OSHA Inspection: E. I DUPONT DENEMOURS AND COMPANY, INC.

Issued

1991-12-03 00:00:00

Abate by

1992-01-07 00:00:00

Penalty

Initial $1875.00 · Current $1875.00

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not furnish employment and a place of employment which
were free from recognized hazards that were causing or likely to cause
death or serious physical harm to employees in that on June 6, 1991
employees in the area of the MRC feed tank were exposed to fire/explos-
ion and toxic inhalation hazards due to chemical release from the
Methylamines synthesis process, amines MRC Feed tank in which during
the incident, the alert level was raised from minor event to standby
notification by the employer and caused the freeway into the plant shut
off.  The following conditions contributed to the potential exposure:
a.   Maintenance and operating did not ensure control
of leakage, accidental escape, and employer exposure
to toxic flammable gas/liquid in that through lack
of maintenance, the automatic steam control valve to the
MRC feed tank heater failed to fully close off the steam
due to a wron indentation or groove in the seat of the
valve.  Both of which could have been recognized during
maintenance.
b.   The recycle tank level instrument device did not have
its span properly set therefore causing the tank to read
85% when the tank was 100% full.
c.   The employee while closing the manual steam valve subsequent
to the chemical release was not equipped with respiratory
protection appropriate for the location and the atmosphere
was not tested in the immediate area for air contaminants
prior to this action.
d.   Due to inadequate training, operators could not recognize
that the automatic steam control valve was still leaking
when the pressure in the MRC Feed tank did not decrease
promptly, after instrumentation showed the valve to be
0% closed.
e.   Written procedures do not address in a worse case
scenario, at what point during an emergency the process
should be shut down.
Feasible abatement methods, among others, include but are not limited
to:
1.   Appropriate preventive maintenance on automatic and other
valves to recognize in advance potential breakdowns of the
valves.
2.   Selection of a valve which would ensure a tighter shut-off
and which is fail safe.
3.   Appropriate training of area personnel in recognition of
potential problems with the system.  For example when the
automatic steam control valve signaled 0%, the pressure
in the MRC Feed tank continued to rise, it was not
recognized that steam was more than likely still getting
to the process and to shut off the manual steam control
valve.
4.   Revise emergency shut down procedures to indicate those
instances during an emergency situation when the system
should be shut down.
5.   Set the span on the recycle tank level device so that it
reads accurately.