OSHA Inspection: COOK COMPOSITES AND POLYMERS CO.

Issued

Mar 8, 2010

Abate by

Mar 18, 2010

Penalty

Initial $1,875

General-duty citation text

29 CFR 1910.106(h)(7)(i)[a]: Precautions were not taken to prevent the
ignition of flammable
vapors. Sources of ignition include but are not limited to open flames;
lighting; smoking; cutting
and welding; hot surfaces; frictional heat; static, electrical and
mechanical sparks; spontaneous
ignition, including heat-producing chemical reactions; and radiant heat.
(a)The employer did not use non-spark producing tools in areas listed by
the
employer as Class I Division I locations. Process Technicians in building
20 used
a T-Wrench tool(s) that were not made of non-sparking material to secure
and
unsecure manway bolts on kettle reactor vessels and blend tank manway
covers.
This exposed process technicians and other employees to an explosion and
fire
hazard, in-that a spark can potentially be produced while using the tool,
igniting
potentially present flammable vapors from the process vessel during
charging
process.
Certification, with date and method of abatement required.
Certification of abatement is required by 29 CFR Part 1903 and is to be
submitted within ten (10)
calendar days after the abatement date.ment

Issued

Mar 8, 2010

Abate by

Apr 10, 2010

Penalty

Initial $4,500 · Current $2,300 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i):  Process safety information pertaining to the
equipment in the process
did not include the elements specified in 29 CFR 1910.119(d)(3)(i)(A)
through (H):
(a) Reactor K-3, P&ID #D.81.000.F.107:
1.Interlocks installed on the process were not identified on the P&ID. Such
as, but not limited to shut off feeds on loss of agitation, shut off of
nitrogen on high pressure and turn on cooling on high pressure in the
vessel.
(b) Reactor K-4, P&ID #D.81.000.F.110:
1.Rupture disc rating is shown to be 30 PSIG. The actual rupture disc
rating
is 15 PSIG and was installed in September of 2008.
2.The rated design pressure of the K-4 vessel is shown to be 30 PSIG. The
design pressure had been derated to 15 PSIG. The working pressure of the
vessel was shown to be 20 PSIG and is reflected to be 12.5 PSIG in CCP-
04-081-REF-05 Operating Limits and Corrective actions reference
document.
(c) Reactor K-5, P&ID #D.81.000.F.113:
1.The P&ID does not reflect the design pressure of the vessel.
2.Interlocks installed on the process were not identified on the P&ID.
Interlocks installed on the system and not identified are, but not limited
to shut off feeds on loss of agitation, shut off of nitrogen on high
pressure
and turn on cooling on high pressure in the vessel.
(d) Reactor K-7, P&ID #D.81.020.F.115:
1.The rated design pressure of the K-7 vessel is not identified on the
P&ID.
2.The rupture disc pressure setting is shown to be 30 PSIG on the P&ID.
The actual pressure setting is set to 40 PSIG.
3.Interlocks installed on the process were not identified on the P&ID.
Interlocks installed on the system and not identified are, but is not
limited
to shut off feeds on loss of agitation, shut off nitrogen on high pressure
and turn on cooling on high pressure in the vessel.
(e) Hot Oil System Distribution System, P&ID #D.81.000.U.307:
1.The rated design pressure of the vessel was not identified on the P&ID.
2.The working pressure of the Hot Oil Boiler was not identified.
3.The PSV (Pressure Safety Valve) did not identify the relief set point.
Certification, and documentation/evidence of abatement is required.
Certification of abatement is required by 29 CFR Part 1903 and is to be
submitted within ten (10)
calendar days after the abatement date.ment

Issued

Mar 8, 2010

Abate by

Apr 25, 2010

Penalty

Initial $6,300 · Current $3,200 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii):  The employer did not document that the
equipment in the process
complied with recognized and generally accepted good engineering practices:
(a)The employer did not document that Thin Tank T-104 Condenser complied
with
recognized and generally accepted good engineering practices (RAGAGEP), in-
that the Form U-3 Manufacturer's Certificate of Compliance Covering
Pressure
Vessels was not maintained.
(b)The Kettle 7 (K-7) Decanter did not have an independent relief device
installed
on the vessel, nor was an open relief path assured through the method of
carsealed open intervening valves.
Certification, and documentation/evidence of abatement is required.
Certification of abatement is required by 29 CFR Part 1903 and is to be
submitted within ten (10)
calendar days after the abatement date.ment

