OSHA has cited a polymers plant for 12 violations, mainly for exposing workers to chemical hazards from solvents used at the plant. The inspection was initiated following a referral from the National Response Center (NRC) due to an incident involving a methyl chloride release at the plant on July 18, 2013. One repeat PSM violation was cited for failing to follow recognized good engineering practices within the MI inspection program. The company failed to resolve data for storage tanks when changes in measurements occurred over previous readings. Eleven serious PSM violations were issued and included violations of PSI, PHA and MI. Employee exposure to methyl chloride and monochlorobenzene were found during the inspection. Here is a breakdown of the PSM citations:
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; $5,000 29 CFR 1910.119(d)(2)(i)(C): Information concerning the technology of the process shall include at least the following: Maximum intended inventory:
a. The employer’s process safety information (PSI) did not include an accurate maximum intended inventory for methyl chloride in the Udel process unit. ·
Citation 1 Item 2
Type of Violation: Serious; $5,500
29 CFR 1910.119(d)(3)(i)(B): Information pertaining to the equipment in the process shall include: Piping and instrument diagrams (P&ID’s):
a. The P&ID (Drawing #886503-2) Polysulfone Unit MeCl Unloading and Storage Facilities Piping & Instrumentation Diagram, revision date on or about July 25, 2013, was not accurate in that
- the maximum capacity and maximum working capacity for C-151 Methyl Chloride Storage Tank was not identified with the correct information;
- the length, capacity, maximum capacity, maximum working capacity, and MAWP for C-101 Methyl Chloride Storage Tank was not identified with the correct information;
- PSV 101 -102 and PSV 101 -103 with atmospheric discharge and no rain caps for the PC-101 methyl chloride storage tank,
- PSV 151 -102 and PSV 151 -103 with atmospheric discharge and no rain caps for the PC-151 methyl chloride storage tank, and
- PSV 104-101 with atmospheric discharge and no rain cap for the G-104 charge pump were identified with rain caps.
Citation 1 Item 3a
Type of Violation: Serious; $5,500
29 CFR 1910.119(e)(3)(i): The process hazard analysis shall address: The hazards of the process:
a. The employer’s 2009 Udel Five Year Process Hazard Analysis (PHA) Revalidation did not address the hazard(s) associated with the unavailability of the following pressure safety valves due to pluggage of the discharge pipe with obstructions such as snow and/or ice:
- PSV 101-102 and PSV 101-103 with atmospheric discharge and no rain caps for the PC-101 methyl chloride storage tank;
- PSV 151-102 and PSV 151-103 with atmospheric discharge and no rain caps for the PC-151 methyl chloride storage tank;
- PSV 104-101 and PSV 104-103 with atmospheric discharge and no rain caps for the PG-104 methyl chloride charge pump
Citation 1 Item 3b
Type of Violation: Serious; GROUPED
29 CFR 1910.119(e)(3)(iv): The process hazard analysis shall address: Consequences of failure of engineering and administrative controls:
a. The employer’s 2009 Udel Five Year Process Hazard Analysis (PHA) Revalidation did not address the consequences of failure for the relief system related to the unavailability of the following pressure safety valves due to pluggage of the discharge pipe with obstructions such as snow and/or ice:
- PSV 101-102 and PSV 101-103 with atmospheric discharge and no rain caps for the PC-101 methyl chloride storage tank;
- PSV 151-102 and PSV 151-103 with atmospheric discharge and no rain caps for the PC-151 methyl chloride storage tank;
- PSV 104-101 and PSV 104-103 with atmospheric discharge and no rain caps for the PG-104 methyl chloride charge pump.
Citation 1 Item 4
Type of Violation: Serious; $5,500
29 CFR 191O.119(j)(2): Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment:
a. In the Udel unit, the written mechanical integrity procedures for pumps did not establish criteria for performing vibration monitoring including definable criteria (acceptable limits) for continued service and/or removal from service for pump PG-104.
b. In the Udel unit, the written mechanical integrity procedures for pumps did not establish and implement the inspection frequency requirements for inspecting pumps.
c. In the Udel unit, the written mechanical integrity procedures for piping systems did not establish and implement criteria for resolving anomalous inspection data related to thickness growth.
d. In the Udel unit, the written mechanical integrity procedures for piping systems did not establish a requirement for a classification system which prioritizes piping inspections based on consequences of failure.
e. In the Udel unit, the written mechanical integrity procedures for piping systems did not establish the inspection frequency requirements for inspecting piping.
f. In the Udel unit, the written mechanical integrity procedures for piping systems did not establish instructions on how to determine corrosion rates.
g. In the Udel unit, the written mechanical integrity procedures for piping systems did not address the calibration of non-destructive test equipment prior to conducting inspections.
h. In the Udel unit, the written mechanical integrity procedures for piping systems did not establish and implement a thickness measurement strategy for establishing thickness measurement locations (TML’s) on piping and for determining the representative number of thickness measurements on each piping circuit.
i. In the Udel unit, the written mechanical integrity procedures for piping systems did not establish criteria for CUI (corrosion under insulation).
j. In the Udel unit, the written mechanical integrity procedures for pressure vessels and storage tanks did not establish and implement criteria for resolving anomalous inspection data related to thickness growth.
k. In the Udel unit, the written mechanical integrity procedures for pressure vessels and storage tanks did not address the calibration of non-destructive test equipment prior to conducting inspections.
