OSHA Inspection: BORDEN REMINGTON CORPORATION

Issued

Aug 19, 2010

Abate by

Nov 1, 2010

Penalty

Initial $4,200 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i)(A):  Process safety information pertaining to the
technology of the
process did not include a block flow diagram or simplified process flow
diagram:
Facility:  The employer failed to include all main flow streams and major
process equipment of
the sodium hypochlorite process in the block flow diagram such as, but not
limited to:
1)Flow of product stream after bleach reactor.
2)Recycle bleach loop with accumulator recycle tank.
3)Cooling water loop with cooling tower.
4)Provent Scrubber flow streams.
5)Heat exchangers, pumps, and metering valves.

Issued

Aug 19, 2010

Abate by

Oct 5, 2010

General-duty citation text

29 CFR 1910.119(d)(2)(i)(B):  Process safety information pertaining to the
technology of the
process did not include the process chemistry:
Facility:  The employer failed to document the process chemistry of the
sodium hypochlorite
process.

Issued

Aug 19, 2010

Abate by

Oct 5, 2010

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D):  Process safety information pertaining to the
technology of the
process did not include the safe upper and lower limits for such items as
temperatures,
pressures, flows or compositions:
Facility: The employer failed to document safe upper and lower limits for
process parameters
such as, but not limited to, temperature, pressure, flows, and
composition.

Issued

Aug 19, 2010

Abate by

Oct 5, 2010

Penalty

Initial $4,200 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(C):  Process safety information pertaining to the
equipment in the
process did not include the electrical classification:
Facility: The employer failed to document the electrical classification
for the process equipment
such as, but not limited to:
1)   7.5 HP 2113A starter/disconnect for the bleach dilution water pump
2)   7.5 HP 2113A starter/disconnect for the process water pump
3)   25 HP 2113A starter/disconnect for the cooling water pump
4)   25 HP 2113A starter/disconnect for the cooling tower fan 2 speed
Consequent Pole
5)   10 HP 2113A starter/disconnect for the bleach plant 50caustic pump
6)   7.5 HP 21113A starter/disconnect for the bleach dilution 50caustic
pump
7)   Twin disconnect with 30 amp breakers for 10 HP air padding system &
spare
8)   15 HP 2113A starter/disconnect for Provent chlorine line scrubber
9)   25 HP 2113A starter/disconnect for Bleach Plant recycle pump
10)  15 HP 2113A starter/disconnect for Bleach Filter pump
11)25 HP 2113A starter/disconnect for Bleach Water Backwash pump
12)1/3 HP 2113A starter/disconnect for filter screen motor
13)10 HP 2113A starter/disconnect for Bleach Dilution pump
14)10 HP 2113A starter/disconnect for Bleach Loading pump
15)5 HP  2113A starter/disconnect for filter pre-coat, unfiltered bleach
tank vents, and bag
opening station fan

Issued

Aug 19, 2010

Abate by

Nov 1, 2010

General-duty citation text

29 CFR 1910.119(d)(3)(i)(G):  Process safety information pertaining to the
equipment
did not
include the material and energy balances for processes built after May 26,
1992:
Facility:  The employer failed to document the material and energy
balances for the sodium
hypochlorite process.rite

Issued

Aug 19, 2010

Abate by

Feb 28, 2011

Penalty

Initial $4,200 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i):  The process hazard analysis (PHA) did not
address the hazards of
the process:
Facility:  The PHA did not address the hazards of the sodium hydrochlorite
process such as, but
not limited to:
1)Hazards related to the Provent Scrubber node.
2)Hazards related to the Cooling Tower node.
3)Outdoor environmental factors affecting the safe operation of process
equipment.
4)Failure of process equipment including pumps, heat exchanger, and
accumulation tanks.
5)Process equipments located downstream of the bleach reactor.
6)Failure of pressure relief devices.

Issued

Aug 19, 2010

Abate by

Feb 28, 2011

Penalty

Initial $4,200 · Current $2,500 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:
Facility: The employer did not establish a system to address the
recommendations documented
in the initial process hazard analysis.

