OSHA Inspection: MONTGOMERY CHEMICAL LLC

Issued

Jun 21, 2011

Abate by

Jul 26, 2011

Penalty

Initial $3,850 · Current $2,310 Reduced

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 accurate piping and instrument diagrams (P&ID'S):
a)  Sodium Borohydride Plant -  The employer's piping and instruments
diagrams were
incomplete as PID-106 does not show where the trimethylborate (TMB) flows
into and
from Tank T-1404 on or about December 21, 2010.
b)  Sodium Borohydride Plant - Employer's piping and instruments diagrams
for T-1414
(PID-104) refers to PID-604 which has not been developed.  It also
incorrectly indicates
that the TMB feed to the process is from T-1404  on or about December 21,
2010.
c) Sodium Borohydride Plant - Employers Piping and instruments diagram
PID-603 for
the methanol storage tank does not indicate a feed from T-1414 on or about
December
21, 2010.
d)  Sodium Borohydride Plant - Employers Piping and instrument diagram
PID-101 for
the TMB-Blend Tank incorrectly indicates that methanol feed from tank 1402
is
diagramed on PID-604, it should indicate PID-603 on or about December 21,
2010.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Aug 31, 2011

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D):  Process safety information pertaining to the
equipment in the
process did not include the relief system design and design basis:
a)  Sodium borohydride Plant - Employers process safety information did
not include the
design basis for the relief system for tanks and process vessels used to
process
methanol
and trimethylborate including T-1402 the sixteen thousand gallon methanol
storage tank,
reactor R-1408 the trimethylborate reactor and T-1422 a 300 gallon
methanol tank on or
about March 23, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Sep 22, 2011

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E):  Process safety information pertaining to the
equipment in the
process did not include the ventilation system design:
a) Sodium Borohydride Plant -  Employers process safety information did
not include the
ventilation system design for the process building where large amounts of
methanol were
processed and methanol containing wastes were flushed out of the
centrifuges on or about
January 19, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Jul 26, 2011

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F):  Process safety information pertaining to the
equipment did not
include the design codes and standards employed:
a) Sodium Borohydride Plant - Employers process safety information did not
include the
design codes and standards employed for protecting enclosures containing
ordinary
electrical equipment that are located in hazardous rated area.  The
process control room
is partially inside a Class I division II hazardous area, and contains
non-rated electrical
equipment such as computers and monitors on or about March 23, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Oct 26, 2011

Penalty

Initial $3,850 · Current $2,310 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 were resolved in a timely manner
and that the
resolution was documented:
a) Sodium Borohydride Plant - Employers 2008 Process Hazard Analysis for
the New
DC-1420 Recovery Column included a list of Prioritized List of
Recommendations, no
documentation was available indicating the status of these items including
but
not limited
to :
1)  Employer's 2008 Process hazard analysis indicated that they should
evaluated
the need for addition pressure relief for T-1422.  The status of this
items was
"incomplete" on or about March 23, 2011.
2)  Employer's 2008 Process hazard analysis indicated a need to
re-evaluate the
decision to vent the reflux drum to the storage tank.  The status of this
item was
"incomplete" on or about March 23, 2011.
3)  Employer's 2008 process hazard analysis indicated a need to confirm the
electrical classification of equipment in the T-1412 area.  The status of
this items
was "being processed" on or about March 23, 2011.
4)  Employer's 2008 process hazard analysis indicated a need to evaluate
the
adequacy of pipe supports on the DC-1420 feed line.  The status of this
item
was
"incomplete" on or about March 23, 2011.
5)  Employer's 2008 process hazard analysis indicated a need to evaluate
emergency procedures for release of methanol in the upper tank farm area.
The
status of this item was "incomplete" on or about March 23, 2011.
6)  Employer's 2008 process hazard analysis indicated a need to review the
standard for issuance of hot work permits in the tank farm area.  The
status of
this item was "incomplete" on or about March 23, 2011.
b) Sodium Borohydride Plant - Employers 2001 Process Hazard Analysis of
the Sodium
Borohydride Manufacturing Process included a Prioritized List of
Recommendations, no
documentation was available indicating the status of these items including
but not limited
to :
1)   Employer's 2001 process hazard analysis indicated a need (scenario
14) to
check if methanol tank vent line sizing meets NFPA, no documentation was
available indicating the status this item on or about March 23, 2011.
2)   Employer's 2001 process hazard analysis indicated a need (scenario
15) to
add annual grounding test for the methanol tank to the mechanical integrity
program, no documentation was available indicating the status of this item
on or
about March 23, 2011.3)  Employer's 2001 process hazard analysis indicated
a need (scenario 15) to
continue with plans to develop mechanical integrity written program and
schedule,
no documentation was available indicating the status of this item on or
about
March 23, 2011.
4)  Employer's 2001 process hazard analysis indicated a need (scenario 19)
to
include methanol skirt inspection in the mechanical integrity program, no
documentation was available indicating the status of this item on or about
March
23, 2011.
5)  Employer's 2001 process hazard analysis indicated a need to ensure
that the
new mixing tank has sufficient emergency relief, no documentation was
available
indicating the status of this item on or about March 23, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Nov 24, 2011

