OSHA Inspection: ARIZONA CHEMICAL COMPANY

Issued

Mar 22, 1999

Abate by

Mar 15, 2000

Penalty

Initial $7,000 · Current $3,750 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 a contact hazard as a result of system upset and/or
equipment failure due to an
uncontrolled over-pressurization of a vessel:
a)In the ester reactor room (building 23), reactor operators were exposed
to a
contact hazard from chemical and/or thermal burns due to failure of
equipment
and/or associated controls and the release of chemicals from a vessel such
as the
catalyst charge pot (V-146) and/or reactor vessels (V-103, V-104, V-107,
and V-
108).
Among other methods, feasible and acceptable abatement methods to correct
this
hazard include, but are not limited to, the following:
*Provide training and refresher training for reactor operators with
emphasis
on the specific safety and health hazards of the process, emergency
operations including shutdown, and safe work practices applicable to the
employee's job task such as, but not limited to, the following:
**the knowledge, skills, and abilities to safely run ester batches on
reactor vessel #8 (V-108);
**the knowledge, skills, and abilities to safely charge 35hydrogen
peroxide to reactor vessel #8 (V-108);
**operating procedures such as emergency operations, emergency
shutdown, and peroxide bleaching;
**the consequences of charging any chemical or substance other than
TPT through the catalyst charge pot (V-146) and that any deviation
could potentially result in over-pressurization beyond the capacity
of the charge pot;
**the reactive properties of TPT and the hazards associated with the
mixing of TPT with water/steam and other chemicals such as 35
hydrogen peroxide in the catalyst charge pot (V-146) and TPT
charge lines;
**the critical limits on each batch and/or reactor vessel (V-103, V-
104, V-107, and V-108), such as maximum temperatures and
pressures, and the consequences of deviation;
**the limitations and inadequacies of the pressure relief device on the
catalyst charge pot (V-146); and
**the safety systems and their functions on each of the reactor
vessels.
*Ascertain and document that the #8 reactor operator involved in the
incident in the ester reactor room (building 23) on October 15, 1998,
received and understood the training.
*Conduct an organized and systematic evaluation (engineering and hazard
analysis) of the ester production process at the facility that will
effectively
identify potential causes and consequences of system upsets or deviations
that could cause safety or health hazards to employees, including items
such as, but not limited to, the following:
**address charging and mixing of a reactive chemical such as 35
hydrogen peroxide with TPT in the catalyst charge pot (V-146) and
TPT charge lines;
**address addition and mixing of water and/or steam with TPT in the
catalyst charge pot (V-146) and TPT charge lines;
**address the consequences of engineering control failure such as,
but not limited to, the failure of the pressure relief device in the
event of an uncontrolled over-pressurization of the catalyst charge
pot (V-146) due to a reaction from TPT mixing with another
chemical or water/steam;
**address facility siting such as, but not limited to, the location of
the controls and the location/construction of the break/control
room;
**address human factors such as, but not limited to, the potential
hazards associated with the capability of three ester reactor
operators running four reactors in the event of multiple problems
and/or alarms on more than one reactor vessel;
**evaluate consequences of charging and mixing of a reactive
chemical such as 35hydrogen peroxide with TPT in the catalyst
charge pot (V-146) and TPT charge lines;
**evaluate consequences of addition and mixing of water and/or
steam with TPT in the catalyst charge pot (V-146) and TPT charge
lines;
**evaluate consequences of the relief system's inability to safely
handle an event such as an uncontrolled over-pressurization of the
catalyst charge pot (V-146); and**identify and evaluate any previous
incidents in the ester reactor
room (building 23) such as, but not limited to, the following:
***the incident, approximately 17 to 18 years ago, which
involved a reaction between residual TPT and hydrogen
peroxide resulting in the upper valve of the sample bomb
being blown apart on reactor #3;
***the incident, in approximately 1984, which involved an
explosion on a reactor, injuring at least 2 employees, due
to static electricity; and
***the incident, in approximately 1948-49, which levelled
building 23 killing 1 employee.
Abatement certification and documentation are required.tion

