OSHA Inspection: ARCADIAN CORPORATION

Issued

Feb 25, 1991

Abate by

Jan 31, 1992

Penalty

Initial $700 · Current $700

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 CASUING OR LIKELY TO CAUSE DEATH
OR SERIOUS PHYSICAL HARM TO EMPLOYEES IN THAT EMPLOYEES WERE EXPOSED TO
THE RECOGNIZED HAZARD OF FIRE AND EXPLOSION. SPECIFICALLY:
A) ADEQUATE PRECAUTIONS WERE NOT TAKEN TO PREVENT EXPLOSIONS, SUCH AS
OCCURRED ON OCTOBER 15, 1990, WITHIN THE VAPOR SPACE OF THE MEA
STORAGE TANK IN THE NITROGEN AREA OF THE FERTILIZER MANUFACTURING
PLANT DUE TO THE PRESENCE OF HYDROGEN GAS IN EXPLOSIVE
CONCENTRATIONS.
FEASIBLE METHODS OF ABATEMENT INCLUDE BUT MAY NOT BE LIMITED TO THE
FOLLOWING:
1) CONDUCT INTERNAL AUDITS THAT INCLUDE ITEMS SUCH AS A PROCESS HAZARD
REVIEW, A JOB SAFETY ANALYSIS OR A HUMAN FACTORY ANALYSIS OF THE
FERTILIZER PLANT OPRATIONS BY ADDRESSING SAFETY FACTORS IN, FOR
EXAMPLE, A GENERAL HAZARD AND OPERABILITY STUDY (HAZOP), (WHAT IF),
(CAUSE/CONSEQUENCE), (FAULT TREE), ETC., SUCH A REVIEW SHALL BE A
STRUCTURED METHOD OF SYSTEMATICALLY INVESTIGATING EACH ELEMENT OF
A PROCESS DESIGN, TO IDENTIFY ALL OF THE WAYS IN WHICH DEVIATIONS
CAN OCCUR FROM INTENDED PROBLEMS, AND SHALL INCLUDE, BUT NOT
NECESSARILY BE LIMITED TO, THE FOLLOWING:
A) PREPARATION AND REVIEW OF PROCESS FLOW SHEETS TO DETERMINE POSSIBLE
EMERGENCIES DURING START-UP, NORMAL OPERATING AND SHUTDOWN CONDITIONS
AND TO EVALUATE THE CONSEQUENCES OF EXCESSIVE TEMPERATURES AND
PRESSURES OR VARIATIONS IN MATERIAL CONTROLS.
B) PREPARATION AND REVIEW OF A PIPING AND INSTRUMENTATION DIAGRAM (P&ID)
TO ASSURE THAT CONTROLS AND INSTRUMENTATION WILL DETECT UNUSUAL
CONDITIONS AND THAT THE SYSTEM WILL AUTOMATICALLY SHUT DOWN IN THE
EVENT OF OPERATOR EQUIPMENT ERROR.
C) REVIEW OF RAW MATERIAL MSDS (MATERIAL SAFETY DATA SHEETS), PRODUCT
BULLETINS, TECHNICAL AND SCIENTIFIC LITERATURE CONSIDERING FIRE,
EXPLOSION, HEALTH, STABILITY AND REACTIVITY CHARACTERISTICS INCLUDING
HANDLING, STORAGE, EMERGENCY PROCEDURES AND SPECIAL PRECAUTIONS.
D) REVIEW OF OPERATING DESIGN AND POTENTIAL FOR OPERATIONAL ERRORS
CONSIDERING DETAILED OPERATING DESCRIPTIONS AND STANDARD OPERATING
PROCEDURES; ACCURACY AND READIBILITY OF CONTROL INSTRUMENTATION AND
OPERATOR TRAINING IN PROCESS CHEMISTRY, HAZARDS AND OPERATIONAL
PROCEDURES.
2) EMPLOY A FEASIBLE AND USEFUL METHOD SUCH AS REDESIGNING THE PROCESS
SYSTEMS TO PROVIDE FOR STORAGE TANKS WITH CONTINUOUS PURGE AND/OR
VENTING SO THAT HYDROGEN GAS CONCENTRATIONS CANNOT RISE TO THE LOWER
FLAMMABLE LIMIT.
3) EMPLOY FEASIBLE AND USEFUL METHODS SUCH AS REDESIGN OF LIQUID
TRANSFERINTO TANKS WHICH WILL ELIMINATE IGNITION SOURCES SUCH AS
STATIC ELECTRICITY GENERATED BY ALLOWING LIQUIDS TO FALL FREELY
THROUGH THE VAPOR SPACE OF THE TANK.

