OSHA Inspection: GREAT LAKES CHEMICAL CORPORATION

Issued

Jun 6, 2012

Abate by

Sep 1, 2012

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(f)(1)(iv):  The employer's written operating procedures
did not address
requirements for the safety systems and their functions:
The Employer does not list in its operating procedures specific safety
systems and their
functions such as, but not limited to the following:
a. The chlorine detection system in the rail-car loading/unloading area;
b. The ammonia detection system located at the ammonia storage tank
(TK-01-027);
c. The chlorine rail-car compressed air padding system reverse flow
prevention system.
These violations occurred on or about January 19, 2012 in the Bromine Unit
where these
conditions exposed employees to the hazards associated with uncontrolled
releases of ammonia
and/or chlorine into the atmosphere.
Pursuant to 29 CFR 1903.19, within (10) calendar days of the abatement
date
the employer must
submit documentation showing that it is in compliance with the standard,
including describing
the steps that it is taking to ensure that specific safety systems and
their functions are listed in
its operating procedures.

Issued

Jun 6, 2012

Abate by

Oct 1, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(e)(5):  The employer did not develop a written schedule as
to when the
actions recommended by the process hazard analysis team are to be
completed:
The employer does not ensure that a written schedule is completed for
action
items resulting
from the 2007 Bromine Unit Process Hazard Analysis such as but not limited
to:
a. The Bromine Unit Facility Sitting Checklist findings.
(1)Control room is located in unreasonable proximity to highly hazardous
chemical
storage or process area, i.e. bromine and methyl bromide storage tanks.
(2)A release at an adjacent unit can cause a potential problem, i.e.
methyl bromide
release
(3)Control room is not capable of withstanding toxic releases, i.e. not a
positive
pressure room
(4)Hazardous materials are routed in close proximity to the control room,
i.e.
bromine lines are run next to the control room wall
b.  The Bromine Unit Human Factors Checklist findings.
(1)Different processes are run concurrently from the same control room and
operators are not
cross-trained on the different processes.
These violations occurred in the Bromine Unit where these conditions
exposed employees
to the hazards associated with uncontrolled releases of ammonia, chlorine,
sulfur dioxide
and/or bromine into the atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including
describing the steps that it is taking to ensure that a written schedule
is completed for action
items resulting from the 2007 Bromine Unit Process Hazard Analysis.

Issued

Jun 6, 2012

Abate by

Nov 1, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(2):  The employer did not establish and implement
written procedures to
maintain the on-going mechanical integrity of process equipment:
The employer does not implement its mechanical integrity program, which
references the
procedures identified in API 510 and API 572, for establishing thickness
measurement
locations (TMLs) for pressure vessels and piping, when inspecting and
testing
pressure
vessels and piping such as, but not limited to the following:
a.Chlorine Evaporators (EV-01-058 & EV-01-078)
b.Sulfur Dioxide Storage Tank (TK-01-028)
c.Ammonia Storage Tank (TK-01-027)
d.Bromine Tower Exchanger (HE-01-096)
e.Liquid and/or vapor chlorine lines PG-01-301, PG-01-0303, PG-01-0307,
PG-01-
0447, PG-01-0834 and PG-01-0835.
These violations occurred in the Bromine Unit where the conditions exposed
employees
to the hazards associated with uncontrolled releases of ammonia, chlorine,
sulfur dioxide
and bromine liquid and/or vapor into the atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including
describing the steps that it is taking to ensure that a mechanical
integrity (MI) program
procedure for establishing thickness measurement locations (TMLs) for
pressure vessels and
piping is implemented.

Issued

Jun 6, 2012

Abate by

Sep 1, 2012

Penalty

Initial $7,000 · Current $7,000

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:
In the Central Plant Bromine Unit, the employer does not ensure that
inspections and
testing was completed in accordance with recognized and generally accepted
good
engineering practices for such equipment as but not limited to:
a)The Chlorine vaporizers (EV-01-058 & EV-01-078)
b)The Bromine Tower Exchanger (HE-01-096)
c)The Anhydrous Ammonia Storage Tank (TK-01-027).
These violations occurred in the Bromine Unit where these conditions
exposed employees
to the hazards associated with not being provided with an early warning of
uncontrolled
releases of ammonia and chlorine liquid and/or vapor into the atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including
describing the steps that it is taking to ensure that equipment is
inspected and tested in
accordance with recognized and generally accepted good employer must
submit documentation
showing that it is in compliance with the standard, including describing
the steps that it is taking
to ensure that equipment is inspected and tested in accordance with
recognized and generally
accepted good engineering practices such as API 510.