I. In the Udel unit, the written mechanical integrity procedures for pressure vessels and storage tanks did not establish and implement a thickness measurement strategy for establishing thickness measurement locations (TML’s) on pressure vessels and for determining the representative number of thickness measurements performed to satisfy requirements for internal inspections.
m. In the Udel unit, the written mechanical integrity procedures for pressure vessels and storage tanks did not establish criteria for CUI (corrosion under insulation).
n. In the Udel unit, the written mechanical integrity procedures for pressure vessels did not establish instructions on how to determine corrosion rates.
Citation 1 Item 5
Type of Violation: Serious; $5,500
29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:
a. In the Udel unit, the preventative maintenance inspections such as the oil change was not performed at least every 6 months according to the frequency established by the manufacturer’s user instruction manual for the methyl chloride charge pump, PG-I 04.
b. In the Udel unit, thickness measurements were not performed according to the frequency established in API 510 and were overdue as identified on the thickness inspection dated on or about December 18, 2008, for the methyl chloride storage tank, PC-151.
Citation 1 Item 6
Type of Violation: Serious; $5,500
29 CFR 1910.119(j)(5): Equipment deficiencies. The employer shall correct deficiencies in equipment that are 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 are taken to assure safe operation:
a. In the Udel unit, the employer did not correct the deficiency of line sag and the lack of support below TML No. 8 for Piping Circuit PP-3066-l .5-1J3 as identified with the recommendation to install shims in piping inspection reports dated on or about June 2, 2009 and October 23, 2013.
b. In the Udel unit, the employer did not correct the deficiency of the lack of support North of TML No. 19 for Piping Circuit PP-074-1.5-IBS as identified with the recommendation to install supports in piping inspection reports dated on or about December 26, 2002; January 12, 2010; and October 29, 2013.
Citation 1 Item 7
Type of Violation: Serious; $5,500
29 CFR 1910.119(l)(2)(ii): The procedures shall assure that the following considerations are addressed prior to any change: Impact of change on safety and health:
a. The management of change, MOC #6304 – Temp removal of power to PZI 104-07 and PZI 104-08, did not effectively address the impact of change on safety and health prior to the change.
Citation 1 Item 8a
Type of Violation: Serious; $5,500 29 CFR 1910.119(l)(2)(iii): The procedures shall assure that the following considerations are addressed prior to any change: Modifications to operating procedures:
a. The management of change, MOC #6304 -Temp removal of power to PZI 104-07 and PZI 104-08, did not address modifications to operating procedures.
Citation 1 Item 8b
Type of Violation: Serious; Corrected During Inspection
29 CFR 1910.119(l)(5): If a change covered by this paragraph results in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices shall be updated accordingly:
a. The Raw Material Handling operating procedure, Document Number 01.01.30, section 4.5.4.4, was not updated when the power was removed and the rupture disk burst sensor alarms, PZI l 04-07 and PZI 104-08, were disabled; and the practice of inspecting tell-tale gauges was implemented on or about March 7, 2012.
Citation 1 Item 9
Type ofViolation: Serious; $5,500
29 CFR 1910.119(l)(3): Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the process or affected part of the process:
a. The employer did not ensure that operators and maintenance employees in the Udel process and other areas of the facility were trained in and informed of the changes prior to start-up of the affected part of the process including, but not limited to, the following management of changes:
- MOC #6304 – Temp removal of power to PZI 104-07 and PZI 104-08;
- MOC #7225 – Udel 00.03.07 Loss of Utilities;
- MOC #6874 – Radel Evaluate Y-1525 Lid Chain-falls and Monorails;
- MOC #7167 – UE-1133 Fan Blade Replacement;
- MOC #7173 – Install Teflon Spacers for TOX Hoses;
- MOC #7221 – Install Peristaltic Bleach Pump for Cooling Tower;
- MOC #7239 – Burner Insertion Tube Metallurgy Upgrade; MOC #7331 – TMOC-MLI 525-01 Replace Transmitter;
- MOC #7327 – Eliminate Flex Hoses in MG-630DD Lube Oil Piping; and
- MOC #7328 – Transformation Project T26: Filter Feed Control Improvements.
Citation 2 Item 1
Type of Violation: Repeat; $27,500
29 CFR 1910.119(j)(4)(ii): Inspection and testing procedures shall follow recognized and generally accepted good engineering practices:
a. In the Udel unit, the employer did not follow recognized and generally accepted good engineering practices (RAGAGEP) when it failed to resolve anomalous data for pressure vessels PC-I 0 I and PC-151, methyl chloride storage tanks, such as increasing thickness measurements over previous readings, with no explanations as to how this might have occurred in the inspection/testing records.
The business was previously cited for a violation of this occupational safety and health standard 29 CFR 1910.119(j)(4)(ii), which was contained in OSHA inspection number 108902, citation number 1, item number 2 and was affirmed as a final order on March 12, 2012, with respect to a workplace located in Marietta, Ohio.
Members can CLICK HERE for the actual citations.