Plant was cited for six process safety management standard violations, including one willful, after an explosion in June killed two workers and injured 80 people. A willful violation was cited for failing to develop clear, written procedures for how to change and put idle pressure vessels into service. The five (5) serious and one (1) willful violations include:
PLEASE NOTE: these citations are NOT the final settlement and some are BEFORE the employer’s informal conference. They are shared as a learning tool to show what types of issues OSHA and EPA are finding in their PSM/RMP inspections. I have scrubbed all company information from these postings as this is NOT about any one company, but rather a trend of issues that continue to be found by OSHA and EPA.
Citation 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 1910.119(d)(l)(vii): The employer did not describe the hazardous effects of inadvertent mixing different materials that could foreseeably occur.
The employer does not describe in the process safety information the hazardous effects of inadvertently mixing hot water with propylene which may occur due to a rupture or failure of the reboilers (EA 425 A and/or EA 425 B) tubes or leaking of the process inflow valve.
Citation 1 Item 2
Type of Violation: Serious; $7,000
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices.
a) The employer does not ensure compliance with recognized and generally accepted good engineering practices (RAGAGEP-ASME BPVC Section 8, Div 1, UG-125 (a)1-3)), specifically operating and maintaining process vessels without overpressure protection. EA-425B was exposed to process conditions through the introduction of quench water without an open relief path or pressure relief device.
b) The employer does not ensure compliance with recognized and generally accepted good engineering practices (RAGAGEP-API 521-paragraph 2.3.15) in that EA-425B did not have a pathway to relief in the event of exposure to fire.
Citation 1 Item 3
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(3)(i): The employer did not ensure that the process hazard analysis considered the hazards of the process.
The employer did not ensure that the process hazard analysis was appropriate to the complexity of the process which identify, evaluate, and control the hazards involved in the process. This violation was documented on or about June 21 , 2013 , when the employer’s process hazard analysis (July 1996, July 2001, July 2006, and September 2011) for the propylene fractionation area did not address opening the quench water flow to a stand-by reboiler when shell side hydrocarbon residuals may exist through valve leakage.
Citation 1 Item 4
Type of Violation: Serious; $3,000
29 CFR 1910.119(g)(3): Training documentation. The employer did not prepare a record which contained the identity of the employee, the date of training, and the means used to verify that the employee understood the training.
The employer does not prepare a record containing the verification used to determine that the employee understood the training. This violation was documented on or about July 17, 2013 when the process safety training records did not contain a means of verification for three operator technicians.
Citation 1 Item 5
Type of Violation: Serious; $5,000
29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.
Chemical Process Safety Management Compliance Audit (# 5963-5977) was reviewed and it was determined that the employer failed to promptly correct 12 out of 32 recommendations (2010 Compliance Audit #5906-5962) such as but not limited to the following:
A) Recommendation to modifying the alarm settings in the written operating procedures to reflect the minimum/maximum setting for alarms rather than current TDC setting for the alarms remains open.
B) The current fixed equipment program does not address the inspection and thickness testing of small bore piping.
C) No documentation that pipe hangars, supports and insulation were being inspected
These deficiencies are not being corrected in a timely manner.
Citation 2 Item 1
Type of Violation: Willful; $70,000
29 CFR 1910.119(f)(l): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information.
The employer does not ensure that written operating procedures provide clear instructions for safely conducting activities involved in the covered process. This violation occurred on or about June 13, 2013, and at times prior thereto when the employer failed to develop a clear, written procedure to change the service between reboilers EA-425A and EA-425B.
Proposed penalties total $99,000.
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