OSHA Inspection: QUANTUM CHEMICAL COMPANY

Issued

Mar 9, 1990

Abate by

Mar 12, 1990

Penalty

Initial $1,000

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 recognized hazards that were causing or likely to cause death
or serious physical harm to employees in that employees were exposed to
serious hazards including being struck, crushed, burned or asphyxiated
resulting from increased likelihood of catastrophic failure of
improperlyand inadequately maintained pressure vessels and power
piping. The employer failed to establish, properly implement and manage
an effective program of pressure vessels and power piping safety
including maintenance inspections, rating, repair, alterations and/or
replacement. In addition, appropriate records necessary for informed
decision making, documenting pressure vessels and power piping actual
conditiongs were not prepared, retained, or made available for
inspection.
Employees working throughout the ethylene unit were exposed to these
hazards on a daily basis including September 12, 1989, when a heat
exchanger, EA 405, exploded and released flammable gas, vapor and/or
liquid.
A feasible and useful method of correcting these hazards related to
pressure vessel and piping rupture and failure is to establish and
properly implement an effective program including maintenance inspection
rating, repair and alterative and/or replacement of pressure vessels,
piping, and their associated safety devices. such a program must include
the following elements as a minumun:
1) Ensure that persons who are authorized to peform and interpret
Nondestructive Testing (NDE) are qualified to American Society of
Nondestructive Testing (ASNT) SNT-TC-1A or equivalent written
requirements or written procedures in accordance with 1989 ASME
Boiler and Pressure Vessel Code Section v.

Issued

Mar 9, 1990

Abate by

Mar 12, 1990

Penalty

Initial $1,000 · Current $1,200

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
employer did not furnish employment which were free from recognized
hazards that were causing or likely to cause death or serious physical
harm to employees in that the employer did not establish, in the
Ethylene Unit, safe and effective adminsitrative and engineering control
to prevent inadvertant releases of vapors and/or gases during start-up,
production, and shut-down operations to protect employees against the
hazards of fire, explosion, and/or asphyxiation.
Among other methods, one feasible and acceptable abatement method to
correct this hazard is to establish administrative and engineering
controls over the ethylene production process including but not
necessarily limited to the following provisions:
1) Conduct a chemical process system safety review that will identify
process deficiencies and excursions plus estimates of their frequency
and probable consequences. This review shall be of a type generally
recognized in the chemical processing industry (such as What if,
Cause/Consequency, FMEA, HAZOP, Fault Tree, etc.,) and shall include,
but not be limited to the following:
a) Preparation and review of process flow sheets to determine possible
emergencies during start-up, normal operating and shut-down
conditions and to evaluate the consequences of excessive temperatures
and pressures of 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 shutdown
or can be safely shut down in the event of operator or equipment
error.
c) Review of raw material MSDS's, product bullents, technical and
scientific literature considering fire, explosion, health, stability
and reactivity characteristics including handling, storage, emergency
procedures and special precautions.
d) Review of the ethylene manufacturing process considering potential
problems arising from abnormal temperature excursions, pressure
excursions and rates of reaction; improper addition of reactants
including any catalysts and material flow stoppages.
e) Review of operating equipment used in the processing of ethylene and
associated by-products considering the adequacy of design and
fabrication; effects of corrosion, erosion and metal fatigue;
potential for exceeding design limitations; equipment leaks and
spills; equipment malfunctions and failures; plus maintenance, repair
anmd replacement program.
f) Review of operating design and potential for operational errors
considering detailed operating descriptions and Standard Operating
Procedures; accuracy and readability of control instrumentation and
operator training in process chemistry, hazards and operational
procedures.
g) Conduct periodic review of the process system safety analysis to
ensure continual effectiveness of the program.
2) Develop written start-up procedures that include instrument and
control function verification prior to system start-up.
3) Provide training to operators in the hazards of:
a) Low temperatures whenever any part of the system is depressurized
and how to return systems to a safe condition after encountering
extremely low temperatures.
b) Opening remotely commanded valved in excess of ten percent open
prior to commencing any handjacking operations.
4) Provide complete integration of the computerized instrumentation and
control system with the design of the process plant.
5) Establish a clear and comprehensive chain of command and assigned
locations of handle process system excursions. This chain of command
needs to account for safety of personnel, safety of plant and
equipment, locations of data availability, communications capability,
the authority (or lack thereof) for independent action, the
capablilities of the available personnel, the numer of available
personnel, and the need to minimize the hazard associated with the
excursion.

Issued

Mar 9, 1990

Abate by

Mar 26, 1990

Penalty

Initial $1,000 · Current $1,200

Issued

Mar 9, 1990

Abate by

Apr 9, 1990

Issued

Mar 9, 1990

Abate by

Mar 26, 1990

Penalty

Initial $1,000

Issued

Mar 9, 1990

Abate by

Apr 9, 1990

Penalty

Initial $1,000 · Current $500 Reduced

Issued

Mar 9, 1990

Abate by

Mar 26, 1990

Issued

Mar 9, 1990

Abate by

Mar 26, 1990

Issued

Mar 9, 1990

Abate by

Mar 26, 1990

Penalty

Initial $1,000 · Current $500 Reduced

Issued

Mar 9, 1990

Abate by

Mar 26, 1990

Issued

Mar 9, 1990

Abate by

Mar 26, 1990

Issued

Mar 9, 1990

Abate by

Apr 9, 1990

Penalty

Initial $400 · Current $300 Reduced

Issued

Mar 7, 1990

Abate by

Apr 2, 1992

Penalty

Initial $1,000

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 recognized hazards that were causing or likely to cause death
or serious physical harm to employees in that the employer did not
provide an adequately designed positive pressure control room to protect
Ethylene Unit personnel against the inhalation of toxic chemicals such
as benzene and ethylene oxide.
Among other methods, one feasible and acceptable abatement method to
correct this hazard is:
a) Comply with the 1989 National Fire Protection Association Standard,
Chapter 3, for purged and pressurized enclosures for Electrical
Equipment, NFPA 496, and:
1) Install an air filter system that would remove harmful levels of
ethylene oxide, benzee and flammable gases.
2) Install monitors of benzene, ethylene oxide, and oxygen to monitor
air quality. Provide SCBA for escape if harmful levels are reached.
3) Provide ducting for air intake away from the control room to an area
away from the process plant.