Issued

Mar 8, 2010

Abate by

Apr 10, 2010

Penalty

Initial $1,125 · Current $600 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(iii):  The process hazard analysis did not address
the engineering and
administrative controls applicable to the hazards and their
interrelationship, such as, appropriate
application of detection methodologies to provide early warning of
releases:
(a)Process Hazard Analysis (PHA) Safe Guards reference Generic and Inherent
Safeguards to protect against or mitigate process material releases. The
specific
Generic and Inherent safe guards listed in Table A.3 and that apply to the
node
item are not identified.
(b)Node 13 Kettle startup (k1/k2/k3/k4) - Pit Cover and Water Supply: Node
Item
13.4 does not list a safe guard for if water pressure goes below the 25
PSIG
operating limit.
(c)Node 17 Charging Bulk liquids to K1-K7 Kettles and Associated Weigh
Tanks via
Mass Meters: Node item 17.7 deviation states if a wrong charge quantity is
entered into the mass meter control panel a release of material could
occur. The
safeguard does not identify that a high alarm level warning device is
integrated
into the weigh tank.
Certification, with date and method of abatement required.
Certification of abatement is required by 29 CFR Part 1903 and is to be
submitted within ten (10)
calendar days after the abatement date.

Issued

Mar 8, 2010

Abate by

Jun 8, 2010

Penalty

Initial $1,125 · Current $600 Reduced

General-duty citation text

29 CFR 1910.119(e)(5):  The employer did not establish a system to assure
that the process
hazard analysis team's recommendations are resolved in a timely manner and
that the resolution
is documented:
(a)The employer did not document that PHA recommendations were resolved in
a
timely manner.  Recommendations from the 1998 initial PHA could not be
verified as closed and what the final resolution to the recommendation was.
Certification, with date and method of abatement required.
Certification of abatement is required by 29 CFR Part 1903 and is to be
submitted within ten (10)
calendar days after the abatement date.ment

Issued

Mar 8, 2010

Abate by

Apr 10, 2010

Penalty

Initial $6,300 · Current $3,200 Reduced

General-duty citation text

29 CFR 1910.119(e)(6):  The employer did not ensure after the initial
process hazard analysis
that the process hazard analysis was updated and revalidated at least
every five (5) years by a
team meeting the requirements of 29 CFR 1910.119(e)(4):
(a)The employer did not accomplish a Process Hazard Analysis (PHA)
revalidation
at least every five years in that the 1998 initial PHA revalidation was
not begun
until May of 2008 and not completed as of March, 2010.
Certification, and documentation/evidence of abatement is required.
Certification of abatement is required by 29 CFR Part 1903 and is to be
submitted within ten (10)
calendar days after the abatement date.ment

Issued

Mar 8, 2010

Abate by

Apr 10, 2010

Penalty

Initial $1,875 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(B):  The employer did not develop written
operating procedures
covering the steps for each operating phase of normal operations:
(a)The employer did not have an operating procedure for Draining of
Knock-Out
Boxes to the TSD facility.
Certification, with date and method of abatement required.
Certification of abatement is required by 29 CFR Part 1903 and is to be
submitted within ten (10)
calendar days after the abatement date.ment

Issued

Mar 8, 2010

Abate by

Apr 10, 2010

Penalty

Initial $1,875

General-duty citation text

Certification of abatement is required by 29 CFR Part 1903 and is to be
submitted within ten (10)
calendar days after the abatement date.ment

Issued

Mar 8, 2010

Abate by

Mar 11, 2010

Penalty

Initial $6,300 · Current $3,200 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i):  Inspections and tests were not performed on
process equipment to
maintain its mechanical integrity:
(a)The employer did not assure the ongoing mechanical integrity of the
T-104
Condenser (Spiral Heat Exchanger), serial number 22450, in that no
mechanical
integrity inspection and test were accomplished on the vessel.
No certification required.  Violation Abated.on

Issued

Mar 8, 2010

Abate by

Apr 10, 2010

Penalty

Initial $4,500 · Current $2,250 Reduced

General-duty citation text

29 CFR 1910.119(l)(2)(ii):  The written procedures to manage changes did
not assure that the
impact of the change on safety and health was addressed prior to any
change:
(a)The employer did not accomplish a management of change (MOC) when the
K-4
vent line rupture disc was changed from a 30 PSIG rupture disc to a 15 PSIG
rupture disc.
(b)The employer did not accomplish a management of change (MOC) when the
K-3
vent line rupture disc was changed from a 30 PSIG rupture disc to a 15 PSIG
rupture disc.
(c)A reduction in staffing levels was accomplished without implementing a
Management of Change (MOC) to ensure that processes were adequately staffed
to handle monitoring of covered processes.
Certification, and documentation/evidence of abatement is required.
Certification of abatement is required by 29 CFR Part 1903 and is to be
submitted within ten (10)
calendar days after the abatement date.ment