Issued

Feb 25, 1991

Abate by

Oct 31, 1991

Penalty

Initial $800 · Current $800

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 EMPLOYEES WERE EXPOSED TO
THE RECOGNIZED HAZARDS OF FIRE EXPLOSION, MISSILES AND EXPOSURE TO TOXIC
CHEMICALS. SPECIFICALLY:
A) ADEQUATE PRECAUTIONS WERE NOT TAKEN TO PROTECT EMPLOYEES FROM FIRE,
EXPLOSION, MISSILE AND TOXIC CHEMICAL EXPOSURE HAZARDS IN THE AMMONIA
PROCESS CONTROL ROOM WHICH HAS A WINDOW ON WEST WALL WHICH MEASURES
APPROXIMATELY 4' 4" BY 17' 8" AND A WINDOW ON THE EAST WALL WHICH
MEASURES APPROXIMATELY 4' 4" BY 16' 4", IN THAT A FIRE, EXPLOSION,
MISSILE AND/OR TOXIC CHEMICAL FROM AN EXPLOSION OF VESSELS LOCATED
AS CLOSE AS 25', CALCULATED TO HAVE AN EQUIVALENT EXPLOSIVE FORCE
WHICH COULD RANGE AS HIGH AS 10 TO 50 POUNDS OF TNT, WOULD DESTROY
THE WINDOWS EXPOSING THE CONTROL ROOM EMPLOYEES TO SERIOUS INJURIES.
GENERAL METHODS OF CONTROL INCLUDE BUT MAY NOT BE LIMITED TO THE
FOLLOWING:
1) PERFORM AN ANALYIS OF CONTROL ROOM SAFETY FACTORS AND DESIGN USING
FOR EXAMPLE, A GENERAL HAZARD AND OPERABILITY STUDY (HAZOP),
(WHAT IF), (CAUSE/CONSEQUENCE), (FAULT TREE), ETC., SUCH A REVIEW
SHALL BE A STRUCTURED METHOD OF SYSTEMATICALLY INVESTIGATING EACH
ELEMENT OF THE PROCESS DESIGN, TO IDENTIFY ALL OF THE WAYS IN WHICH
DEVIATIONS CAN OCCUR FROM INTENDED DESIGN PARAMETERS TO CREATE
HAZARDS OR OPERABILITY PROBLEMS, AND INCLUDES BUT NOT NECESSARILY
BE LIMITED TO, THE FOLLOWING:
A) REVIEW OF RAW MATERIAL MSDS (MATERIAL SAFETY DATA SHEETS), PRODUCTS
BULLETINS TECHNICAL AND SCIENTIFIC LITERATURE CONSIDERING FIRE,
EXPLOSION, HEALTH, STABILITY AND REACTIVITY CHARACTERISTICS INCLUDING
HANDLING, STORAGE, EMERGENCY PROCEDURES AND SPECIAL PRECAUTIONS.
B) REVIEW MATERIALS PRESENT AND TYPES OF REACTIONS OCCURRING, OPERATING
PRESSURES AND TEMPERATURES, QUANTITIES OF MATERIAL PRESENT IN THE
EQUIPMENT OR THAT COULD BE RELEASED, CALCULATE THE EXPLOSIVE FORCE
THAT WOULD RESULT FROM VESSEL EXPLOSIONS AND COMPARE TO THE TYPE AND
STRENGTH OF THE CONTROL ROOM CONSTRUCTION AND THE LOCATION OF THE
CONTROL ROOM IN REFERENCE TO THE EQUIPMENT, INCLUDING RELIABILITY
IN THE EVENT OF AN EXPLOSION, FIRE PROTECTION FACILITIES PROVIDED,
AND PRESENCE OF IGNITION SOURCES IN PROXIMITY TO THE CONTROL ROOM.
2) BASED ON THE ANALYSIS INDICATED IN PARAGRAPH (1) ABOVE, INSTITUTE
MEASURES TO REMEDIATE DEFICIENCIES IN MATERIALS OF CONSTRUCTION OF
PLANT STRUCTURE AND/OR RELOCATE STRUCTURE(S) CRITICAL TO SAFE PLANT
OPERATIONS TO AREAS WHICH WOULD REMAIN UNAFFECTED BY THE FORCE OF
POTENTIAL EXPLOSIONS.

