OSHA Inspection: HULS AMERICA

Issued

Oct 17, 1991

Abate by

Nov 4, 1991

Penalty

Initial $4,250

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 rebase of Methyldichlorosilane from storage tank S-440.  The storage
tank S-440 is located outside in the tank farm without any protection
against radiant heat which could cause an increase of internal  pressure
in the tank and which could result in the discharge of the safety relief
valve; therefore releasing Methyldichlorosilane to the atmosphere and
exposing the employees to chemical burns, damage to lungs, serious eye
injuries, serious systemic injury and even death.
Feasible abatement methods include, but not limited to the following:
1.  Insulation of the tank to protect against radiant heat.
2.  Installation of a heat exchange.

Issued

Oct 17, 1991

Abate by

Dec 12, 1991

Penalty

Initial $4,250 · Current $3,188 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
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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 release of Methyldichlorosilane from storage tank S-440 pressure gauges
to detect pressure inside the vessel and nitrogen pressure were not
operable and functioning properly.  Inspection and testing programs for
critical equipment were not established.
Feasible abatement methods include, but not limited to the following:
1.  A list of critical equipment and systems that are subject to testing
and inspection.  This list should include pressure vessels and storage
tanks, critical piping, relief systems and devices, emergency shutdown
systems, and critical controls, alarms and interlocks.  This list should
specify the method and frequency of testing and inspection, acceptable
limits and critical for passing the test or inspection.
2.  Testing and inspection procedures that follow commonly accepted
standards and codes such as APR 510 or the API Guide for Inspection of
Refinery Equipment (3).
3.  Documentation of completed testing and inspection, in general, to
assist in determining any needed changes in the frequency of testing,
inspection, and preventive maintenance, documentation should be retained
for the life of the equipment.
4.  Procedures to correct equipment deficiencies or operations that are
outside acceptable limits.
5.  A system for reviewing and authorizing changes in tests and
inspections.

Issued

Oct 17, 1991

Abate by

Nov 4, 1991

Penalty

Initial $4,250 · Current $3,188 Reduced

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 release of methlydichlorosilane vapors, which upon contact with
air, forms hydrogen chloride (HCl).
%%
On or about May 11, 1991, employees working adjacent Tank S-440 were
exposed to hydrogen chloride (HCl) vapors which were released during
venting from the emergency relief vent system into the atmosphere.
Contractor employees were working approximately 25 feet from the
emergency relief vent during construction operations.
%%
One feasible and acceptable method of abatement could be to follow
the recommendations contained in "working Paper on Control of Major
Hazards in Industry and Prevention of Major Accidents", Tripartite
Ad Hoc Meeting of Special Consultants on Methods of Prevention of
Major Hazards in industry, Section 3.1.2 "protective Devices":
Protective devices may include pressure/vacuum relief valves, bursting
discs, emplosion vents, high/low-level alarms, high/low temperature
alarms, weight tables, contents gauges, maximum fill devices and
many forms of instrumentation.  Any pressure relief system should vent
to a safe place, e.g., into a suitable tank which can contain the
released contents, or through suitable treatment systems, e.g.,
scrubbers, which render the released materials safe, or directly to
an area where nobody can be adversely affected by the release.
%%

Issued

Oct 17, 1991

Abate by

Nov 4, 1991

Penalty

Initial $4,250 · Current $3,188 Reduced

Issued

Oct 17, 1991

Abate by

Nov 4, 1991

Penalty

Initial $4,250