OSHA Inspection: HONEYWELL INTERNATIONAL, INC.

Issued

Jun 21, 2011

Abate by

Nov 10, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.101(b):  The in-plant handling, storage, and utilization of
all compressed gases
in cylinders, portable tanks, rail tankcars, or motor vehicle cargo tanks
were not in
accordance with Compressed Gas Association Pamphlet P-1-1965:
(a)Storage of 134a refrigerant cylinders were exposed to physical damage
from vehicular
impact when stored along the roadway.
Compressed Gas Association Pamphlet P-1, Paragraph 3.3.8 states: Protect
cylinders
from any object that will produce a cut or other abrasion in the surface
of the metal.
Do not store cylinders near elevators or gangways, or in locations where
heavy
moving objects may strike or fall on them.
Abatement documentation is required for this item in accordance with the
requirements of 29
CFR 1903.19(d).

Issued

Jun 21, 2011

Abate by

Nov 10, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B):  Process safety information pertaining to the
equipment
in the
process did not include the piping and instrument diagrams:
The employer did not ensure the Piping and Instrumentation Diagrams (P&ID)
were correct
and up to date. Field verification of valves identified several
inaccuracies in the P&ID.  The
following valves were not labeled correctly:
(a)Valve tags reversed manipulated during unloading:  GS GF2 HV203 and GS
GF2
HV209.
(b)Valve tags reversed manipulated during unloading: GS HFNTR HV202 and GS
HFNTR HV208.
(c)Dual relief header downstream #1 HF Tank rupture disc tags reversed:
RD 604 and
RD 605.
(d)Dual relief header downstream #1 HF Tank valve tags reversed:  HF U256
HV003
and HV U256 HV002.
(e)Dual relief header downstream #1 HF Tank common vent line not marked
from RV
606 and RV607.
(f)Rupture disk RD660 on HF Dump Tank was not labeled.
(g)Dump valves HF U256 AV006 & HF U256 HV015 for tank #1 were field
verified on
Tank #3.
(h)Dump valves HF U256 AV004 & HF U256 HV013 for Tank #3 were field
verified
on Tank #1.
(i)Relief valves on HF Dump Tank U-256 were reversed. RV610 & RV653 were
reversed.
(j)Relief valves on Tank #2 U-404 were reversed. RV412 & RV413 were
reversed.
(k)Valve between the inlet RD and RV on Tank #1 had a ball valve listed as
HF RD605
HV001, field verification determined valve was labeled HF RD605 HV004.
(l)Block valve from HF Dump Tank U-256 was listed as HF U827 HV004, field
verification determined that it was labeled HF U287 HV004.
(m)Block valve from HF Dump Tank U-256 was listed as HF HFSTG HV006, field
verification determined it was labeled HF HFSTG HV007.
(n)On Ammonia Storage Tank U-466, the relief valves RV423 & RV422 were
reversed.
(o)Ammonia unloading line had block valve listed as NH3 LIQSTG HV008, field
verification determined it was labeled  NH3 LIQSTG HV003.
(p)Ammonia vent line had block valve listed as NH3 P404 HV005, field
verifiaction
determined it was labeled  NH3 P404 HV003.
(q)Three way valve coming off of Ammonia tank U-466 was not identified on
PID.
(r)Three way valve coming off of Ammonia tank U-467 was not identified on
PID.
(s)Relief valve on Ammonia tank U-466 was listed as RV668, field
verification indicated
it was RV666. There were two RV666 in the field.
Abatement documentation is required for this item in accordance with the
requirements of 29
CFR 1903.19(d).

Issued

Jun 21, 2011

Abate by

Nov 10, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F):  Information pertaining to the equipment in
the process did not
include design codes and standards employed:
(a)Minimum required thicknesses were not appropriately established for
process piping
per API 574, Inspection Practices for Piping System Components, Section
11.1.4.
Abatement documentation is required for this item in accordance with the
requirements of 29
CFR 1903.19(d).

Issued

Jun 21, 2011

Abate by

Aug 5, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(d)(3)(ii):  Equipment did not comply with recognized and
generally
accepted good engineering practices:
(a)Manual block valves were located downstream from automated dump valves
at
hydrofluoric acid storage tanks U-613, U-404, and U-201.  The configuration
subrogated the automated rapid deinventory capabilities as prescribed in
The
Hydrogen Fluoride Industry Practices Institute (HFIPI), Guideline for the
Bulk
Storage of Anhydrous Hydrogen Fluoride, Sections 2.3, 4.2, 5.4.
(b)Hydrofluoric acid storage tanks U-613, U-404, and U-201 were not sized
to receive
delivery quantities at 1.5 times the size of said anticipated deliveries
per Hydrogen
Fluoride Industry Practices Institute (HFIPI), Guideline for the Bulk
Storage of
Anhydrous Hydrogen Fluoride, Section 3.1.
(c)Hydrofluoric acid dump tank U-256 intended for deinventory purposes did
not have
the equivalent capacity of the largest hydrofluoric acid storage tanks
U-404 and U-201
per Hydrogen Fluoride Industry Practices Institute (HFIPI), Guideline for
the
Bulk
Storage of Anhydrous Hydrogen Fluoride, Section 5.6.
(d)Liquid flow velocity for piping exceeded 5.9 feet/second at 1-1/2"
unloading line
PFF-747 to assure the integrity of iron fluoride scale to protect against
corrosion per
Hydrogen Fluoride Industry Practices Institute (HFIPI), Guideline for the
Bulk
Storage of Anhydrous Hydrogen Fluoride, Section 3.7.
(e)The eye wash and shower station was not equipped with an alarm device
to sound in
the control room at the hydrofluoric acid rail car unloading area per
Hydrogen
Fluoride Industry Practices Institute (HFIPI), Tank Car Unloading
Guideline for
AHF, Section 4.2.7.
(f)There was no valve capping kit provided for hydrofluoric acid rail car
unloading per
Hydrogen Fluoride Industry Practices Institute (HFIPI), Tank Car Unloading
Guideline for AHF, Section 4.2.1.
Abatement documentation is required for this item in accordance with the
requirements of 29
CFR 1903.19(d).

