OSHA Inspection: E I DU PONT DE NEMOURS & CO INC (DUPONT BEAUMONT)

Issued

May 1, 2012

Abate by

Jun 4, 2012

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.106(i)(3)(ii): Unfired vessels were not constructed in
accordance with the Code
for Unfired Pressure Vessels, Section VIII of the ASME Boiler and Pressure
Vessel Code-1968:
a)This condtion was observed at the, at E. I. du Pont de Nemours and
Company, in
Beaumont, TX, in the Aniline Unit where the employer did not ensure that
the Purge
Column was constructed in accordance with Section VIII of the ASME Boiler
and
Pressure Vessel Code, when the employer failed to ensure RV-J-0111
relieved to a safe
location, exposing employees to a toxic material.

Issued

May 1, 2012

Abate by

Jun 4, 2012

Penalty

Initial $7,000

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)This condition was most recently observed, at the E. I. du Pont de
Nemours and
Company in Beaumont, TX when the employer failed to identify and examine
that the
loss of reflux could result in an overpressure condition on the Purge
Column in
accordance API Standard 521.
b) This condition was most recently observed, at the E. I. du Pont de
Nemours and
Company in Beaumont, TX when the employer failed to identify and examine
that liquid
level above the level chamber could result in an overpressure condition on
the Purge
Column.on

Issued

May 1, 2012

Abate by

Jun 4, 2012

General-duty citation text

29 CFR 1910.119(e)(1):  The process hazard analysis was not appropriate to
the
complexity of
the process and did not identify, evaluate, and address the control of the
hazards involved in the
process.
a)This condition was observed at the E. I. du Pont de Nemours and Company,
in
Beaumont, TX, where the employer did not ensure that the Process Hazard
Analysis
(PHA) was appropriate to the complexity of the process, and that the PHA
identified,
evaluated and addressed control of the hazard involved in the process when
the employer
failed to ensure that RV-J-0111 relieved to a safe location, therefore
exposing employees
to an atmosheric release of toxic material.c

Issued

May 1, 2012

Abate by

May 4, 2012

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(f)(1):  The employer's shall develop and implement written
operating
procedures that provide clear instructions for safely conducting
activities involved in each
covered process consistent with the process safety information and shall
address steps for initial
startup:
a)The condition was most recently observed at E. I. du Pont de Nemours and
Company,
in Beaumont, TX,  the employer did not ensure that operating procedures
used in the
initial startup of the purge column, provided clear instructions which was
used to bring
the column up after a turnaround.  The use of the procedure resulted in
over pressuring
the column and relieving carcinogens such as 4-ADP and Aniline into the
atmosphere.

Issued

May 1, 2012

Abate by

Jun 4, 2012

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D):  The employer's written operating procedures
covering the steps
for each operating phase did not address emergency shutdown including the
conditions under
which emergency shutdown is required, and the assignment of shutdown
responsibility to
qualified operators to ensure that emergency shutdown is executed in a
safe and timely manner:
a)This condition was most recently observed, at E. I. du Pont de Nemours
and Company,
in Beaumont, TX, in the Aniline Unit where the employer did not ensure
that the
operator on CCR#1 had emergency shutdown procedures to ensure that the
responsibility
of an emergency shutdown was executed in a safe and timely manner, during
the incident
on November 3, 2011.ber

Issued

May 1, 2012

Abate by

Jun 4, 2012

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(g)(1)(i):  The employer did not train each employee,
before being involved
inoperating a newly assigned process, in an overivew of the process and in
the operating
procedures as specified in 29 CFR 1910.119(f):
a)This condition was most recently observed, at E. I. du Pont de Nemours
and Company,
in Beaumont, TX, in the Aniline Unit where the employer did not ensure
that all board
operators working on CCR#1, the Aniline Unit, were trained in the
operating procedures
before operating a newly assigned process.

Issued

May 1, 2012

Abate by

Jun 4, 2012

General-duty citation text

29 CFR 1910.119(g)(3):  The employer did not prepare a means of verifying
that the employee
had received and understood the training required by 29 CFR 1910.119(g):
a)This condition was most recently observed, at E. I. du Pont de Nemours
and Company,
in Beaumont, TX, in the Aniline Unit where the employer did not ensure
that
all board
operators working on CCR#1, the Aniline Unit, had a prepared record
verifying that each
employee involved in operating a process a had received and understood the
training
required.

Issued

May 1, 2012

Abate by

Jun 4, 2012

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:
a)This condition was most recently observed in the Aniline and DHN process
areas of the
DuPont facility in Beaumont, Texas when the employer operated deficient
process
equipment without taking necessary means to assure safe operation.
Deficiencies present
included defective heat tracing, steam leaks in areas where operators are
required to enter
and do work, and corrosion-damaged equipment.
Examples of deficient conditions include:
1.Heavy steam and condensate sprays from damaged steam tracing in
walk/pathway
areas that are required by operators to access equipment in the DHN and
Aniline
production areas.
2.Damaged heat trace system with open ends blowing steam into walkway
areas and
causing external corrosion on piping and other process equipment.
3.Severely corrosion-damaged ducting in fresh air system of DHN ECR.
4.The Letdown Separator (7020-06) vessel head, nozzle, and associated
piping
(spool A625) integrity is questionable due to heavy external corrosion.
b)This condition was most recently observed in piping in the Aniline and
DHN process
areas of the DuPont facility in Beaumont, Texas, when the employer
operated deficient
process piping systems without taking necessary means to assure safe
operation.
Deficiencies included valves with missing handles, piping systems with
uncontrolled
external corrosion, and open-ended process piping.

Issued

May 1, 2012

Abate by

Jun 4, 2012

General-duty citation text

29 CFR 1910.119(d):   The employer did not develop a written compilation
of process safety
information on hazardous chemicals in the process, the technology of the
process,
and the
equipment in the process before conducting the process hazard analysis:
a)This condition was most recently observed at the E. I. du Pont de
Nemours and
Company in Beaumont, TX, in the Aniline Unit, when the employer did not
complete
a compilation written process safety information before conducting the
2009 Process
Hazard Analysis, when the FAA# on the Purge Column was not consistent
throughout
Process Safety Information.
b)This condition was most recently observed at the E. I. du Pont de
Nemours and
Company, in Beaumont, TX, in the Aniline Unit, when the employer did not
complete
a compilation written process safety information before conducting the
2009 Process
Hazard Analysis, when the P&ID B161019 did not reflect the correct set
pressure for
RV-J-0111.