Issued

Jun 6, 2012

Abate by

Sep 1, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(4)(ii):  Inspections and testing procedures performed
on
process equipment
to maintain its mechanical integrity, did not follow recognized and
generally accepted good
engineering practices:
The employer does not follow recognized and generally accepted good
engineering
practices (RAGAGEP) when it fails to complete a pre-repair pop test and/or
reduce the
inspection interval as per API 576 or GLCC MI Procedure IT-ME-002 for
relief devices
such as but not limited to:
a.RV-01-058 - Chlorine
b.RV-01-078 - Chlorine
These violations occurred in the Bromine Unit where these conditions
exposed employees
to the hazards associated with the uncontrolled release of chlorine
liquid and/or vapor
into the atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including
describing the steps that it is taking to ensure that RAGAGEPs are
followed for repair of relief
devices.

Issued

Jun 6, 2012

Abate by

Sep 1, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(4)(iii):  The frequency of inspections and tests of
process equipment to
maintain its mechanical integrity, was not consistent with applicable
manufacturers'
recommendations and good engineering practices:
The employer does not inspect piping on a frequency determined by
recognized and
generally accepted good engineering practices (RAGAGEP) for such lines as,
but not
limited to the following liquid and/or vapor chlorine lines:
a)PG-01-0303: Last Inspected: 7/11/2006 Missed 7/11/2007 based on report
but
7/11/2011 for 5 years, Class 1
b)PG-01-0307: Last Inspected: 7/11/2006 Missed 7/11/2007 based on report
but
7/11/2011 for 5 years, Class 1
c)PG-01-0447: Last Inspected: 7/13/2007, Missed 7/13/2007 based on report
but
7/13/2011 for 5 years, Class 1
d)PG-01-0834: Last Inspected: 3/25/2008, Missed 3/25/2009 based on
remaining
life of 2.2, Class 1
e)PG-01-0845:  Last Inspected: 4/9/2007, Missed 5/21/2010 based on
remaining
life of 6.2, Class 1
These violations occurred in the Bromine Unit where these conditions
exposed employees
to the hazards associated with the uncontrolled release into the
atmosphere of chlorine
liquid and/or chlorine vapor.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including
describing the steps that it is taking to ensure that it is inspecting
piping using a frequency
determined by recognized and generally accepted good engineering practices
(RAGAGEP).

Issued

Jun 6, 2012

Abate by

Oct 1, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(4)(iv):  The documentation of the inspection or test
that been performed on
process equipment to maintain its mechanical integrity did not identify
the date of the inspection
or test, the serial number or other identifier of the equipment on which
the inspection or test was
performed, a description of the inspection or test, and the results of the
inspection or test:
The employer does not identify the date of the test/inspection, the
function item number
or identifier of the equipment/piping on which the test/inspection is
performed,
a
description of the test/inspection, and the results of the test/inspection
up to and including
exercising the final element of the control for such items as but not
limited to:
a.Interlock CS 2450 - A series of interlocks and/or permissive(s) used to
ensure
that chlorine flow to the bromine tower is stopped when conditions such as
low
brine flow, low column bottom pressure and high tower pressure at top of
column
are detected or an E-Stop is activated
b.Chlorine Detection System consisting of sensors (AE-258, AE-259, AE260,
AE-
261),transmitters, and alarm logic/annunciation
c.Ammonia Detection System consisting of sensors (AE-227A-D),
transmitter(s)
(AT-227), and alarm logic/annunciation
d.Chlorine Unloading - Compressed air rail car padding system consisting of
pressure sensor/transmitter (PIT-551), control logic, and two solenoid
valves
(PCV-111A & PCV-111).
e.The nitrogen blanketing systems on the bromine storage tanks (TT-090,
092, and
093) consisting of pressure sensors/transmitters (PT-245, PT-246, PT-247),
control logic, and control/solenoid valve(s) (PCV-245, PCV-246, and
PCV-247).
These violation instances occurred in the Central Plant Bromine Unit where
these
conditions exposed employees to the hazards associated with uncontrolled
chlorine and
bromine liquid and/or vapor releases into the atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including the
description of the steps that it is taking to ensure that the
documentation of the inspection or test
that is performed on process equipment to maintain its mechanical
integrity identifies the date
of the test/inspection, the function item number or identifier of the
equipment/piping on which
the test/inspection is performed, a description of the test/inspection,
and the results of the
test/inspection up to and including exercising the final element of the
control.