Issued

Feb 25, 1991

Abate by

Aug 31, 1991

Penalty

Initial $800 · Current $800

General-duty citation text

SECTION 5(A)(1) OF THE OCCUPATONAL SAFETY AND HEALTH ACT OF 1970: THE
EMPLOYER DID NOT FURNISH EMPLOYMENT AND A PLACE OF EMPLOYMENT WHICH WERE
FREE FROM RECOGNIZED HAZARDS THAT WER ECAUSING OR LIKELY TO CAUSE DEATH
OR SERIOUS PHYSICAL HARM TO EMPLOYEES IN THAT EMPLOYEES WERE EXPOSED TO
THE RECOGNIZED HAZARD OF FIRE/EPLOSION AND EXPOSURE TO HAZARDOUS
MATERIALS. SPECIFICALLY:
A) EMPLOYEES WERE EXPOSED TO FIRE/EXPLOSION AND TOXIC CHEMICAL EXPOSURE
HAZARDS OF HYDROGEN AND AMMONIA WHERE PROCESS VESSELS, SUCH AS BUT
NOT NECESSARILY LIMITED TO HORTON SPHERE #2, AMMONIA SEPARATOR
#050-SE-114, AMMONIA SEPARATOR #050-SE-116, AMMONIA SEPARATOR
#050-SE-110, AND AMMONIA FLASH TANK #050-FT-291, WERE NOT INSPECTED
FOR CORROSION (INCLUDING STRESS CRACKING) ON A REGULAR BASIS AND FOR
WHICH CORROSION INSPECTION RECORDS WERE NOT PROPERLY MAINTAINED.
AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO
CORRECT THIS HAZARD WOULD INCLUDE:
ESTABLISH AN INSPECTION PROGRAM SUCH AS THAT STIPULATED BY API 510-1989
AMERICAN PETROLEUM INSTITUTE'S PRESSURE VESSEL INSPECTION CODE.
ESSENTIAL ELEMENTS OF THE INSPECTION PROGRAM WOULD INCLUDE:
1) INSPECTION FREQUENCIES, AND METHODOLOGY IN DETERMINING INTERVALS:
A) GENERALLY, A MAXIMIM INTERVAL FOR INTERNAL INSPECTION OF PRESSURE
VESSEL IS 10 YEARS OR ONE HALF THE CORROSION LIFE, WHICH EVER IS
LESS
2) MAINTAIN PERMANENT AND PROGRESSIVE CORROSION INSPECTION RECORDS.