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) Sodium Borohydride Plant - Employer conducted a full Process Hazard
Analysis in
2001 on the sodium borohydride process.  This process hazard analysis had
never been
updated or revalidated on or about February 22, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Nov 24, 2011

Penalty

Initial $3,850 · Current $2,310 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(A):  The employer's written operating
procedures covering safety
and health considerations did not address the properties of, and hazards
presented by the
chemicals used in the process:
a)  Sodium Borohydride Plant - Trimethylborate Process standard operating
guideline
SOG#1401 did not include the properties and hazards of boric acid which is
fed into the
process from a large sack on or about February 10, 2011.
b)  Sodium Borohydride Plant - Trimethylborate Process standard operating
guideline
SOG#1401 did not include the properties and hazards of methanol which is
fed into the
system from a large storage tank on or about February 10, 2011.
c)  Sodium Borohydride Plant - Trimethylborate Process standard operating
guideline
SOG#1401 did not include the properties and hazards of Trimethylborate
which is
produced in the process on or about February 10, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Nov 24, 2011

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(B):  The employer's written operating
procedures covering safety and
health considerations did not address the precautions necessary to prevent
exposure, including
engineering controls, administrative controls, and person protective
equipment:
a)  Sodium Borohydride Plant:  Trimethylborate Process Standard Operating
Guideline
#1401 did not include ensuring that ventilation systems were turned on
prior to starting
up and operating the process on or about February 10, 2011.
b) Sodium Borohydride Plant: Trimethylborate Process Standard Operating
Guideline
#1401 did not include the type of personal protective equipment required
to work in the
plant and to conduct procedures such as unblocking the boric acid feed
line and taking
samples at tank 1406, reactor 1408, the static mixer and the evaporator
sample tank, on
or about February 10, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Nov 24, 2011

General-duty citation text

29 CFR 1910.119(f)(3):  The employer did not certify annually that the
operating procedures
are current and accurate:
a)  Sodium Borohydride Plant:  Trimethylborate Process Standard Operating
Guideline
#1401 was dated August 8, 2007 was not certified as being currently up to
date and
accurate and did not include precautions necessary to prevent exposure on
or about
February 10, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Oct 26, 2011

Penalty

Initial $3,850 · Current $2,310 Reduced

General-duty citation text

29 CFR 1910.119(h)(2):  The employer did not fulfill all responsibilities
described in sections
(i) through (vi) of this paragraph when employing contractors in covered
process areas:
a) Sodium Borohydride Plant - The employer, when selecting a contractor,
did
not obtain and evaluate information regarding the contract employer's
safety
performance and programs, on or about January 19, 2011
b) Sodium Borohydride Plant - The employer did not inform contract
employers
of the known potential fire, explosion, or toxic release hazards related
to the
contractor's work and the process, on or about January 19, 2011.
c) Sodium Borohydride Plant - The employer did not explain to contract
employers the applicable provisions of the emergency action plan, on or
about
January 19, 2011.
d) Sodium Borohydride Plant - The employer  did not implement safe work
practices to control the entrance, presence, and exit of contract
employers and
contract employees in covered process areas, on or about January 19, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Jan 26, 2012