Issued

Jun 6, 2012

Abate by

Sep 1, 2012

Penalty

Initial $7,000 · Current $7,000

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:
The employer does not address deficiencies to equipment performing safety
functions
such as but not limited to:
a)The Ammonia Detection System at the ammonia storage tank had sensors that
were not operable.
The violation occurred in the Bromine Unit where this condition exposed
employees
to
the hazards associated with not having an early warning of uncontrolled
releases of
ammonia liquid and/or vapor into the atmosphere.
Pursuant to 29 CFR 1903.19, within (10) calendar days of the abatement
date the employer must
submit documentation showing that it is in compliance with the standard,
including describing
the steps that it is taking to ensure that equipment deficiencies are
corrected in a timely manner.

Issued

Jun 6, 2012

Abate by

Sep 1, 2012

Penalty

Initial $7,000 · Current $3,000 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:
The employer does not implement management of change (MOC) procedures to
manage changes
to equipment and procedures such as but not limited to;
The sulfur dioxide vaporizer (EV-01-063) was by-passed utilizing hoses and
has not been
replaced.
These violations were observed in the Bromine Unit where these conditions
exposed employees
to the hazards associated with uncontrolled releases of ammonia, chlorine,
sulfur dioxide and/or
bromine into the atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including
describing the steps that it is taking to ensure that management of change
(MOC)
procedures to
manage changes to equipment and procedures are established and implemented.

Issued

Jun 6, 2012

Abate by

Aug 1, 2012

Penalty

Current $7,000

General-duty citation text

29 CFR 1910(b)(9)(ix): A hydrostatic relief valve was not installed
between each pair of valves
in the liquid ammonia piping or hose where liquid could be trapped so as
to relieve into the
atmosphere at a safe location:
The employer does not ensure that a relief valve is provided between each
pair of block
valves in the liquid ammonia piping where liquid could become trapped.
Relief for a portion of line 2376 was not provided should liquid be
trapped between the
valves of lines 2376, 2377 and 1410.
This violation was observed in the Central Plant Bromine Unit where these
conditions
exposed employees to the hazards associated with an uncontrolled ammonia
release into
the atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date, the employer
must submit documentation showing that it is in compliance with the
standard, including
describing the steps that it is taking to ensure that hydrostatic relief
valves are installed.

Issued

Jun 6, 2012

Abate by

Jan 30, 2013

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
(RAGAGEP):
The employer does not ensure that equipment in the process complies with
recognized
and generally accepted good engineering practices (RAGAGEP) such as but
not limited
to:
a.The Chlorine Rail Car Un-loading facility stations do not have an
emergency
shut-off system as defined by the chlorine Institute Pamphlet 57, Edition
5, March
2009-Revision 1.
b.The Chlorine Rail Car Un-loading facility's liquid line does not have
relief
devices or expansion chambers installed where liquid chlorine could be
trapped
between two block valves, as defined by the Chlorine InstitutePamphlet 6,
Edition 15, May 2005
c.The re-boilers RB-01-055 & RB-01-056 on Chlorine Stripping columns CL-01-
055 and CL-01-056 had relief devices set at 30 psig but the vessels'
documents
do not reflect the design code and standard utilized to determine the
relief device
settings as defined by American Society of Mechanical Engineers (ASME)
Codes
for vessels with expected operating pressures greater than 15 psig.
These violation instances were observed in the Central Plant Bromine Unit
where
these
conditions exposed employees to the hazards associated with uncontrolled
chlorine and
bromine liquid and/or vapor releases into the atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including the
description of the steps that it is taking to ensure that an emergency
shut-off system and relief
devices are installed and that appropriate codes are utilized to determine
relief device settings.

