OSHA Inspection: INFINEUM USA L.P.

Issued

May 21, 2010

Abate by

Aug 31, 2010

Penalty

Initial $4,500 · Current $4,500

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 fire and explosion hazards:
a- Bayway Chemical Plant, Lofi Unit - A 3/4 inch block valve on the inlet
of the 7E20
(7R20 P/A Heater) safety valve was not included on P&ID 12566-66BA-1TC
Sheet 1 of
1 Revision Number 15.  On 01/21/10 workers failed to lock out the above
noted block
valve resulting in a mechanic being splashed with heated product from the
7R20 Lofi
Reactor while removing the safety valve.
Feasible and acceptable methods among others to correct these hazards
include:
Update the above noted P&ID and ensure that all P&IDs on non-PSM covered
units are accurate and include all process equipment as per CCPS
Guidelines
for
Process Safety Documentation, Section 5.2.2.
b- Bayway Chemical Plant, Calcium Phenate Unit - Block valves on the inlet
lines to
safety valves for the 10D8 Lower Layer Solvent Drum, 10D9 Upper Layer
Solvent
Drum and 10D10 Upper Layer Solvent Drum were not car-sealed in their open
positions.
Condition noted on or about 12/02/10.
Feasible and acceptable methods among others to correct these hazards
include:
On non-PSM covered units provide adequate controls to ensure that
intervening
valves on the upstream or downstream lines to/from relief devices remained
in
the open position during pressure vessel operation as per ASME Boiler and
Pressure Vessel Code, Division 1 (BPVC), Section VIII, UG-135(d).
c- Bayway Chemical Plant, Polybutene Mechanical Shop and LM Finishing
Building -
Workers were exposed to blast injuries from flying projectiles (glass
windows and
corrugated metal/fiberglass walls) as a result of exposure to vapor cloud
explosions and
associated overpressures of 1-3 psi.  Condition noted on or about 02/19/10.
Feasible and acceptable methods among others to correct these hazards
include such as
but not limited to complying with API 752 Management of Hazards Associated
with
Location of Process Plant Buildings:
Perform mitigation measures found in API 752 Section 3.3.7.2 to include
relocating personnel, eliminating/modifying windows, strengthening
doorways,
installing external walls for explosion/projectile protection and/or
constructing
new explosion-resistant structures.esistant

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $1,875 · Current $1,875

General-duty citation text

29 CFR 1910.27(c)(4):  The distance from the centerline of rungs, cleats,
or steps to the
nearest permanent object in back of the ladder was not at least seven
inches:
a- Bayway Chemical Plant, 6E5s, Vis- J Unit - Employees were exposed to
fall
hazards of 33 feet while using a fixed metal ladder which had a conduit
within 4
inches of a rung.  Condition noted on or about 12/01/10.
b- Bayway Chemical Plant, 8E13, Dispersants Unit - Employees were exposed
to fall
hazards of 6 feet 9 inches while using a fixed metal ladder which had a
conduit within
3 inches of a rung.  Condition noted on or about 01/13/10.

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $1,875

General-duty citation text

29 CFR 1910.27(d)(2):  Fixed ladder(s), used to ascend to heights
exceeding 20 feet and
provided with cages or wells were not provided with a landing platform for
each 30 feet of
height or fraction thereof:
a- Bayway Chemical Plant, 6E5s, Vis-J Unit - Operators making rounds and
mechanics performing preventive maintenance were exposed to fall hazards
of 33 feet
while using a fixed metal ladder which was not provided with a rest
platform.
Condition noted on or about 12/01/09.

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $1,875 · Current $1,875

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $4,500 · Current $4,500

Issued

May 21, 2010

Abate by

Aug 31, 2010

Penalty

Initial $4,500 · Current $4,500

Issued

May 21, 2010

Abate by

Jul 2, 2010

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $4,500 · Current $4,500

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $4,500

General-duty citation text

29 CFR 1910.119(f)(1):  The employer did not develop and implement written
procedures
that provided clear instructions for safely conducting activities in each
covered process
consistent with the process safety information:
a- Bayway Chemical Plant, Main Control Room - There was no written
procedures
covering the necessary actions required if hydrocarbon or toxic gas was
detected in
the HVAC system and/or entered into the control room.  Condition noted on
or about
12/23/09.
b- Bayway Chemical Plant, Vis-J and Dispersants Units - Written operating
procedures to include normal start up/turnaround start up in the case of
continuous
processes or start up after turnaround in the case of batch processes did
not include
the requirement to remove all non-essential personnel from process unit
prior to
initiating such procedures as referenced in CCPS Guidelines for Safe
Process
Operations and Maintenance.  Condition noted on or about 01/12/10.
c- Bayway Chemical Plant, Zinc Unit - The P2S5 Bin Transporting, Inverting
and
Charging Procedure did not specifically indicate that only one bin is to
be inverted at
a time.  Workers routinely functioned both inverters (9INV1 and 9INV2)
simultaneously which have resulted in improper clamping with a bin
slipping from the
inverter and spilling product.  During the event workers were exposed to
H2S when
the P2S5 contacted water.  Condition noted on or about 12/02/10.

