OSHA has cited a Louisiana chemical facility with 10 serious and one other-than-serious violations related to OSHA’s process safety management standard (PSM) with proposed penalties totaling $67,000. OSHA conducted the inspection under the PSM National Emphasis Program (NEP). The ten serious violations include failing to provide accurate process safety information for P&IDs, use the appropriate detection methodologies in the process hazard analysis and properly complete emergency shutdown procedures, repair or maintain pressure-relieving devices and conduct management of change while maintaining process equipment. Here is break down of the 11 citations…
Process Safety Information
- P&IDs not being updated; Serious, $5,000
- The Vinyl Chloride (VCM) plant failed to update a P&ID after the removal of an orifice plant with meter run.
- The Vinyl Chloride (VCM) plant failed to update P&IDs to reflect newly installed Car Seals/Mechanical locking devices on intervening stop valves
- Relief System Design Basis; Serious, $7,000
- PSI data does not include design calculations for six (6) pressure vessels and relief valves in the VCM unit
- Did not document equipment complied with RAGAGEPs
- Did not comply with RAGAGEP by failing to provide adequate controls to ensure that intervening stop valves on upstream and downstream from relief devices remained in the open position during operation, as spelled out in Appendix M of 2007 ASME Section VIII, Division 1
- PSI did not include the design codes and standards employed; Other-than-Serious, $1,000
- PSI did not list the design codes for the safety interlock systems within the VCM unit;
Process Hazards Analysis
- PHAs did not meet the complexity of the process; Serious, $7,000
- 2009 PHA did not identify, evaluate, and control a process hazard, the inadvertent mixing of chlorine and VCM due to reverse/other flow of chlorine into the VCM column
- 2009 PHA did not address highly hazardous chemicals relieving to an unsafe location. Ethylene, Ethyl chloride, chloroform, ethylene dichloride relieving through an incinerator bypass valve to an area where workers could be working
- 2009 PHA did not address Human Factors associated with closing two (2) specific valves during emergency situations
- 2009 PHA failed to recognize and evaluate the lack of appropriate safeguards to ensure that 16 relief valves did not have their capacity diminished or eradicated by intervening stop valves.
- 2009 PHA assumed relief devices were adequate; Serious, $7,000
- Four (4) relief devices were listed as safeguards in the 2009 PHA before the facility had determined they could provide adequate relief protection
- 2009 PHA did not address Facility Siting; Serious, $7,000
- 2009 PHA did not address encroachment of Chlorine gas into the VCM control room
Operating Procedures
- SOPs did not provide clear instructions for safely conducting activities involved in each covered process; Serious, $7,000
- The VCM Column Emergency Shutdown SOP did not include shutting off the chlorine vaporizer feed by manual control and by a console controlled flow controller.
- SOPs did not address precautions necessary to prevent exposures, including engineering controls, administrative controls, and PPE; Serious, $7,000
- SOPs do not address any controls (i.e. detection device or other method) for the prevention of intrusion of chlorine gas into the VCM control room.
- SOPs did not address safety systems and their function(s); Serious, $5,000
- No operating procedures for the administrative control of car seals/mechanical locking elements on intervening stop valves in the up stream and down stream lines to/from 13 relief devices
Mechanical Integrity
- Did not correct deficiencies in equipment that are outside the acceptable limits as defined by the PSI before further use or in a safe or timely manner when necessary means are taken to assure safe operation; Serious, $7,000
- a relief device identified in a 1999 relief study as being undersized for a fire scenario had not been corrected
- two (2) relief devices identified in a 1999 relief study as being undersized for a “loss of cooling water” scenario had not been corrected
- a relief device identified in a 1999 relief study as being undersized for a blocked outlet scenario had not been corrected. The 1999 relief study indicated that both relief devices together could sufficiently relieve if BOTH relief valves car sealed OPEN but one relief valve was car-sealed closed
- two (2) relief devices identified in a 1999 relief study as being undersized for a control valve failure scenario had not been corrected
- a relief device identified in a 2005 relief study as being undersized for a for a fire scenario had not been corrected
- a relief device identified in a 2004 relief study as being undersized for a for a fire scenario had not been corrected
- pressure relief calculations were incomplete due to insufficient information and the engineers report stated the valve was undersized for the fire scenario
Management of Change
- Did not ensure written procedures to manage changes were implemented; Serious, $7,000
- failed to to a MOC for changing a chlorine control loop containing a chlorine flow meter
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