On 8/9/21, the flex hose transferring chlorine to the furnace failed, and employees discovered the leak by observing a visible chlorine cloud. An exposed employee was hospitalized as a result of pulmonary edema.
29 CFR 1910.119(d)(3)(ii)
Serious; $11,167
The employer did not document that the equipment complied with recognized and generally accepted good engineering practices.
a) Chlorine process: The employer did not document that the chlorine flex hose from the carbon steel pipe to the Metaullics pump for the furnace complied with RAGAGEP, such as Chlorine Pamphlet 6, Edition 16 Section 9, in that the flex hose was not designed for chlorine use and used as permanent piping. Failure to document that piping and hoses are suitable for service exposes employees to loss of containment events leading to exposure to chlorine resulting in skin and eye burns and possibly pulmonary edema, on or about 8/9/21.
b) Furnace area: The employer did not document that a chlorine monitor was installed that complied with RAGAGEP, such as Chlorine Institute Pamphlet 1, Edition 8, section 8, in that chlorine was piped from the chlorine room to the furnace without a means to detect a leak. On 8/9/21, the flex hose transferring chlorine to the furnace broke, and employees learned of the leak by observing a visible cloud of chlorine. An exposed employee was hospitalized as a result of pulmonary edema.
c) Chlorine room: The employer did not document that the Farris pressure relief valves on evaporators H and M complied with RAGAGEP, such as Chlorine Institute Pamphlet 6, Edition 16 Section 5.2, in that the relief valve did not vent to a safe location. The discharge piping from the valve was removed allowing the valve to vent directly above the operation panel of the evaporators potentially exposing employees when they are taking readings of the panels, on or about 8/10/21.
29 CFR 1910.119(e)(1)
Serious; $11,167
The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910.119:
a) Chlorine process: On or about 8/10/21, the PHA failed to identify, evaluate, and control hazards as a result of failure of the heat exchanger within the evaporators.
b) Chlorine process: On or about 8/10/21, the PHA failed to identify, evaluate, and control hazards of high/low chlorine gas temperature from the evaporator.
29 CFR 1910.119(e)(3)(iii)
Serious; $11,167
The process hazard analysis did not address engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases.
a) Chlorine process: On or about 8/10/21, the PHA did not address the consequences of the loss of nitrogen when purging the chlorine system. The system is purged several times per year for maintenance and annually for a system rebuild.
29 CFR 1910.119(e)(3)(v)
Serious; $11,167
The process hazard analysis did not address facility siting. A) Chlorine process: On or about 8/10/21, the employer did not address facility siting. The 1999, 2005, 2010, 2015, and 2020 PHAs did not address potential toxic release of chlorine gas scenarios and the impact on employees throughout the plant, including the furnace area, office building, warehouse, and maintenance area. Employees work in these areas daily.
29 CFR 1910.119(e)(3)(vi)
Serious; $11,167
The process hazard analysis did not address human factors.
a) Chlorine process: The PHA did not address human factors when changing one-ton chlorine containers. The PHA did not address improper torqueing or the use of the wrong type of wrench when connecting and disconnecting the containers, or tightening the packing nut, on or about 8/10/21.
29 CFR 1910.119(f)(1)(ii)
Serious; $11,167
The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and did not address operating limits.
a) Chlorine process: The Chlorine Field Service Report, “Form A”, did not include the operating parameters for the evaporator water level and temperature, chlorine gas temperature and chlorine gas pressure, on or about 8/10/21.
29 CFR 1910.119(f)(1)(ii)(A)
Serious; $11,167
The employer did not develop and implement written operating procedures that addressed the consequences of deviations from the operating limits in the covered process.
a) Chlorine process: The employer did not list the consequences of deviation for the high and low temperature and high and low pressure operating limits in their “Standard Operating Procedures for Chlorine Activities” in sections I-IV and VI, on or about 8/10/21.
29 CFR 1910.119(f)(1)(ii)(B)
Serious; $0.00
The employer did not develop and implement written operating procedures that provided clear instructions for steps required to correct or avoid deviation from the operating limits in the covered process. a) Chlorine process: The employer did not list the steps required to correct or avoid deviation for high and low temperature and high and low pressure operating limits in their “Standard Operating Procedures for Chlorine Activities” in sections I-IV and VI, on or about 8/10/21.