Issued

May 21, 2010

Abate by

Aug 1, 2010

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.119(f)(4):  The employer did not implement safe work practices
for employees
and contractor employees to provide for the control of hazards during
operations such as
lockout/tagout; confined space entry; opening process equipment or piping;
and control over
entrance into a facility by maintenance, contractor, laboratory, or other
support personnel:
a- Bayway Chemical Plant, Dispersants and Vis-J Units - The employer
failed to
implement General Safety Rule 1.9 Process Operation (Visitors Sign-In
Procedures) to
account for workers on process units.  Both Infineum and contract
employees
failed to
sign in/out at the Main Control Room and Polybutene Control House.
Condition
noted on or about 01/27/10.

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $4,500 · Current $4,500

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $4,500 · Current $4,500

Issued

May 21, 2010

Abate by

Jul 21, 2010

Penalty

Initial $4,500 · Current $4,500

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $4,500 · Current $4,500

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $4,500 · Current $3,000 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 the process safety information in
29 CFR
1910.119(d)) before use or in a safe and timely manner:
a- Bayway Chemical Plant, Outside Compressor Room, Vis-J Unit - Excess
vibration
was observed on the 6 inch ammonia header from the C3 Ammonia Compressor
high
pressure side to SV4659.  Condition noted on or about 12/01/09.
b- Bayway Chemical Plant, Finishing Section, Vis-J Unit - The 6P13A,
bottoms pump
for 6T1 was observed in operation with a non functioning pressure gauge.
Condition
noted on or about 12/01/09.
c- Bayway Chemical Plant, Second Deck 6Es, Vis-J Unit - An inoperative
pressure
gauge was observed for the Ammonium Hydroxide to overhead system.
Condition
noted on or about 12/01/09.
d- Bayway Chemical Plant, POA Unit - Tell tale pressure gauges for RDs on
P16A/B
were inoperative.  Condition noted on or about 12/01/09.
e- Bayway Chemical Plant, Ground Floor Reactor Building, Dispersants Unit
- A 3
inch hot oil line for the 8R4 jacket was observed with visible vibration
and
movement.  Condition noted on or about 01/13/10.
f- Bayway Chemical Plant, 3rd Floor Mezzanine Reactor Building,
Dispersants Unit -
A pressure gauge for the 8R1X was inoperative.  Condition noted on or about
01/13/10.

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $4,500 · Current $4,500

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $4,500 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(m)(6):  The incident investigation report was not reviewed
with all affected
personnel, including contract employees whose job tasks are relevant to
the incident findings:
a- Bayway Chemical Plant, Reactor Building, Dispersants Unit - On 07/07/10,
maintenance employees were in the process of replacing the 8D13 bottom
valve when
they were exposed to a release of overhead vapor containing Chlorine,
Hydrochloric
Acid
and Maleic Anhydride from 8R3.  An incident investigation was performed and
completed on 09/15/09 but was never reviewed with affected employees.
Condition
noted on or about 11/24/09.

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $4,500 · Current $3,000 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
were being
followed:
a- Bayway Chemical Plant, Dispersants, Zinc, POA and Vis-J Units - The
Infineum
2007 TCPA/OSHA PSM Management System Documentation and Self Assessment
Plan did not include a review of pressure vessel inspection records.
Condition noted
on or about 11/30/09.
b- Bayway Chemical Plant, Dispersants, Zinc, POA and Vis-J Units -
Infineum relies
on Eii, Inc. to provide subcontractors to work at the facility.  Eii also
obtains and
evaluates subcontractor safety and health performance and programs prior
to them
working at Infineum.  However, the Infineum 2007 TCPA/OSHA PSM Management
System Documentation and Self Assessment Plan did not include a review
Eii's
procedure to evaluate subcontractor safety and health performance along
with an
inspection of respective subcontracor records.  Condition noted on or
about 12/16/09.

Issued

May 21, 2010

Abate by

Jul 2, 2010

Penalty

Initial $1,875 · Current $1,875

Issued

May 21, 2010

Abate by

Sep 16, 2010

Penalty

Initial $4,500 · Current $4,500