Li Ion Battery Manufacturing is a PSM covered process

19100119 C01 – Employee Participation

19100119 C02 – Employee Participation

19100119 C03 – Employee Participation

19100119 D – On or about and prior to November 15, 2023,

the employer did not have a completed compilation of written

process safety information (PSI) (as required for hazards of

the chemicals, technology of the process and equipment in

the process) for managers, engineers, operators, contractors

and maintenance employees involved in operating and

maintaining the process to understand the hazards of the

process and equipment involving or affecting highly hazardous

chemicals. The employer had not compiled and managed PSI

for covered equipment prior to conduct of an initial process

hazard analysis; had not prepared files for each piece of covered

process equipment and populated those files with the process

safety information (PSI) required by 1910.119(d)(1)-(3).

Additionally, the employer failed to document and compile

PSI documenting that covered process equipment complies

with recognized and generally accepted engineering practices

(RAGAGEP) and other process information, such as records of

equipment operating conditions and records of mechanical

integrity activities used to collect

process safety information. 

19100119 E01 – The employer failed to conduct an initial process

hazard analysis prior to operating the covered process for the

new facility at 7400 Tod Avenue, Warren Ohio workplace. The

process hazard analysis had not been conducted, PHA

recommendations for PHA team findings had not been identified

and recommendations were not resolved prior to startup of

operations in 2022. 

19100119 I02 II – On or about and prior to November 15, 2023,

the employer failed to ensure that the pre-startup safety review

for a new facility confirmed that safety, operating, maintenance

and emergency procedures to comply with this part were in

place and adequate prior to the introduction of highly

hazardous chemicals to the CESS/electrolyte covered process.

The employer had not developed adequate written operating

procedures to comply with the requirements of

1910.119(f)(1)(i)-(iv) including but not limited to normal

operations, emergency shutdown, emergency operations,

startup following an emergency shutdown and safety

systems and their functions. The employer had not

developed adequate written mechanical integrity procedures

to comply with the requirements of 1910.119(j)(2)-(6) including

but not limited to maintenance, equipment inspection, equipment

testing and quality assurance written procedures to maintain

the on-going integrity of process equipment. 

19100119 I02 III – On or about and prior to November 15, 2023,

the employer failed to ensure that a process hazard analysis

(PHA) had been performed on the Central Electrolyte Storage

System (CESS) and packaging line covered processes and

that all PHA team recommendations have been resolved

prior to startup of the process. A PHA was not performed

prior startup of the covered process for the new facility. 

19100119 D03 I D – On or about and prior to November 14, 2023,

the employer did not document the relief system design and

design basis for 30 pressure vessels that are part of the

covered process in the CESS storage area and in the

packaging area. The employer did not document the conditions

or scenarios for which overpressure protection may be required,

such as those listed in API Standard 521 which include pool fires

that can affect multiple vessels, did not document the contingencies

that can cause overpressure and the associated pressures generated

and the rates at which fluids are required to be relieved, did not

document the A/C Tower 1 as a safe discharge location,

and did not document any considerations for the combined

effect of superimposed and built-up backpressure on the

operating characteristics of the relief devices for the

discharge piping from each pressure vessel to the A/C Tower 1

for any scenarios identified for which overpressure protection

may be required. The employer failed to document and

compile the relief system design and design basis for the

following covered process equipment:

a. Storage Tank ST-101A located in the CESS Storage Area,

b. Storage Tank ST-101B located in the CESS Storage Area,

c. Storage Tank ST-102A located in the CESS Storage Area,

d. Storage Tank ST-102B located in the CESS Storage Area,

e. Storage Tank ST-103A located in the CESS Storage Area,

f. Storage Tank ST-103B located in the CESS Storage Area,

g. Waste Tank WT-101 located in the CESS Storage Area,

h. Separator Tank SP-301 located in the CESS Storage Area,

i. Separator Tank SP-302 located in the CESS Storage Area,

j. Separator Tank SP-303 located in the CESS Storage Area, and

k. the Buffer Tank relief system comprised of 20 pressure vessels

located in the packaging line area that included protection for

Buffer Tanks BT-101A through BT-110B.

19100119 F01 I B – The employer failed to develop, document

\and implement PSM compliant operating procedures for

normal operations for the covered process operations that

included electrolyte material supply from the CESS storage

area, process piping distribution to the MCB cabinet, process

piping to Buffer Tank cabinets at the packaging line and

electrolyte filling in the packaging line. The employer had not

developed, documented and implemented an operating

procedure for normal operations that included the process

specific information required by 1910.119(f)(1)(ii), (iii) and (iv).

19100119 F01 I D – The employer failed to develop, document

and implement PSM compliant operating procedures for

emergency shutdown for the covered process operations

that included electrolyte material supply from the CESS

storage area, process piping distribution to the MCB cabinet,

process piping to Buffer Tank cabinets at the packaging line

and electrolyte filling in the packaging line. The employer

had not developed, documented and implemented an

operating procedure for emergency shutdown that included

the process specific information required by 1910.119(f)(1)(ii),

(iii) and (iv).

