In November 2014, a worker was overcome at the chemical manufacturing facility when a supply line unexpectedly released more than 20,000 lbs. of methyl mercaptan, a deadly chemical. Three co-workers came to the worker’s aid in an attempted rescue, but all four were asphyxiated fatally by the colorless, flammable, and highly toxic gas. After the initial investigation into the four deaths, OSHA found hazards that prompted the inspection at the facility to be expanded under the National Emphasis Program for chemical facilities. OSHA issued citations for three willful, one repeat and four serious violations at the chemical manufacturing plant. The agency has proposed penalties of $273,000 for these new violations. OSHA has also placed the company in its Severe Violator Enforcement Program. Here is a breakdown of the 2nd round of citations:
Citation 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 1910.119(d): The employer did not complete a compilation of written process safety information pertaining to the equipment in the process.
a) This violation was most recently observed on or about January 12, 2015 in the Herbicide Business Unit (HBU) when the employer failed to document and maintain the Process Safety Infonnation (PSI) including but not limited to:
- design specification and the materials of construction for the following process piping:
- Line # 211 2511 I 211 2512 (Extractor Pump Tank Overhead to Vacuum Stripper Column)
- Line# 211 3615/ 211 3615A (Vacuum Stripper Seal Pot to F3455 Stripped S/T)
- Line# 311 3204/211 3205 (Crystallizer Outlet to Slurry Hold Tank)
- Line # 311 3151 (Preheater to Concentrator)
This violation was most recently observed on or prior to January 12, 2015 in the HF Unit when the employer failed to document and maintain the Process Safety Information (PSI) including but not limited to:
- design specification and the materials of construction for the following process piping:
- Line# 1526, 211 from drip acid tank vent to middle primary gas cooler.
Citation 1 Item 2a
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(3)(i): The Process Hazard Analysis did not address the hazards of the process.
On or about January 12, 2015, the employer’s process hazard analysis was not appropriate to the complexity of the process in that it did not address and control the hazards of the Hexazinone process. The process hazard analysis did not address potential employee exposure to hazardous chemicals and temperatures resulting from the atmospheric discharge from pressure relief devices on the CHI Condenser Seal Pot and Vacuum Stripper Seal Pot.
Citation 1 Item 2b
Type of Violation: Serious; Grouped
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP).
This violation was most recently observed on or about January 12, 2015, in the Herbicides(Hexazinone) Business Unit when the employer did not document that atmospheric discharge piping from pressure relief devices on the CHI Condenser Seal Pot and Vacuum Stripper Seal Pot relieved to a safe location and complied with (RAGAGEP) such as the ASME Boiler and Pressure Vessel Code, Section VIII.
Citation 1 Item 3
Type of Violation: Serious; $7,000
29 CFR 1910.119(f)(1): The employer did not develop and implement written operating procedures.
This violation was most recently observed on or about January 12, 2015, in the Herbicides (Hexazinone) Business Unit when the employer did not develop and implement written operating procedures for each operating phase of the Vacuum Stripper Preheater (304-352-21).
Citation 1 Item 4
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(2): Written procedures. The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.
On or about January 12, 2015 in the Hydrogen Fluoride Unit (HF) the employer did not establish and implement written procedures to maintain the on-going integrity of process equipment such as lined process piping (e.g. Teflon-lined piping).
Citation 2 Item 1
Type of Violation: Willful; $7,000
29 CFR 1910.119(j)(4)(i): Inspections and tests was not performed on process equipment.
On or about January 12, 2015, in the Herbicide Business Unit (HBU), the employer did not perform inspections and test on process piping, including but not limited to:
- Line# 2″ 2511I2″ 2512 (Extractor Pump Tank Overhead to Vacuum Stripper Column)
- Line# 2″ 3615/ 2″ 3615A (Vacuum Stripper Seal Pot to F3455 Stripped S/T)
- Line# 3″ 3204/2″ 3205 (Crystallizer Outlet to Slurry Hold Tank)
- Line # 3″ 3151 (Preheater to Concentrator)
Citation 2 Item 2
Type of Violation: Willful; $70,000
29 CFR 1910.119(j)(4)(ii): Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.
On or about January 12, 2015, in the Herbicides (Hexazinone) Business Unit, the employer data did not include t-min/t-required and corrosion rate values as stipulated in RAGAGEP such as API 570 and Corporate MI procedures.
Citation 2 Item 3
Type of Violation: Willful; $70,000
29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.
On or about January 12, 2015 in the Herbicides (Hexazinone) Business Unit, the employer did not ensure that the frequency of inspections and tests of process vessels was consistent with applicable manufacturers’ recommendations and good engineering practices for process vessels including but not limited to:
the Crystallizer (304-326-08) and Vacuum Stripper Preheater (304-352-21)
Citation 3 Item 1
Type of Violation: Repeat; $35,000
29 CFR 1910.119(j)(4)(i): Inspections and tests were not performed on process equipment.
This violation was most recently observed in the Hydrogen Fluoride (HF) Unit at XXXXXX Plant located in XXXXXXXX when inspections and tests were not performed on hydrofluoric acid process piping.
The employer did not perform inspections and tests on Line #1526, 2″ from the drip acid tank vent to the middle primary gas cooler.
Company was previously cited for a violation of this Occupational Safety and Health Standard or its equivalent standard 29 CFR 1910.119(j)(4)(i) which is contained in OSHA Inspection Number 313371924, Citation Number 1 Item 2, issued on July 19, 2010 with respect to a workplace located at XXXXXXX Belle, WV. This file became Final Order on August 24, 2010.
CLICK HERE (pdf) for the citations