OSHA Inspection: TROY CHEMICAL CORPORATION

Issued

Jul 6, 2011

Abate by

Aug 22, 2011

Penalty

Initial $4,500 · Current $4,500

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:
a) Building 71 and Fractionator Area
Process chemistry for the production of Polyphase Part II did not include
comprehensive
documentation of chemistry of all reactions, by-products and side
reactions
that might take place
in credible abnormal operations, no documentation of thermodynamic
information such as heat
of reaction or kinetic data defining rates of reaction.
Violation occurred on or about 01/07/2011.

Issued

Jul 6, 2011

Abate by

Aug 22, 2011

Penalty

Initial $6,300 · Current $6,300

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) Building 71 and Fractionator Area
The employer did not have adequate documentation for the design and design
basis for the
pressure relief system for the fractionator when used in Dimethyl
Sulfoxide (DMSO) service.
Violation occurred on or about 01/07/2011.
b) Building 71 and Fractionator Area
The employer did not have adequate documentation for the design and design
basis
for the
pressure relief system for the fractionator when used in methanol service.
The employer did not
have documentation such as, but not limited to, causes of system
overpressure, including
assumptions and calculations for basis of sizing,the name of the equipment
the pressure relief
design was intended and safe disposal of relieving material.
Violation occurred on or about 01/07/2011.

Issued

Jul 6, 2011

Abate by

Aug 22, 2011

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:
a) Building 71 and Fractionator Area
The employer did not provide any hazardous area classification
documentation for locations in
which methanol was being processed and electrical equipment was used.
Violation occurred on or about 01/07/2011.

Issued

Jul 6, 2011

Abate by

Aug 22, 2011

Penalty

Initial $6,300 · Current $6,300

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) Building 71 and Fractionator Area
The employer did not comply with recognized and and generally accepted
good engineering
practices, in that the set pressure of the rupture disk (55 PSI), exceeded
the maximum allowable
working pressure of the fractionator vessel (50 PSI).
Violation occurred on or about 01/07/2011.r

Issued

Jul 6, 2011

Abate by

Aug 22, 2011

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.119(f)(1): The employer did not develop and implement written
operating
procedures that provided clear instructions for safety conducting
activities in each covered
process consistent with the process safety information:
a) Building 71 and Fractionator Area
The employer did not develop and implement written shift change
procedures. The employer
operates the Polyphase Part II and distillation methanol recovery process
on three shifts and does
not have written shift change procedures to ensure that essential
information is communicated
to the incoming shift.
Violation occurred on or about 01/07/2011.d

Issued

Jul 6, 2011

Abate by

Aug 22, 2011

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(C):  The employer's written operating
procedures covering safety
and health considerations did not address the control measures to be taken
if physical contact or
airborne exposure occurs:
a) Building 71 and Fractionator Area
Batch Instructions for Polyphase Part II, item #I53002-27 did not include
control measures to
be taken for accidental physical contact and/or inhalation of hazardous
chemicals.
Violation occurred on or about 01/07/2011.

Issued

Jul 6, 2011

Abate by

Aug 22, 2011

Penalty

Initial $6,300 · Current $6,300

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) Building 71 and Fractionator Area
The employer did not conduct inspection and testing on process equipment
for the Polyphase
Part II and distillation methanol recovery process. Equipment including,
but not limited to,
fractionator, heat exchangers, associated pumps and methanol piping.
Violation occurred on or about 01/07/2011.

Issued

Jul 6, 2011

Abate by

Aug 22, 2011

Penalty

Initial $6,300 · Current $6,300

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) Building 71 and Fractionator Area
The employer did not conduct a compliance audit to ensure compliance with
process safety
management requirements for Polyphase Part II and distillation methanol
recovery process.
Violation occurred on or about  01/07/2011.