Issued

Feb 25, 1991

Abate by

Jan 21, 1992

Penalty

Initial $800

Issued

Feb 25, 1991

Abate by

Jan 21, 1992

Issued

Feb 25, 1991

Abate by

Jan 21, 1992

Issued

Feb 25, 1991

Abate by

Jan 21, 1992

Issued

Feb 25, 1991

Abate by

Apr 30, 1992

Penalty

Initial $800 · Current $1,000

Issued

Feb 25, 1991

Abate by

Nov 30, 1991

Penalty

Initial $800

Issued

Feb 25, 1991

Abate by

Apr 30, 1992

Penalty

Initial $800 · Current $2,000

Issued

Feb 25, 1991

Abate by

Nov 30, 1991

Penalty

Initial $800

Issued

Feb 25, 1991

Abate by

Jan 21, 1992

Issued

Feb 25, 1991

Abate by

Jan 21, 1992

Penalty

Initial $800 · Current $700 Reduced

Issued

Feb 25, 1991

Abate by

Jan 2, 1992

Penalty

Initial $700

Issued

Feb 25, 1991

Abate by

Jan 2, 1992

Issued

Feb 25, 1991

Abate by

Jan 2, 1992

Penalty

Initial $800

Issued

Feb 25, 1991

Abate by

Jan 2, 1992

Issued

Feb 25, 1991

Abate by

Oct 31, 1992

Penalty

Initial $9,000 · Current $10,000

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 REOGNIZED HAZARDS THAT WERE CAUSING OR LIKELY TO CAUSE DEATH
OR SERIOUS PHYSICAL HARM TO EMPLOYEES IN THAT EMPLOYEES WERE EXPOSED TO
FIRE, EXPLOSION, STEAM AND CHEMICAL BURNS AND TOXIC VAPOR HAZARDS FROM:
A) SAFETY RELIEF VALVE STACK WHICH WOULD RELEASE AMMONIA FROM THE
STORAGE REFRIGERATION COMPRESSOR AND THE AMMONIA CONDENSER AT THE
NORTH SIDE DIKE OF THE STORAGE FACILITIES INTO THE WORK AREA;
B) SAFETY RELIEF VALVE WHICH WOULD RELEASE HYDROGEN GAS AT WASTE HEAT
BOILER E-307 INTO WORK AREAS.
C) TWO SAFETY RELIEF VALVES WHICH WOULD RELEASE STEAM AT WASTE HEAT
BOILER E-307 INTO WORK AREAS.
D) TWO SAFETY RELIEF VALVES WHICH WOULD RELEASE HYDROGEN AT THE LOW
TEMPERATURE SHIFT CONVERTER INTO WORK AREAS.
E) SAFETY RELIEF VALVE WHICH WOULD RELEASE MEA AT MEA FLASH TANK V-307
INTO WORK AREAS.
F) SAFETY RELIEF VALVE WOULD RELEASE HYDROGEN AT METHANATOR FEED/
EFFLUENT HEAT EXCHANGER E-310 INTO WORK AREAS.
G) SAFETY RELIEF VALVE WHICH WOULD RELEASE AMMONIA AT THE UREA
PRIMARY ABSORBER INTO WORK AREAS.
H) SAFETY RELIEF VALVE WHICH WOULD RELEASE AMMONIA AT THE UREA
SECONDARY ABSORBER INTO WORK AREAS.
I) SAFETY RELIEF VALVE WHICH WOULD RELEASE AMMONIA AT THE UREA HIGH
PRESSURE OFF GAS SEPARATOR INTO WORK AREAS.
J) SAFETY RELIEF VALVE WHICH WOULD RELEASE AMMONIA AT THE UREA
PRIMARY DECOMPOSER SEPARATOR INTO WORK AREA.
K) SAFETY RELIEF VALVE WHICH WOULD RELEASE AMMONIA AT THE UREA
SECONDARY DECOMPOSER SEPARATOR INTO THE WORK AREAS.
L) SAFETY RELIEF VALVE WHICH WOULD RELEASE MEA AT THE UREA MEA
RECLAIMER INTO WORK AREAS.
M) THREE SAFETY RELIEF VALVES WHICH COULD RELEASE HYDROGEN OFF
TRAIN I COMPRESSORS INTO WORK AREAS.
N) SAFETY RELIEF VALVES WHICH WOULD RELEASE AMMONIA AT THE UREA
PRIMARY DECOMPOSER AMMONIA SEPARATOR (SE-150) INTO THE WORK AREA
AMONG OTHER METHODS, FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT
THESE HAZARDS IS:
1) TO DISCHAGE SAFETY RELIEF VALVE VENTS TO A SAFE LOCATION,
2) ASSURE THAT THE DISCHARGE VENTS CANNOT BE DIVERTED INTO WORK AREAS,
AREAS, AND
3) ADD WATER/STEAM DILUTION SYSTEMS TO THE DISCHARGE VENTS WHERE SOLIDS
FORMATION PRESENTS POTENTIAL FOR PLUGGING.

Issued

Feb 25, 1991

Abate by

Jan 21, 1992

Penalty

Initial $100

Issued

Feb 25, 1991

Abate by

Jan 21, 1992

Issued

Feb 25, 1991

Abate by

Jan 21, 1992