OSHA Inspection: IMC FERTILIZER, INC.

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Mar 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Nov 4, 1991

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Dec 1, 1991

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Mar 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Mar 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Nov 4, 1991

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Nov 4, 1991

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Nov 4, 1991

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Nov 4, 1991

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Nov 4, 1991

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Nov 4, 1991

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Nov 1, 1991

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $5,000 · Current $4,337 Reduced

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $5,000 · Current $4,336 Reduced

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Jan 1, 1992

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.

Issued

Oct 31, 1991

Abate by

Dec 1, 1994

Penalty

Initial $50,000 · Current $43,475 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 hazard of fire and explosion:
A) The employer did not protect its employees from the recognized hazard
of fire and explosion in that pipes containing nitromethane and/or a
nitromethane/nitroethane mixture located in pipe racks in the
nitroparaffin plant were not adequately protected from exposures to
heat and shock.
Feasible abatement methods to correct this condition may include, but
are not limited to, using barricades to protect the piping.
B) The employer did not protect its employees from the recognized
hazard of fire and explosion in that pipes, one-half inch or greater
in diameter containing nitromethane and/or a nitroethane mixture,
located in pipe racks in the nitroparaffin plant were not equipped
with detonation traps.
Feasible abatement methods to correct this condition may include, but
are not limited to, installing detonation traps at appropriate locations
in the nitromethane and nitromethane/nitroethane piping.
C) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the propane bullet, GT-01, was
unsuitable for use due to its material of construction and due to the
closeness of its operating pressure to its design pressure.
Feasible abatement methods to correct this condition may include, but
are not limited to, replacing the propane bullet, GT-01, with a vessel
having adequate ductility and an adequate margin between its operating
pressure and its design limit pressure.
D) The employer did not protect its employees from the recognized hazard
of fire and explosion in that the relief valves for the propane
bullet, GT-01, the vent gas recovery compressor, RJ-29, and the
recovered propane compressor, RJ-27, were vented near ground level.
Feasible abatement methods to correct this condition may include, but
are not limited to, reconfiguring the relief valve piping on these items
of equipment to assure that venting of flammable gases occurs at a safe
location.
E) The employer did not protect its employees from the recognized hazard
of fire and explosion in that adequate separation distances were not
provided between process units and the NP plant control room building
and the front gate security building.
Feasible abatement methods to correct this condition may include, but
are not limited to, following the guidelines for plant layout and
spacing such as those contained in Dow's Fire & Explosion Index Hazard
Classification Guide (American Institute of Chemical Engineers) and
Nitroparaffins and Their Hazards, (National Board of Fire Underwriters,
1959 edition).
Additional feasible abatement methods to correct all of the above
conditions A-E may include, but are not limited to, implementing an
effective chemical process safety management program that includes
such elements as a process hazard review, a job safety analysis, and
a human factors analysis of the nitroparaffins plant. Effective process
safety management assures prompt corrective action to eliminate
hazardous conditions.
A comprehensive process safety management program should at a minimum
(a) systematically investigate each element of a process design and its
hardware, to identify all of the ways in which deviations can occur from
intended design parameters to create hazards or operability problems,
(b) examine working conditions which influence the performance of human
operators, maintenance staff, technicians and other personnel, and
identify features of the job design likely to produce significant human
error or accident event sequences, and (c) systematically list the
process hazards and types of human errors likely to be encountered
during normal and upset/emergency conditions, the factors creating such
process hazards and potential accident sequences, and the proposed
system modifications and corrective action to eliminate the hazards
and/or the potential for human error.