natural gas was blown at high velocity through CT#1 Main Knockout DrumVent Pipe (561-TNK-1002) into the area between the two HRSGs and close to buildings, scaffolding, partiallyenclosed work areas, and other structures that were adjacent to the Power Generation Building in which employees

worked and in or around which open flame ignition sources, including but not limited to propane heaters, existed,construction work was occurring, and numerous employees non-essential to conducting the gas blow were working.

When natural gas is chosen for this method of cleaning gas line pipes, feasible means of abatement to eliminate ormaterially reduce the hazard are to ensure that the vent pipe is positioned vertically and above the PowerGeneration Building and all other nearby structures, or horizontally to a location away from structures that couldinhibit the adequate dispersal of the gas; ensure that any and all ignition sources are eliminated; ensure that any andall construction activity ceases during the gas blow process; ensure that all workers other than those essential toconducting the gas blows are removed from the building and area around which the gas blows are occurring; andensure the use of devices to control the amount and pressure of gas vented, such as a fast closing pipe shut-off valveand a gas pressure control valve.




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Proposed Penalty: $ 70000.00


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existence of this hazard: the vent pipe configured close to and below scaffolding, in close proximity to the PowerGeneration Building, in the area immediately east of the two approximately 115 foot tall Heat Recovery SteamGenerators (HRSGs) and well below the tops of all of those structures; the failure to eliminate open flame ignitionsources, including but not limited to propane heaters; construction work occurring during the gas blow process;individuals other than those essential to conducting the gas blows working in the area during the gas blow process;and the inability to readily control the amount of gas and pressure flowing through the main gas fuel line.

On February 7, 2010, employees were exposed to serious or fatal impact and other injuries from an explosionhazard created when a large amount of natural gas was blown at high velocity through CT#2 Main Knockout DrumVent Pipe (561-TNK-2002) into the area immediately east of HRSG number 2 and close to buildings, scaffolding,partially enclosed work areas, and other structures that were adjacent to the Power Generation Building in which

employees worked and in or around in which open flame ignition sources, including but not limited to propaneheaters, existed, construction work was occurring, and numerous employees non-essential to conducting the gasblow were working.

When natural gas is chosen for this method of cleaning gas line pipes, feasible means of abatement to eliminate ormaterially reduce the hazard are to ensure that the vent pipe is positioned vertically and above the PowerGeneration Building and all other nearby structures, or horizontally to a location away from structures that couldinhibit the adequate dispersal of the gas; ensure that any and all ignition sources are eliminated; ensure that any andall construction activity ceases during the gas blow process; ensure that all workers other than those essential toconducting the gas blows are removed from the building and area around which the gas blows are occurring; andensure the use of devices to control the amount and pressure of gas vented, such as a fast closing pipe shut-off valve

and a gas pressure control valve.


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existence of this hazard: the vent pipe configured close to and below scaffolding, in close proximity to the PowerGeneration Building, in the area immediately east of the two approximately 115 foot tall Heat Recovery SteamGenerators (HRSGs) and well below the tops of all of those structures; the failure to eliminate open flame ignitionsources, including but not limited to propane heaters; construction work occurring during the gas blow process;individuals other than those essential to conducting the gas blows working in the area during the gas blow process;and the inability to readily control the amount of gas and pressure flowing through the main gas fuel line.

On February 7, 2010, employees were exposed to serious or fatal impact and other injuries from an explosionhazard created when a large amount of natural gas was blown at high velocity through CT#2 Pilot Gas FilterSeparator "A" Vent Pipe (561- SEP-2000A) into the area immediately east of HRSG number 2 and close tobuildings, scaffolding, partially enclosed work areas, and other structures that were adjacent to the Power

Generation Building in which employees worked and in or around in which open flame ignition sources, includingbut not limited to propane heaters, existed, construction work was occurring, and numerous employees non-essential to conducting the gas blow were working.

When natural gas is chosen for this method of cleaning gas line pipes, feasible means of abatement to eliminate ormaterially reduce the hazard are to ensure that the vent pipe is positioned vertically and above the PowerGeneration Building and all other nearby structures, or horizontally to a location away from structures that couldinhibit the adequate dispersal of the gas; ensure that any and all ignition sources are eliminated; ensure that any andall construction activity ceases during the gas blow process; ensure that all workers other than those essential toconducting the gas blows are removed from the building and area around which the gas blows are occurring; andensure the use of devices to control the amount and pressure of gas vented, such as a fast closing pipe shut-off valve

and gas pressure control valve.