Issued

Mar 22, 1999

Abate by

Mar 15, 2000

Penalty

Initial $7,000

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized hazards that
were causing or likely to cause death or serious physical harm to
employees in that employees
were exposed to a fire/explosion hazard as a result of system upset and/or
equipment failure due
to an uncontrolled over-pressurization of a vessel:
a)In the ester reactor room (building 23), reactor operators were exposed
to a
fire/explosion hazard due to vessel fragmentation from an uncontrolled
over-
pressurization of a vessel such as the catalyst charge pot (V-146) and/or
reactor
vessels (V-103, V-104, V-107, and V-108).
Among other methods, feasible and acceptable abatement methods to correct
this
hazard include, but are not limited to, the following:
*Provide training and annual refresher training for reactor operators with
emphasis on the specific safety and health hazards of the process,
emergency operations including shutdown, and safe work practices
applicable to the employee's job task such as, but not limited to, the
following:
**the knowledge, skills, and abilities to safely run ester batches on
reactor vessel #8 (V-108);
**the knowledge, skills, and abilities to safely charge 35hydrogen
peroxide to reactor vessel #8 (V-108);
**operating procedures such as emergency operations, emergency
shutdown, and peroxide bleaching;
**the consequences of charging any chemical or substance other than
TPT through the catalyst charge pot (V-146) and that any deviation
could potentially result in over-pressurization beyond the capacity
of the charge pot;
**the reactive properties of TPT and the hazards associated with the
mixing of TPT with water/steam and other chemicals such as 35
hydrogen peroxide in the catalyst charge pot (V-146) and TPT
charge lines;
**the critical limits on each batch and/or reactor vessel (V-103, V-
104, V-107, and V-108), such as maximum temperatures and
pressures, and the consequences of deviation;
**the limitations and inadequacies of the pressure relief device on the
catalyst charge pot (V-146); and
**the safety systems and their functions on each of the reactor
vessels.
*Ascertain and document that the #8 reactor operator involved in the
incident in the ester reactor room (building 23) on October 15, 1998,
received and understood the training.
*Conduct an organized and systematic evaluation (engineering and hazard
analysis) of the ester production process at the facility that will
effectively
identify potential causes and consequences of system upsets or deviations
that could cause safety or health hazards to employees, including items
such as, but not limited to, the following:
**address charging and mixing of a reactive chemical such as 35
hydrogen peroxide with TPT in the catalyst charge pot (V-146) and
TPT charge lines;
**address addition and mixing of water and/or steam with TPT in the
catalyst charge pot (V-146) and TPT charge lines;
**address the consequences of engineering control failure such as,
but not limited to, the failure of the pressure relief device in the
event of an uncontrolled over-pressurization of the catalyst charge
pot (V-146) due to a reaction from TPT mixing with another
chemical or water/steam;
**address facility siting such as, but not limited to, the location of
the controls and the location/construction of the break/control
room;
**address human factors such as, but not limited to, the potential
hazards associated with the capability of three ester reactor
operators running four reactors in the event of multiple problems
and/or alarms on more than one reactor vessel;
**evaluate consequences of charging and mixing of a reactive
chemical such as 35hydrogen peroxide with TPT in the catalyst
charge pot (V-146) and TPT charge lines;
**evaluate consequences of addition and mixing of water and/or
steam with TPT in the catalyst charge pot (V-146) and TPT charge
lines;
**evaluate consequences of the relief system's inability to safely
handle an event such as an uncontrolled over-pressurization of the
catalyst charge pot (V-146); and**identify and evaluate any previous
incidents in the ester reactor
room (building 23) such as, but not limited to, the following:
***the incident, approximately 17 to 18 years ago, which
involved a reaction between residual TPT and hydrogen
peroxide resulting in the upper valve of the sample bomb
being blown apart on reactor #3;
***the incident, in approximately 1984, which involved an
explosion on a reactor, injuring at least 2 employees, due
to static electricity; and
***the incident, in approximately 1948-49, which levelled
building 23 killing 1 employee.
Abatement certification and documentation are required.tion

Issued

Mar 22, 1999

Abate by

Mar 15, 2000

Penalty

Initial $7,000 · Current $3,750 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:
29 CFR 1910.106(h)(8)(i): Maintenance and operating practices were not in
accordance with
established procedures which did not tend to control leakage and prevent
the accidental escape
of flammable or combustible liquids:
a) In the ester reactor room (building 23) where flammable and combustible
liquids are used
in ester production, the employers written operating and manufacturing
procedures for
the production of ester batches were not fully implemented, did not
provide clear
instructions and did not address all of the safety and health
considerations for safely
manufacturing esters such as, but not limited to the following:
*the manufacturing procedure for the Uniflex 186 ester product was not
effectively
implemented in that operators, prior to adding sebacic acid, heated the
reactor 30
to 60 degrees Fahrenheit higher than what was stated in steps C and F for
charging the reactor;
*the peroxide bleaching procedure was not effectively implemented in that
operators were adding the bleaching agent through the reactor manhead
rather than
through the charge pot on top of the reactor which was stated in the
polymeric
peroxide bleaching procedure;
*the operating and manufacturing procedures did not provide clear
instructions on
how TPT (flashpoint approximately 140 degrees F) was to be charged to the
reactor vessels;
*the operating and manufacturing procedures did not indicate which valves
to open
and close when charging TPT to the reactor vessels via the catalyst charge
pot
(V-146);
*the operating and manufacturing procedures did not specify the importance
of TPT
being the only chemical that could be charged through the catalyst charge
pot (V-
146) and that any deviation could potentially result in
over-pressurization beyond
the capacity of the charge pot; and
*the reactive properties of TPT and hazards associated with the mixing of
TPT with
water/steam and other chemicals such as 35hydrogen peroxide in the
catalyst
charge pot (V-146) and TPT charge lines.

Issued

Mar 22, 1999

Abate by

Mar 15, 2000

Penalty

Initial $3,500

Issued

Mar 22, 1999

Abate by

Apr 24, 1999

Penalty

Initial $70,000 · Current $37,500 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:
29 CFR 1910.106(h)(4)(iv)(a): Equipment was not designed and arranged to
prevent the
unintentional escape of liquids and vapors and to minimize the quantity
escaping in the event of
accidental release:
a)In the ester reactor room (building 23), the catalyst charge pot (V-146)
and associated
controls were not sufficient to minimize uncontrolled over-pressurization
of the vessel
due to reaction from TPT (tetraisopropyl titanate), which is a combustible
liquid (flashpoint
approximately 140 degrees F), mixing with another chemical or water/steam.
The
process system design could not safely handle the temperatures and
pressures that could
potentially occur due to, but not limited to, the following:
* no pressure vessel certification nor ASME certification for the catalyst
charge pot (V-146) which was fabricated in-house;
*no evaluation of the safe upper and lower limits such as, but not limited
to, temperatures and pressures;
*no relief system design and design basis;
*no design codes and standards employed for the construction; and
*no documentation that the catalyst charge pot (V-146) complied with
recognized and generally accepted engineering practices.g