OSHA Inspection: SURPASS CHEMICALS

Issued

Oct 7, 1997

Abate by

Nov 9, 1997

Penalty

Initial $2,500 · Current $2,500

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 inhalation, chemical burn and struck-by hazards
caused by
the rupture of a FRP aboveground atmospheric storage tank containing 5,000
gallons of
31hydrochloric acid solution and the ensuing destruction of adjacent PVC
transfer
lines containing 18sodium hypochlorite.  Those hazards resulted from the
employers
failure to (1) follow the storage tank manufacturers instructions during
air loading
operations and (2) develop and implement an inspection, maintenance and
testing
program for its atmospheric tank and appurtenances; for its FRP aboveground
atmospheric storage tank containing 31hydrochloric acid and associated
scrubber
system.
On or about April 8, 1997, that tank ruptured during air loading of
hydrochloric acid,
resulting in the release of hydrochloric acid, sodium hypochlorite and
chlorine gas, and
turning parts of the ruptured structures into flying objects.
Feasible means of abatement, among others, include the following:
1) Adhere to the tank manufacturers instructions, including, but not
limited to, those
stamped on manufacturers Drawing No. HA 34096-B, and contained in O.C.F.
Pub. No. 3-
PE-6344.  Those instructions specifically advise that  IF THE TANK IS TO
BE AIR
LOADED, THE TANK MUST BE VENTED WITH A 22" MINIMUM DIAMETER
OPENING DURING ALL FILLING PERIODS...TANK PRESSURE NOT TO EXCEED
10" WATER.;
2) Develop and implement an inspection, maintenance and testing program
for atmospheric
tank and appurtenances which include, but are not limited to, venting
devices and scrubber
systems, to ensure continued appropriate venting rates and hydrogen
chloride gas control,
respectively;
3) Install a high level alarm, a tank over pressurization indicator/alarm,
and provide for
adequate emergency venting or emergency shutoff during bulk transfer
operations;
4) Develop and implement written standard operating procedures (SOPs) for
bulk transfers
into atmospheric tanks;
5) Ensure compatibility of all materials stored or handled in close
proximity to hydrochloric
acid and sodium hypochlorite.  Incompatible materials shall be separated,
by inert products,
separating walls, dikes, or some safe minimal distance.
A SEARCH OF OSHA STANDARDS REVEALED THAT NONE ARE APPLICABLE.
ABATEMENT DOCUMENTATION AND CERTIFICATION REQUIRED