29 CFR 1910.119(j)(4)(i)
Serious; $11,167
The employer did not perform inspections and tests on process equipment
a) Chlorine process: The employer did not test the Eclipse Actuator emergency shutoff system every time a chlorine container was changed as recommended by the manufacturer, on or about 8/9/21.
b) Chlorine process: The employer did not test the continuity of the sensor input connections for the Eclipse Actuator emergency shutoff system every three months as recommended by the manufacturer, on or about 8/9/21.
c) Chlorine process: The employer did not check the calibration voltages every three months for the De Nora Electrochemical Chlorine Sensor Module as required by the manufacturer, on or about 8/9/21.
29 CFR 1910.119(j)(4)(ii)
Serious; $11,167
Inspections and testing procedures performed on process equipment to maintain its mechanical integrity did not follow recognized and generally accepted good engineering practices (RAGAGEP).
a) Chlorine process: Piping was inspected bi-annually through ultra sonic testing, but a specific RAGAGEP, such as, but not limited to ASME B31.3, that included items such as documentation of testing points and measurements and actions to take based on the results, was not referenced, exposing employees to a potential chlorine release on or about 8/10/21.
29 CFR 1910.119(j)(4)(iii)
Serious; $0.00
The frequency of inspections and tests of process equipment to maintain its mechanical integrity was not consistent with applicable manufacturer’s recommendations and good engineering practices, nor was it more frequently determined to be necessary by prior operating experience.
a) Chlorine process: The employer did not inspect the retainer and seat for the gas pressure reducing valve monthly as recommended by the manufacturer, on or about 8/10/21.
b) Chlorine process: The employer did not test the chlorine sensors monthly as required by the employer, on or about 8/10/21.
29 CFR 119.(j)(4)(iv)
Serious; $11,167
The employer did not document each inspection and test that had been performed on process equipment with documentation that identified the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.
a) Chlorine process: The employer did not document annual inspections of the H and M evaporators that included a description of the inspection or test, the results, and the person who performed the test. This included testing for equipment, such as but not limited to, electrical system checks of relief system pressure switches, automatic water level control, and low level switch, and operational testing of pressure relief systems, and in-place cleaning of the evaporator cylinder and system according to the manufacturer, on or about 8/10/21.
29 CFR 1910.119(j)(5)
Serious; $11,167
The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) before use.
a) Chlorine process: The employer did not repair the broken chlorine gas gauge on the H furnace evaporator. The gauge was broken, and employees could not identify the temperature of the gas leaving the evaporator to the furnace, on or about 8/10/21.
b) Chlorine process: The employer did not repair the broken water level indicator on the H furnace evaporator used to determine the amount of water in the hot water tank used to heat the chlorine, on or about 8/10/21.
c) Chlorine process: The employer did not repair the broken low water indicator light on the H furnace evaporator used to measure the water level in the hot water tank used to heat the chlorine, on or about 8/10/21.
d) Chlorine process: The employer did not repair the high and low temperature indicators on the H furnace evaporator used to measure the water temperature in the hot water tank used to heat the chlorine, on or about 8/10/21.
29 CFR 1910.119(l)(1)
Serious; $7,977
The employer did not establish written procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process.
a) Chlorine process: The employer did not establish and implement written procedures to manage changes to process equipment that affected a covered process. The employer removed the piping from the Farris Relief Valves located on the evaporators in the chlorine room, which would have vented a chlorine release to the outside of the building, on or about 8/10/21.
29 CFR 1910.119(c)(2)
Serious; $0.00
The employer did not consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard.
a) Chlorine process: The employer did not include employees in the development of the process hazard analysis (PHA) for the chlorine process. Employees did not know where to obtain a copy of the PHA or what it consisted of or about 8/10/21.
