OSHA Inspection: MOMENTIVE PERFORMANCE MATERIALS

Issued

Oct 18, 2010

Abate by

Nov 22, 2010

Penalty

Initial $4,500 · Current $4,500

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)MeCl Process, Train A, Building 34A:  Employer failed to document that
relief
systems complied with recommended and generally accepted good engineering
practice(s), such as API 520 Part II, including, but not limited to:
PSV-5205,
PSV-5241, PSV-5245, and PSV-5253, when the inlet pressure drop exceeded 3%
of the set point, on or about 5/25/10.
(a)MeCl Process, Train A, Building 34A: Employer failed to document that
relief
systems complied with recommended and generally accepted good engineering
practice(s), such as API 520 Part I, including, but not limited to:
PSV-5205,
when the outlet pressure drop exceeded 10% of the set point, on or about
5/25/10.
Abatement note:  The employer should document that all relief systems in
the MeCl unit
are properly verifed for compliance with API 520 part I and II.
Pursuant to 29 CFR 1903.19(d), the employer must provide documentation and
certification to OSHA that this violation has been abated within 10
calendar days of
the "Date by which Violation Must be Abated".

Issued

Oct 18, 2010

Abate by

Nov 22, 2010

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.119(e)(3)(v):  The process hazard analysis did not address
facility siting:
(a)MeCl process, Trains A & B, on or prior to 6/10/10:  The PHA did not
address
facility siting hazards which could result in personnel exposure to MeCl
vapor in
the process area, including, but not limited to:
-Hazards associated with location of safety relief valve atmospheric vents
immediately adjacent to personnel work platforms on 7th deck;
-Hazards associated with installation of a wind protection barrier which
partially enclosed the structure on the A train side;
-Hazards associated with lack or limitations of vapor detectors/alarms or
other suitable means of warning employees of a vapor leak or release;
-Hazards associated with location of emergency escape respirators.
Pursuant to 29 CFR 1903.19(d), the employer must provide documentation and
certification to OSHA that this violation has been abated within 10
calendar days of
the "Date by which Violation Must be Abated".

Issued

Oct 18, 2010

Abate by

Nov 22, 2010

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.119(e)(3)(vi):  The process hazard analysis did not address
human factors:
(a)MeCl process, Trains A & B:  The Process Hazard Analysis did not address
hazard(s) associated with limited staffing in the control room while
operators are
performing a rail car switch, on or about 5/7/10.
(b)MeCl process, Trains A & B:  The Process Hazard Analysis did not address
hazard(s) associated with operator fatigue and shift length, on or about
5/7/10.
(c)MeCl process, Trains A & B:  The Process Hazard Analysis did not
address shift
staffing and operator failure to follow the established shift change
procedure for
the MeCl/Siloxanes unit, on or about 5/7/10.
Pursuant to 29 CFR 1903.19(d), the employer must provide documentation and
certification to OSHA that this violation has been abated within 10
calendar days of
the "Date by which Violation Must be Abated".

Issued

Oct 18, 2010

Abate by

Nov 22, 2010

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.119(e)(5):  Them employer did not assure that actions
recommended by the
process hazard analysis team are resolved in a timely manner and that the
resolution is
documented:
(a)MeCl Process, Trains A & B:  Employer failed to ensure that all
recommendations from the previous process hazard analysis were completed as
soon as possible, in that PHA recommendations from 2004 study were still
open,
on or prior to 5/7/10.
(b)MeCl Process, Trains A & B:  Employer failed to document the resolution
of all
PHA recommendations from 2004 PHA study, in that the resolution of
recommendation no. 8 "consider installation of a flame arrestor at MeOH
high
point vent" was not documented, on or prior to 6/5/10.
Pursuant to 29 CFR 1903.19(d), the employer must provide documentation
and certification to OSHA that this violation has been abated within 10
calendar days of the "Date by which Violation Must be Abated".