OSHA Inspection: HYDROCHEM INDUSTRIAL SERVICES, INC.

Issued

Jan 10, 2006

Abate by

Feb 28, 2006

Penalty

Initial $7,000 · Current $3,500 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 the condition(s) listed below:
The employer does not always protect each employee from fire / explosion
hazards.  This
violation was most recently observed on August 16, 2005 at the job
location of Chevron Phillips
Chemical Company LP, Ryton Plant, Borger, TX where a fire / explosion
occurred when a
HydroChem Industrial Services, Inc. employee was transferring "washwater"
from a pumper
truck into the tank identified as L4.  The pumper truck was not grounded /
bonded to the
system.  A sample taken of the washwater was classified as a Class I
Flammable Liquid.  The
liquid transferred from the pumper truck via the fill pipe fell
approximately 10 - 15 feet into the
L4 tank, creating a static charge.
American Petroleum Institute Publication 2219, Paragraph 4.1.3 states
"Vacuum truck operators
shall be aware that trace amounts of flammable and combustible liquids and
gases, hydrogen
sulfide gas, acids, caustics, spent caustics, spent acids, sour water and
other liquids, materials
and gases present in the petroleum industry may cause serious injury,
illness or death, if not
properly handled.  In addition, vacuum truck operators shall be aware that
when under vacuum,
even trace amounts of hydrocarbons and hydrogen sulfide gas may be easily
separated and create
flammable and or toxic atmospheres."
American Petroleum Institute Publication 2219, Paragraph 5.4.1.1 states
"Whenever liquids or
materials are transferred into or from a tank, vessel, or container (other
than a surface spill),
a bonding cable shall be connected from the vacuum truck to the source or
receiving container."
American Petroleum Institute Publication 2219, Paragraph 5.10.2 states
"Vacuum truck operators
shall be aware that whenever materials (such as produced water or spent
acid) that have the
potential to contain trace amounts of hydrocarbon condensates or hydrogen
sulfide are placed
under a vacuum, flammable vapors and toxic gases are freely released,
creating potential ignition
and exposure hazards."
Among other methods, feasible and acceptable abatement methods to correct
this hazard would
be:
1.  Verify prior to each transfer the bonding cable is securely connected
to the system.
2.  Ensure all vacuum truck operators have been trained and fully
understand American
Publication 2219.