Issued

Aug 19, 2010

Abate by

Jan 3, 2011

Penalty

Initial $4,200 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iii):  The employer's written operating procedures
did not address the
requirements for the safety and health considerations listed in 29 CFR
1910.119(f)(1)(iii)(A)
through (f)(1)(iii)(E):
Facility: The employer failed to include safety and health considerations
in the following existing
operating procedures, such as precautions necessary to prevent exposure
and control measures
to be taken in case of physical contact or airborne exposure:
1)Sodium Hypochlorite Run Sheet (BOR-096)
2)Sodium Hypochlorite Start Up Procedure (B17-319)
3)Provent Scrubber Process (B17-321)
4)Chlorine Padding System (B17-322)
5)Bleach Filtering System (B17-323)
6)Chlorine Unloading (B17-324)
7)Dilution Procedure (B17-320)

Issued

Aug 19, 2010

Abate by

Nov 3, 2010

Penalty

Initial $4,200 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(i):  The employer, when selecting a contractor, did
not obtain and
evaluate information regarding the contract employer's safety performance
and programs:
Facility:  The employer failed to evaluate the mechanical contractor's
safety and health
programs.  The mechanical contractor lacks safety programs such as, but
not limited to,
lockout/tagout, hot works, and personal protective equipment.

Issued

Aug 19, 2010

Abate by

Nov 3, 2010

Penalty

Initial $4,200 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(j)(2):  The employer did not establish and implement
written procedures to
maintain the on-going mechanical integrity of process equipment:
Facility: The employer did not develop and implement written mechanical
integrity procedures
to maintain the on-going mechanical integrity of process equipment
including, but not limited
to:
1)Skid mounted system containing recycle pumps, tanks, piping,
instrumentation and PLC
controls
2)Remote Mounted Motor Control Center
3)Marley Cooling Tower and associated motors, pumps, tanks, and level
control
4)30 SCFM 10 HP chlorine tank car padding unit
5)Provent Chlorine Scrubber
6)Chlorine tank car unloading system
7)Unipro shutoff system equipment
8)Pressure relief valves
9)Chlorine gas detectorse

Issued

Aug 19, 2010

Abate by

Nov 1, 2010

General-duty citation text

29 CFR 1910.119(j)(3):  The employer did not train each employee involve
in maintaining the
on-going mechanical integrity of process equipment in an overview of that
process and its
hazards and in the procedures applicable to the employee's job tasks to
asssure that the employee
can perform the job tasks in a safe manner:
Facility: The employer did not train the employees on the mechanical
integrity procedures.

Issued

Aug 19, 2010

Abate by

Nov 1, 2010

Penalty

Initial $4,200 · Current $2,500 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:
Facility: The employer did not conduct inspections and tests on the
process equipment such as,
but not limited to:
1)Skid mounted system containing recycle pumps, tanks, piping,
instrumentation controls
2) Remote Mounted Motor Control Center
3)Marley Cooling Tower and associated motors, pumps, tanks, and level
control
4)30 SCFM 10 HP chlorine tank care padding unit
5)Provent Chlorine Scrubber
6)Chlorine tank car unloading system
7)Unipro shutoff system equipment
8)Pressure relief valves
9)Chlorine gas detectors
The inspections and tests shall comply with the provisions of 29 CFR
1910.119(j)(4)(ii), (iii),
and (iv).,

Issued

Aug 19, 2010

Abate by

Oct 5, 2010

Penalty

Initial $4,200 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(j)(5):  The employer did not correct deficiencies in
equipment that were
outside acceptable limits (as defined by process information in 29 CFR
1910.119(d)) before
further use or in a safe and timely manner:
Facility: The employer did not correct process equipment deficiencies
including, but not limited
to:
1)  Provent Scrubber leaky bottom flange connections
2)  Non-functional Durco G4 plug valve

Issued

Aug 19, 2010

Abate by

Feb 28, 2011

Penalty

Initial $4,200 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(o)(1):  The employer did not certify that they had
evaluated compliance with
the provisions of 29 CFR 1910.119 at least every three years to verify
that the procedures and
practices developed under this standard were adequate and are being
followed:
Facility:  The employer did not evaluate the process safety management
program for compliance
with the provisions of 29 CFR 1910.119.  The mechanical integrity
procedures and contractor
safety program were not evaluated.