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29 CFR 1926.20(b)(2): The employer did not initiate and maintain a safety program which provides for frequentand regular inspections of jobsites, materials, and equipment to be made by a competent person (i.e., a person whois capable of identifying existing and predictable hazards in the surroundings or working conditions which areunsanitary, hazardous, or dangerous to employees, and who has the authority to take prompt corrective measures toeliminate them):

a.Site - A competent person did not conduct frequent and regular inspections of the jobsite, materials andequipment as required.

ABATEMENT NOTE: A "competent person" means one who is capable of identifying existing and predictablehazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, andwhich has authorization to take prompt corrective measures to eliminate them.




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29 CFR 1926.21(b)(2): The employer did not instruct each employee in the recognition and avoidance of unsafecondition(s) and the regulation(s) applicable to his work environment to control or eliminate any hazard(s) or otherexposure to illness or injury:

a.Site - On or about February 7, 2010, O&G failed to instruct Employee #1 in the recognition and avoidance ofhazards related to gas blow operations.









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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee ofKeystone Construction and Maintenance was instructed in the recognition and avoidance ofhazards related to gas blow operations.

NOTE: For penalty purposes, the exposed employees of Keystone Construction and Maintenance have beenadministratively combined into a single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee ofBluewater Energy Services was instructed in the recognition and avoidance of hazards related to

gas blow operations.

NOTE: For penalty purposes, the exposed employees of Bluewater Energy Services have been administrativelycombined into a single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee ofUnited Anco Services was instructed in the recognition and avoidance of hazards related to gas

blow operations.

NOTE: For penalty purposes, the exposed employees of United Anco Services have been administrativelycombined into a single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee ofInstrument Sciences and Technology was instructed in the recognition and avoidance of hazards

related to gas blow operations.

NOTE: For penalty purposes, the exposed employees of Instrument Sciences and Technology have beenadministratively combined into a single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee ofCoverflex Manufacturing Inc. was instructed in the recognition and avoidance of hazards related to


NOTE: For penalty purposes, the exposed employees of Coverflex Manufacturing Inc. have been administrativelycombined into a single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee of ApiGroup Inc. was instructed in the recognition and avoidance of hazards related to gas blow

operations.

NOTE: For penalty purposes, the exposed employees of Api Group Inc. have been administratively combined intoa single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee of DucciElectrical Contractors, Inc. was instructed in the recognition and avoidance of hazards related to


NOTE: For penalty purposes, the exposed employees of Ducci Electrical Contractors, Inc. have beenadministratively combined into a single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee of NorthAmerican Energy Services (NAES) was instructed in the recognition and avoidance of hazards

related to gas blow operations.

NOTE: For penalty purposes, the exposed employees of North American Energy Services (NAES) have beenadministratively combined into a single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee ofSiemens Energy was instructed in the recognition and avoidance of hazards related to gas blow

operations.

NOTE: For penalty purposes, the exposed employees of Siemens Energy have been administratively combinedinto a single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee ofSmedley Crane was instructed in the recognition and avoidance of hazards related to gas blow

operations.

NOTE: For penalty purposes, the exposed employees of Smedley Crane have been administratively combined intoa single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee ofTucker Mechanical was instructed in the recognition and avoidance of hazards related to gas blow

operations.

NOTE: For penalty purposes, the exposed employees of Tucker Mechanical have been administratively combinedinto a single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee ofWorley Parsons was instructed in the recognition and avoidance of hazards related to gas blow

operations.

NOTE: For penalty purposes, the exposed employees of Worley Parsons have been administratively combined intoa single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee of TeamIndustrial was instructed in the recognition and avoidance of hazards related to gas blow

operations.

NOTE: For penalty purposes, the exposed employees of Team Industrial have been administratively combined intoa single citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee ofSecuritas was instructed in the recognition and avoidance of hazards related to gas blow operations.

NOTE: For penalty purposes, the exposed employees of Securitas have been administratively combined into asingle citation.




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a.Site - On or about February 7, 2010, O&G failed to instruct each employee or ensure that each employee ofContech Technical Services Co. was instructed in the recognition and avoidance of hazards related

to gas blow operations.

NOTE: For penalty purposes, the exposed employees of Contech Technical Services Co. have beenadministratively combined into a single citation.




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29 CFR 1926.352(c): The employer did not ensure that welding, cutting and heating was not performed where theapplication of flammable paints, or the presence of other flammable compounds, or heavy dust concentrationscreated a hazard.

a.Site - Welding, cutting and heating were performed where flammable compounds created a hazard.