Issued

Jun 21, 2011

Abate by

Nov 10, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 29 CFR 1910.119(e)(5):  The process hazard analysis team's finding
was not
resolved in a timely manner and the resolution was not documented:
(a)The 2009 PHA team's recommendation #23 regarding re-configuration of
hydrofluoric
acid storage tanks U-613, U-404, and U-201 manual block valves located
downstream
of automatic dump valves had not been resolved.
Abatement documentation is required for this item in accordance with the
requirements of 29
CFR 1903.19(d).

Issued

Jun 21, 2011

Abate by

Aug 5, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(f)(1)(i)(B):  The employer did not develop and implement
written
operating procedures that provided clear instructions for conducting
activities in each covered
process consistent with the process safety information and did not address
normal operations:
(a)The employer did not implement written normal operating procedures that
provided
clear instructions for unloading hydrogen fluoride into three different
storage tanks
and when switching tanks.
Abatement documentation required for this item in accordance with the
requirements
of 29
CFR 1903.19(d).

Issued

Jun 21, 2011

Abate by

Aug 5, 2011

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(f)(1)(i)(E):  The employer did not develop and implement
written
operating procedures that provided clear instructions for conducting
activities in each covered
process consistent with the process safety information and did not address
emergency
operations:
(a)The employer did not implement written emergency operating procedures
that
provided clear instructions for emptying hydrogen fluoride tanks by
opening valves
and isolating nitrogen systems.
Abatement documentation required for this item in accordance with the
requirements of 29
CFR 1903.19(d).

Issued

Jun 21, 2011

Abate by

Aug 5, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(2):  The employer did not establish and implement
written procedures to
maintain the on-going integrity of process equipment:
The employer did not establish and implement written procedures to
maintain the on-going
integrity of process valves in the Tank Farm:
(a)Valves requiring mechanical locking elements (i.e. carseals) were not
documented and
audited to ensure they were administratively controlled per American
Society of
Mechanical Engineers, Boiler & Pressure Vessel Code, Section VIII.
(b)Valves (i.e. piping components) were not included in the mechanical
integrity
program.
(c)The HF Hose Adapter Unloading Assembly connection comprised of 1"
schedule 80
pipe threads, union, and bushing leaked on 3/10/11.
Abatement documentation required for this item in accordance with the
requirements of 29
CFR 1903.19(d).

Issued

Jun 21, 2011

Abate by

Aug 5, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(4)(iii):  The frequency of inspections and tests of
process equipment
were not consistent with applicable manufacturers' recommendations and
good engineering
practices, and more frequently if determined to be necessary by prior
operating experience:
The employer did not conduct inspections and tests consistent with
manufacturers'
recommendations and good engineering practices for the following process
equipment:
(a)5 year hydrostatic testing on hydrogen fluoride tanks; U-613, U-404,
and U-201.
(b)Testing and exercising hydrogen fluoride tank vent valves; XV-652VB,
XV-650VB,
and XV-651VB.
(c)Testing and exercising hydrogen fluoride tank dump valves; XV-652VA,
XV-650VA,
XV-651VA.
Abatement documentation required for this item in accordance with the
requirements of 29
CFR 1903.19(d).

Issued

Jun 21, 2011

Abate by

Aug 5, 2011

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(j)(5):  Deficiencies were not corrected in equipment that
were outside
acceptable limits before further usage:
(a)Throughout the Tank Farm unit, including - but not limited to, 4" dump
lines PFF-
421, PFF-422, and PFF-423, the poor condition of external paint/coating
was not
addressed.
Abatement documentation is required for this item in accordance with the
requirements of 29
CFR 1903.19(d).

Issued

Jun 21, 2011

Abate by

Jun 24, 2011

Penalty

Current $7,000

General-duty citation text

29 CFR 1910.119(j)(6)(ii):  Appropriate checks and inspections were not
performed to assure
that equipment was installed properly and consistent with design
specifications and the
manufacturer's instructions:
(a)The employer did not conduct appropriate checks and inspections to
assure equipment
was installed properly and consistent with design specifications when dump
valves are
actuated in the event of an emergency or during maintenance activities.
There is no abatement documentation or certification required for this
item.

Issued

Jun 21, 2011

Abate by

Jun 24, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(m)(4)(iv):  Incident investigation report did not include
factors that
contributed to an incident:
(a)Incident report IR-07-0471 where there was a hydrogen fluoride leak at
vessel U-613
relief header rupture disk holder on 2/22/07 did not identify factors that
contributed to
the incident.
There is no abatement documentation or certification required for this
item.

Issued

Jun 21, 2011

Abate by

Jun 24, 2011

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(m)(4)(v):  Incident investigation report did not include
recommendations
resulting from the investigation:
(a)Incident report IR-07-0471 where there was a hydrogen fluoride leak at
vessel U-613
relief header rupture disk holder on 2/22/07 did not include
recommendations
resulting from the investigation.
There is no abatement documentation or certification required for this
item.