OSHA Inspection: PANDORA METHANOL LLC

Issued

2012-07-05 00:00:00

Abate by

2012-08-07 00:00:00

Penalty

Initial $4900.00 · Current $3430.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B):  The employer did not complete a compilation
of written process
safety information (PSI) including the piping and instrument diagrams
(P&ID'S) before
conducting any process hazard analysis required by the standard:
This violation was most recently observed in the Pandora Methanol (OCI
North America) site,
when the employer failed to document complete and accurate Process &
Instrument Diagrams
(P&ID) before conducting Ammonia process hazard analysis (PHA).
The following are instances of changes to the ammonia process that are not
reflected on the
P&IDs used for the PHA:
(a)04541-2-50-02J rev5 (used for PHA)
-6" GH-021801-DA3A was blinded and abandoned in place
-4" block valve on recycle Hydrogen is blinded
-2" and 8" valves added to nitrogen pipeline

Issued

2012-07-05 00:00:00

Abate by

2012-08-07 00:00:00

General-duty citation text

29 CFR 1910.119(d)(3)(i)(G): The employer did not complete a compilation
of written process
safety information (PSI) including the material and energy balances before
conducting any
process hazard analysis required by the standard:
This violation was most recently observed in the Pandora Methanol (OCI
North America) site,
when the employer failed to document complete and accurate material and
energy balance before
conducting Ammonia process hazard analysis (PHA). The material and energy
balance used for
the 2011 PHA was missing critical information and did not accurately
reflect the process as it
exist in the field. Information such as flow rates, temperatures and
mixture compositions were
either unknown, not made available or inaccurate.
a)Node 1A mixture of Hydrogen, nitrogen and ammonia arrives at Valve
XV-5599
at a rate of ? SCFH. Composition is ?% Ammonia, ?% Hydrogen and
?% Nitrogen
Node 2A mixture of Nitrogen and Ammonia leaves valve XV-5599 at a rate of
? SCFH. Composition is ?% Ammonia, ?% Hydrogen and ?%
Nitrogen
Node 3Condensate from the steam superheater is returned from the steam
drum,
and superheated steam at a rate of 59,000 LB/HR, ?psig and ? deg
Celsius is fed to the 550 psig superheated steam header
Node 4The recycle steam from the Ammonia converter flows at a rate of ?
SCFH, ? psig and ? deg Celsius into the steam superheater, where it
is collected while generating ? lb/hr steam
Liquid ammonia is removed from the bottom of the ammonia separator at a
rate
of ? lb/hr, and the recycle gas leaves the top of the ammonia separator at
a rate
of ? SCFH, ? psig and ? deg celsius and sent to the cold heat exchanger
where
it is heated to ? deg Celsius and sent to the Syn Gas Compressor 3rd stage
suction
Node 9Ammonia liquid is removed from the ammonia accumulator to the warm
ammonia product heater and then let down to the first ammonia chiller and
then the ammonia accumulator, where it is stored at a ate of 59,000 lb/hr,
? psig and ? deg Celsius
Liquid ammonia at a rate of ? lb/hr, ? psig, deg celsius is also taken
from the
ammonia accumulator to the ammonia accumulator vent gas chiller
Node 10Ammonia rundown product pumps, 215P-101-01/02, boost pressure to ?
psig
NoteThe current process receives Hydrogen from pipeline, however stream #6
(Pipeline Hydrogen) indicated no flow rate.

Issued

2012-07-05 00:00:00

Abate by

2012-08-07 00:00:00

Penalty

Initial $4900.00 · Current $3430.00 Reduced

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.
This violation was most recently observed at the Pandora Methanol (OCI
North America) site,
when the employer failed to ensure that the process hazard analysis was
appropriate to the
complexity of the process and did not posses all of the required process
safety data to identify,
evaluate and control the hazards involved in the process.

Issued

2012-07-05 00:00:00

Abate by

2012-08-07 00:00:00

Penalty

Initial $4900.00 · Current $3430.00 Reduced

General-duty citation text

29 CFR 1910.119(i)(1):  The employer did not perform a pre-startup safety
review for modified
facilities when the modification is significant enough to require a change
in the process safety
information.
The employer did not perform a pre-startup safety review (PSSR) prior to
the introduction of
highly hazardous chemicals to a modified process. This violation was most
recently observed
in the Pandora Methanol (OCI North America) site, when the employer
installed a bypass on
the Steam Superheater E-101 due to tube leakage and put the equipment in
service prior to
performing a pre-startup safety review.

Issued

2012-07-05 00:00:00

Abate by

2012-07-23 00:00:00

Penalty

Initial $4900.00 · Current $4900.00

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 observed on or about June 13, 2012, in the
production area where
process piping was observed operating without a bull plug in place to
complete the closed
end of the piping.
b) This condition was observed on or about June 13, 2012, in the Ammonia
Process
Area, where utility piping connected to the steam jacket of 216V-109
Ammonia Vent
Drum was observed having a rupture in the line, expelling steam and
condensate from
one of the pipe unions.

Issued

2012-07-05 00:00:00

Abate by

2012-07-10 00:00:00

Penalty

Current $2100.00

General-duty citation text

29 CFR 1910.119(l)(2)(iv):  The employer did not  implement written
procedures to manage
changes to process chemicals, technology, equipments, and procedures; did
not assure that the
necessary time period for the change was addressed prior to any change:
The employer did not implement Management of Change procedure
(PSM-01-0010) to manage
changes in Ammonia process equipment and piping. This violation was most
recently observed
in the Pandora Methanol (OCI North America) site, when the employer did
not document
the expiration date for a temporary MOC to install a bypass on E-101 due
to tube leakage.

Issued

2012-07-05 00:00:00

Abate by

2012-07-31 00:00:00

Penalty

Initial $2800.00 · Current $2800.00

General-duty citation text

29 CFR 1910.219(c)(3):  Vertical or inclined shafting was not enclosed
with stationary casing(s):
a) This condition was observed on or about June 13, 2012, where the
exposed rotating
shaft on a pump was observed to be unguarded.