29 CFR 1926.403(b)(2): Listed, labeled, or certified equipment was not installed and used in accordance withinstructions included in the listing, labeling, or certification:

a.Between HRSG #1 and HRSG #2 - On February 7, 2010, the Wacker Neuson Ground Heater was not used asinstructed by its listing, labeling or certification.




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a.North Wall near Column B2 - On February 7, 2010, the Dryco heater, number 52-13, was not used as instructedby its listing, labeling or certification.





a.South Wall near Column G2 - On February 7, 2010, the Dryco heater, number 51-03, was not used as instructedby its listing, labeling or certification.




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a.Subgrid CC+ near Column B6 - On February 7, 2010, the Dryco heater, number 52-14, was not used as instructedby its listing, labeling or certification.





a.Grid D-2/D-3 near Column G6 - On February 7, 2010, the Dryco heater, number 52-10, was not used asinstructed by its listing, labeling or certification.




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a.Grid D3 south of Column B8 - On February 7, 2010, the Dryco heater, number 52-13, was not used as instructedby its listing, labeling or certification.





a.North Wall on Column B1 - On February 7, 2010, the Brasch Electric heater was not used as instructed by itslisting, labeling or certification.




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a.On Column D1 - On February 7, 2010, the Brasch heater was not used as instructed by its listing, labeling orcertification.





a.Grid D-3 on Column G9 - On February 7, 2010, the Brasch heater was not used as instructed by its listing,labeling or certification.




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a.On Column G1 - On February 7, 2010, the Brasch heater was not used as instructed by its listing, labeling orcertification.





a.Grid D-2/D-3 on Column G5 - On February 7, 2010, the Brasch heater was not used as instructed by its listing,labeling or certification.




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a.Grid D-3 on Column B8 - On February 7, 2010, the Brasch heater was not used as instructed by its listing,labeling or certification.





a.Grid D-3 on Column B9 - On February 7, 2010, the Brasch heater was not used as instructed by its listing,labeling or certification.




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a.Grid D-2/D-3 on Column G4 - On February 7, 2010, the Brasch heater was not used as instructed by its listing,labeling or certification.





a.On Column G1 - On February 7, 2010, the Brasch heater was not used as instructed by its listing, labeling orcertification.




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a.Grid D-3 on Column G8 - On February 7, 2010, the Brasch heater was not used as instructed by its listing,labeling or certification.





a.Subgrid A - On February 7, 2010, the Miller IV Express Welder was not used as instructed by its listing, labelingor certification.




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a.Grid D-3, north side of Column G8 - On February 7, 2010, the temporary electric breaker panel SE1 was not usedas instructed by its listing, labeling or certification.





a.Subgrid A Column C4 - On February 7, 2010, the temporary electrical breaker panel NW1 was not used asinstructed by its listing, labeling or certification.




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a.Grid D-3 southwest of Column C9 - On February 7, 2010, temporary electrical breaker panel NE1A was not usedas instructed by its listing, labeling or certification.





a.Grid D-2/D-3 Subgrid j-k - On February 7, 2010, the temporary circuit breaker panel SW1 was not used asinstructed by its listing, labeling or certification.




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a.Grid D-3 west side between Columns D9 and E9 - On February 7, 2010, the Heat Stress Unit C121 was not usedas instructed by its listing, labeling or certification.





a.Grid D-3 west side between Columns D9 and E9 - On February 7, 2010, the Heat Stress Units C254R, C123 andC167 were not used as instructed by its listing, labeling or certification.




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a.Grids D-2/D-3 Subgrid I - On February 7, 2010, the Miller Mark VIII-2 8 pack welder was not used as instructedby its listing, labeling or certification.





a.Grid D-3 northwest side of Column C9 - On February 7, 2010, the Miller Mark VIII-2 8 pack welder was notused as instructed by its listing, labeling or certification.




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a.Grids D-2/D-3 Subgrid K - On February 7, 2010, the Miller Mark VIII-2 8 pack welder was not used as instructedby its listing, labeling or certification.





a.Grids D-2/D-3 near Column F6 - On February 7, 2010, the Miller Mark VIII-2 8 pack welder was not used asinstructed by its listing, labeling or certification.




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a.Grids D-2/D-3 Subgrid K - On February 7, 2010, the FM Mafco KVA power distribution panel was not used asinstructed by its listing, labeling or certification.





a.Grids D-2/D-3 near Column G6 - On February 7, 2010, the 25 KVA Power Distribution Panel was not used asinstructed

osha citations against o&g for kleen energy accident

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