Penalty

Initial $3,850 · Current $2,310 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR 1910.119(j)(2):  The employer did not establish and implement
written
procedures to
maintain the ongoing mechanical integrity of process equipment:
a)  Sodium Borohydride Manufacturing Plant - Employer operates a chemical
plant
containing equipment such as metal piping, mechanical pumps, mechanical
valves and
pressure relief valves that need regular maintenance to keep them in
proper operating
condition. The employer had not established or implemented a program to
maintain the
integrity of the process equipment, on or about March 2, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Jul 26, 2011

Penalty

Initial $3,850 · Current $2,310 Reduced

General-duty citation text

29 CFR 1910.119(l)(1):  The employer did not establish and implement
written procedures to
manage changes to process chemicals, technology, equipment, and
procedures; and, changes to
facilities that affect a covered process:
a)  Sodium Borohydride Plant - Plant operation was changed from a campaign
flow with
scheduled shutdowns to a continuous operations mode without scheduled
shutdowns.
Management of Change policy was not implemented to review and authorize
this change,
on or about March 22, 2011.
b)  Sodium Borohydride Plant -  Plant process equipment changes were made
when
Centrifuge cv-1112a was bypassed because of a breakdown.  Manage of Change
Policy
was not implemented to review and authorize this change on or about March
22, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Jul 26, 2011

Penalty

Initial $3,850 · Current $2,310 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR 1910.119(m)(5):  The employer did not establish a system to
promptly address and
resolve the incident investigation report findings and recommendations:
a)  Sodium Borohydride Manufacturing Plant - Employees, chemical operators
and
maintenance mechanics are exposed to hazards of the Sodium Hydride reactor
becoming
over filled during rework of sodium hydride materials.  The employer did
not promptly
address and resolve findings and recommendations from the investigation of
the incident
that occurred on April 15, 2010, when a reactor overfilled in Area 3,
resulting in the
release of sodium hydride and sodium metal, observed on or about March 2,
2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Jul 26, 2011

Penalty

Initial $3,850 · Current $2,310 Reduced

Hazardous substances 1660

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:
a)  Sodium Borohydride Manufacturing Plant - Employees, chemical operators
and
maintenance mechanics are exposed to hazards during the process operation.
The
employer had not certified that they had evaluated their compliance with
the process
safety management standard as required on or about January 19, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.tives

Issued

Jun 21, 2011

Abate by

Jul 26, 2011

Hazardous substances 1660

General-duty citation text

29 CFR 1910.119(m)(4)(ii):  The report prepared at the conclusion of the
investigation of an
incident which resulted in, or could reasonably have resulted in a
catastrophic release of highly
hazardous chemical in the workplace, did not include the date the
investigation began:
a)  Sodium Borohydride Manufacturing Plant - Employees, chemical
operators, and
maintenance mechanics were exposed to hazards of spill of flammable water
reactive
chemicals in area 3 during the reworking of this material on April 15,
2010.  The
employers incident report for this incident did not indicate when the
investigation was
initiated, on or about March 2, 2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.

Issued

Jun 21, 2011

Abate by

Jul 6, 2011

General-duty citation text

29 CFR 1910.307(c)(2)(i):  Electrical equipment in hazardous (classified)
locations was not
marked to show the class, group and operating temperature for which it is
approve: (classified)
location:
A) Sodium Borohydride Plant - SBH centrifuge cf-1314 was replace with
Westfalia
Model TSD-35-03-977.  The motor was not labeled as being approved for
hazardous
locations and the equipment was installed in a Class I division 2 area of
the plant.
Exposing employees to a fire or explosion hazard on or about March 22,
2011.
Abatement certification required within 10 days after abatement date.  The
certification shall
include a statement that abatement is complete, date and method of
abatement, and states
employees and their representatives were informed of this abatement.