OSHA Inspection: W.R. GRACE & COMPANY

Issued

Jul 31, 1992

Abate by

Sep 2, 1992

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

The employer is not limited to abatement methods suggested by OSHA,
i.e., methods explained are general and may not be effective in all
cases. Other methods of abatement may be equally or more appropriate.
Ultimate responsibility for determining the most appropriate abatement
method rests with the employer, given its superior knowledge of the
specific conditions on this worksite.
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 fire and explosion:
(a)  The employer did not protect its' employees from the
recognized hazard of fire and explosion in that pipes
located between the nitromethane distillation column
VA-311 and routed through the pipe rocks to the
nitromethand storage tank TA-507 was not provided with
a method to limit the pressure to 100 psi or less
Feasible abatement methods to correct this condition
may include, but are not limited to installing pressure
relief devices at appropriate location in the nitromethane
piping.
(b)  The employer did not protect its' employees from the
recognized hazard of fire and explosion in that:
1.      adequate fixed fire suppression equipment was not
provided in the Area 200 (Purification) and Area
300 (Distillation).
Feasible abatement methods to correct this condition
may include, but are not limited to, providing
Automatic Sprinklers/Deluge System to the following:
a. in the 300 Area to protect the distillation columns;
b. in the entire 200 area; and
c. in the area north of the 200 Area to protect the
wet and dry nitroparaffin surge tanks and their
associated pumps.
2.      sprinkler/deluge systems were not automatically
actuated
but instead, required manual actuation.
Feasible abatement methods to correct this condition
may
include, but are not limited to, converting the
existing
manually or remote manually activated deluge systems
to
automatic operation. Actuation should be by a fixed
temperature detection system such that it automatically
actuates the deluge system. Detection and actuation
circuits should be supervised. The following systems
would
be affected:
a. Reactor Area - liquid/liquid separator, 100 Area,
remote manually operated at the control room or
manually at the riser;
b. Distillation Area - acetone and drying columns, 200
Area, remote manually operated at the control room
or manually at the riser; and,
c. Hydrocarbons Area - 1 - and 2-nitropropane columns,
300 Area, remote manually operated at the control
room or manually at the riser.

Issued

Jul 31, 1992

Abate by

Sep 2, 1992

Penalty

Initial $5,000

Issued

Jul 31, 1992

Abate by

Sep 2, 1992

Penalty

Initial $2,500

Issued

Jul 31, 1992

Abate by

Sep 2, 1992

Penalty

Initial $5,000

Issued

Jul 31, 1992

Abate by

Sep 2, 1992

Issued

Jul 31, 1992

Abate by

Aug 5, 1992