19100119 F01 I E – The employer failed to develop, document

and implement PSM compliant operating procedures for

emergency operations for the covered process operations

that included electrolyte material supply from the CESS storage area,

process piping distribution to the MCB cabinet, process piping

to Buffer Tank cabinets at the packaging line and electrolyte

filling in the packaging line. The employer had not developed,

documented and implemented an operating procedure for

emergency operations that included the process specific

information required by 1910.119(f)(1)(ii), (iii) and (iv).

19100119 J02 – On or about November 15, 2024, the employer

had not developed and implemented written procedures to

maintain the ongoing integrity of equipment that is part the

central electrolyte storage system (CESS) through the packaging

line including but not limited to pressure vessels

(storage tanks, separator tanks, waste tanks and buffer tanks)

the multicoupler box, valves, controls, pumps, instrumentation

and covered process piping.

The employer failed to implement written procedures for

inspection and testing to maintain equipment, inspection

and testing during the installation and during ongoing

use of covered process equipment. 

19100119 J04 I – On or about November 15, 2023, the

employer failed to perform initial inspections and tests

related to pressure vessels and pressure vessel

pressure-relieving device installation prior to putting

the equipment into service. Inspections and testing

had not been performed by a qualified and certified

API 510 inspector on ASME code pressure vessels,

for the following covered process equipment:

a. Storage Tank ST-101A located in the CESS Storage Area,

b. Storage Tank ST-101B located in the CESS Storage Area,

c. Storage Tank ST-102A located in the CESS Storage Area,

d. Storage Tank ST-102B located in the CESS Storage Area,

e. Storage Tank ST-103A located in the CESS Storage Area,

f. Storage Tank ST-103B located in the CESS Storage Area,

g. Waste Tank WT-101 located in the CESS Storage Area,

h. Separator Tank SP-301 located in the CESS Storage Area,

i. Separator Tank SP-302 located in the CESS Storage Area,

j. Separator Tank SP-303 located in the CESS Storage Area, and

k. the 20 Buffer Tanks located in the production building

packaging line area that included Buffer Tanks BT-101A

through BT-110B.

Pressure vessels that have not received initial inspections are at

increased risk for loss of containment and overpressure protection

system failure. 

19100119 J05 – Or or about February 28, 2024, the employer

had not corrected equipment deficiencies that were outside

acceptable limits defined by process safety information;

in that equipment was operated with relief system vent line

process piping being disconnected from the AC Tower 1 when

that piping was documented in P&IDs as connected to the

AC Tower 1 equipment. The CESS vent line is connected to

relief systems for ten ASME code pressure vessels in the CESS

storage area and was disconnected from the AC Tower 1

relief system discharge location. The CESS storage area relief

vent line had become “plugged” or blocked by electrolyte material

discharged into the piping and was discovered to be leaking electrolyte

on December 4, 2023. When attempts to clear the blocked

relief vent line failed, the process piping was disconnected

and capped on December 9, 2023. As of February 28, 2024,

the deficiency in the CESS Storage Area pressure vessel relief system

had not been corrected by re-establishing the process piping pathway

to the AC Tower 1 discharge location.

During an overpressure event, overpressure protection relief systems

for pressure vessels are intended to discharge to a safe location,

when the pathway for the discharge is blocked and then disconnected,

the risk for catastrophic release of highly hazardous

chemical from the covered process is increased. 

19100119 L01 – On or about February 28, 2024, the employer

did not ensure that management of change procedures were

developed and implemented related to the failure and

disconnection of the vent line connecting the CESS storage

area overpressure protection relief system to the AC tower.

The CESS storage area relief vent line had become “plugged”

or blocked by electrolyte material discharged into the piping

and was discovered to be leaking electrolyte on December 4, 2023.

When attempts to clear the blocked relief vent line failed,

the process piping was disconnected and capped on December 9, 2023.

As of February 29, 2024, the employer had not initiated a

PSM management of change procedure. 

19100119 L02 II – On or about March 5, 2024, the management of change

(MOC) procedures, MOC Change Validation Tool – v*.02 for CESS

Venting, dated March 5, 2024 failed to address the impact on safety

and health for the disconnection of the CESS Storage Vent line

from the A/C Tower 1 discharge location that disrupted the

pathway for the CESS Storage Area overpressure relief system.

The CESS Storage Area relief system is designed to vent

overpressure events from the 10 ASME code pressure vessels

from the storage area into the A/C Tower 1 discharge location.

This management of change procedure also failed to address

the safety and health impact for disconnecting a separator tank

from the vent line and connecting the separator tank discharge

to a flexible that is placed into an IBC tote during the unloading

of electrolyte from tankers. Each separator tank is the pathway

for the discharge of pressure-relieving devices for two storage tanks.

The MOC procedure failed to address the overpressure event

hazards for the altered pathway for the CESS Storage Area

venting into the disconnected (and capped) vent line that

could lead to catastrophic failure and the overpressure event hazards

of venting storage tank and separator tank contents into an IBC

tote during unloading which would lead to an immediate release

of electrolyte into an employee occupied area.

Due to these conditions for which the MOC does not address

overpressure event hazards, employees are exposed to fire,

explosion and contact hazards. 

19100119 L04 – On or about January 16, 2024, the employer

did not ensure that process safety information including,

but not limited to P&IDs, were updated following a

change a change in the vent piping from the

CESS storage area to the AC Towers.