29 CFR 1910.119(e)(3)(ii)
Serious; $0.00
The process hazard analysis did not address the identification of any previous incident that had a likely potential for catastrophic consequences in the workplace.
a) Chlorine process: On or about 8/9/21, the PHA failed to address previous incidents where chlorine was released from the process. On 5/15/18, a low-pressure gauge on the M Furnace failed, resulting in a chlorine release requiring the assistance of the local emergency response HAZMAT team.
| Violations/Penalties | Serious | Willful | Repeat | Other | Unclass | Total |
|---|---|---|---|---|---|---|
| Initial Violations | 12 | 2 | 14 | |||
| Current Violations | 12 | 2 | 14 | |||
| Initial Penalty | $130,814 | $0 | $0 | $0 | $0 | $130,814 |
| Current Penalty | $67,983 | $0 | $0 | $0 | $0 | $67,983 |
| FTA Penalty | $0 | $0 | $0 | $0 | $0 | $0 |
| # | Citation ID | Citaton Type | Standard Cited | Issuance Date | Abatement Due Date | Current Penalty | Initial Penalty | FTA Penalty | Contest | Latest Event | Note |
|---|---|---|---|---|---|---|---|---|---|---|---|
| 1. | 01001 | Serious | 19100119 D03 II | 02/07/2022 | 02/20/2024 | $7,000 | $11,167 | $0 | 03/02/2022 | P – Petition to Mod Abatement | |
| 2. | 01002 | Serious | 19100119 E01 | 02/07/2022 | 01/03/2023 | $7,000 | $11,167 | $0 | 03/02/2022 | J – ALJ Decision | |
| 3. | 01003 | Serious | 19100119 E03 III | 02/07/2022 | 01/03/2023 | $10,995 | $11,167 | $0 | 03/02/2022 | J – ALJ Decision | |
| 4. | 01004 | Serious | 19100119 E03 V | 02/07/2022 | 01/03/2023 | $0 | $11,167 | $0 | 03/02/2022 | J – ALJ Decision | |
| 5. | 01005 | Serious | 19100119 E03 VI | 02/07/2022 | 01/03/2023 | $0 | $11,167 | $0 | 03/02/2022 | J – ALJ Decision | |
| 6. | 01006 | Serious | 19100119 F01 II | 02/07/2022 | 01/03/2023 | $10,994 | $11,167 | $0 | 03/02/2022 | J – ALJ Decision | |
| 7. | 01007A | Serious | 19100119 F01 II A | 02/07/2022 | 01/03/2023 | $0 | $11,167 | $0 | 03/02/2022 | J – ALJ Decision | |
| 8. | 01007B | Serious | 19100119 F01 II B | 02/07/2022 | 01/03/2023 | $0 | $0 | $0 | 03/02/2022 | J – ALJ Decision | |
| 9. | 01008 | Serious | 19100119 J04 I | 02/07/2022 | 01/03/2023 | $10,994 | $11,167 | $0 | 03/02/2022 | J – ALJ Decision | |
| 10. | 01009A | Serious | 19100119 J04 II | 02/07/2022 | 01/03/2023 | $7,000 | $11,167 | $0 | 03/02/2022 | J – ALJ Decision | |
| 11. | 01009B | Serious | 19100119 J04 III | 02/07/2022 | 01/03/2023 | $0 | $0 | $0 | 03/02/2022 | J – ALJ Decision | |
| 12. | 01010 | Serious | 19100119 J04 IV | 02/07/2022 | 01/03/2023 | $0 | $11,167 | $0 | 03/02/2022 | J – ALJ Decision | |
| 13. | 01011 | Serious | 19100119 J05 | 02/07/2022 | 01/03/2023 | $7,000 | $11,167 | $0 | 03/02/2022 | J – ALJ Decision | |
| 14. | 01012 | Serious | 19100119 L01 | 02/07/2022 | 01/03/2023 | $7,000 | $7,977 | $0 | 03/02/2022 | J – ALJ Decision | |
| 15. | 02001 | Other | 19100119 C02 | 02/07/2022 | 01/03/2023 | $0 | $0 | $0 | 03/02/2022 | J – ALJ Decision | |
| 16. | 02002 | Other | 19100119 E03 II | 02/07/2022 | 01/03/2023 | $0 | $0 | $0 | 03/02/2022 | J – ALJ Decision |
Source: https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1546668.015