OSHA Inspection: ASHLAND CHEMICAL CO., DIV OF ASHLAND, INC.

Issued

Sep 25, 1992

Abate by

Oct 27, 1992

Penalty

Initial $2,625

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 hazard of dermal, eye and inhalation exposures to
sulfuric acid resulting from an uncontrolled release of sulfuric acid
from the sulfuric acid module in Building #9.  The following con-
ditions/practices contributed to the existance of this hazard:
The alleged violations below have been grouped because they involve
similar or related hazards that may increase the potential for injury
resulting from an accident.
a)  The system was operated at 55-65 pounds per square inch
pressure (psi), which exceeds the maximum design pressure
for the filter housings on this unit, on or about
September 11, 1992.
b)  Pressure relief devices were not installed to insure
that system operating pressure did not exceed system design
pressure, on or about May 22, 1992.
c)  The system was designed in such a manner which enabled
it to be pressurized to a level above that at which it had
been hydrostatically tested, on or about May 22, 1992.
d)  There was no competent/knowledgeable person on site
who was familiar with filtering module design specifications
for temperature, pressure, flow level or other process
variables and could ensure that the system was safely
operated within design parameters, nor was such design data
readily available at the plant, on or about June 11, 1992.
e)  Subsequent to significant modifications to the filtering
modules and standard operating procedures, a formal
comprehensive safety analyses was not performed to insure these
modifications did not compromise operational safety, on
or about May 22, 1992.
f)  Butt welds made in the Kynar piping of the sulfuric
acid module were made without the use of fixtures/jigs to
align ends of pipes/fitting and ensure the integrity of
the connection, on or about May 22, 1992.
g)  Bonded joints made by Ashland Chemical Co., in the
thermal plastic pipingm, were not made using a qualified
bonding procedure specifications and were not made by
qualified bonders who had pasted a bonding qualification
test as required by ASME B31.3, on or about May 22, 1992.
h)  The hydrostatic test pressure used to leak test the
sulfuric acid module exceeded 1 1/2 times the maximum rated
pressure of the lowest rated component in the system during a
test in fall of 1991 and following an accident, on or about
May 22, 1992.
Among other methods, feasible and acceptable abatement method
to correct this hazard includes:
1.  Operating the system below the maximum recommended pressure for
the millipore filler housing, and installation of a suitable pressure
relief devices to assure that this maximum pressure is not exceeded
in the system.  (Instance a, b, & c).
2.  Obtaining critical engineering and design specifications for the
sulfuric acid module, including design pressure and temperatures and
assuring that the system is operated within these specifications.
(Instance c & d).
3.  Discontinuing pressure testing procedures which utilize test
pressures in excess of 1 1/2 times the maximum rated pressure of the
lowest rated system component.  (Instance h).
4.  Performing a detailed hazard analysis, utilizing a team with
expertise in engineering and process operations and at least one
employee with experience and knowledge specific to the process, being
evaluated, subsequent to significant process modifications.  Such
analyses are particularity critical prior to experimental runs where
standard operating procedures are changed.  (Instance c & e).
5.  Utilizing bonding systems and procedures for thermal plastic
piping that conform to manufactures recommendations and national
consensus standards such as ANSI and ASTM.  (Instance f & g).
6.  Utilizing bonding operators qualified by using these qualification
methods outlined in ANSI B31.3.  These operators must also be
qualified where they have not used bonding equipment within the last
three (3) months.  Qualification records for these individuals should
be maintained.  (Instance f).
7.  Examination of butt welds currently in service using a method
such as radiographic examination or ultrasonic examination to
determine if any joins are poorly made and apt to fail.  (Instance
f & g).

Issued

Sep 25, 1992

Abate by

Oct 2, 1992

Issued

Sep 25, 1992

Abate by

Oct 2, 1992

Issued

Sep 25, 1992

Abate by

Oct 7, 1992