Issued

Jun 6, 2012

Abate by

Oct 1, 2012

Penalty

Current $7,000

General-duty citation text

29 CFR 1910.119(e)(3)(i):  The process hazard analysis did not address the
hazards of the
process:
The employer does not address in the Bromine Unit 2008 process hazard
analysis (PHA)
hazards of the process such as but not limited to:
a.The possibility of chlorine liquid line block valves being closed
resulting in liquid
chlorine being trapped between the valves without a relief path.
b.The possibility of the inlet valve to the chlorine liquid line expansion
chamber
being closed resulting in no relief path for expansion of chlorine liquid.
c.The possibility of the relief devices for the chlorine vaporizers being
blocked in
resulting in no relief path for the vaporizer vessel contents.
d.The possibility of ammonia liquid relief from the hydrostatic relief
valves on the
liquid outlet lines and whether relief ammonia was being relieved to a safe
location so as not to expose personnel in the area.
e.The possibility of the failure of the chlorine stripping column
re-boilers when
pressures exceeded atmospheric pressure.
f.The possibility of a major leak/release occurring at the chlorine rail
car unloading
platform and the ability to shut off flow in the event of such an
emergency.
These violations occurred in the Bromine Unit where these conditions
exposed employees
to the hazards associated with uncontrolled releases of ammonia, chlorine
and/or bromine
into the atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including
describing the steps that it is taking to ensure that the process hazard
analysis addresses the
hazards of the process.

Issued

Jun 6, 2012

Abate by

Oct 1, 2012

General-duty citation text

29 CFR 1910.119(e)(3)(ii):  The process hazard analysis did not identify
any previous incident
which had a likely potential for catastrophic consequences in the
workplace:
The employer does not address as part of the PHA previous incidents all of
which
occurred prior to the 2008 PHA being conducted but after the PHA done in
2003 or
thereabouts that had the likely potential for catastrophic consequences in
the workplace
such as:
a.Item 05/630-5D dated 7/28/2005 in which a release of bromine occurred as
a
result of the incorrect liner material used that was not suitable for
bromine.
Recommendation was action required by vendor for positive material
indentification (PMI)
b.Item 04/247-5D dated 3/5/2004 in which an unloading hose on a brine rail
car ruptured. Recommendation was to update and/or revise the piping
standards.
c.Item 03/633-5D in which I-beams that hold up the #5 and #7 purification
are corroded to the extent that webbing on the I-beam was missing.
Recommendations
were to put "caution" sign, no tarps allowed, no personnel allowed in 30
mph or
greater winds.
The incidents were not reviewed as part of the 2008 Bromine Unit PHA.
These violations were observed on or about in the Bromine Unit where these
conditions
exposed employees to the hazards associated with uncontrolled releases of
ammonia,
chlorine, sulfur dioxide and/or bromine into the atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including
describing the steps that it is taking to ensure that the process hazard
analysis addresses any
previous incident that had a likely potential for catastrophic
consequences in the workplace.

Issued

Jun 6, 2012

Abate by

Oct 1, 2012

Penalty

Current $7,000

General-duty citation text

29 CFR 1910.119(e)(3)(vi):  The process hazard analysis did not address
human
factors:
The employer does not in the 2008 PHA identify or evaluate, appropriate to
the
complexity of the process, the possibility of human error in its operating
procedures and
process control screens which reflect equipment and instrument identifiers
that are
different from those on the Process and Instrument Diagrams (P&IDs).
These violations were observed in the Bromine Unit where these conditions
exposed
employees to the hazards associated with uncontrolled releases of ammonia,
chlorine,
sulfur dioxide and bromine liquid and/or vapor into the atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including
describing the steps that it is taking to identify or evaluate the
possibility of human error in its
operating procedures and process control screens which reflect equipment
and instrument
identifiers that are different from those on the Process and Instrument
Diagrams (P&IDs) thus
creating a likely potential for catastrophic consequences in the
workplace.

Issued

Jun 6, 2012

Abate by

Oct 1, 2012

General-duty citation text

29 CFR 1910.119(e)(3)(iii):  The process hazard analysis did not address
the engineering and
administrative controls applicable to the hazards and their
interrelationship, such as, appropriate
of detection methodologies to provide early warning of releases:
The employer does not address in the process hazard analysis the
engineering and
administrative controls applicable to the detection systems such as but
not limited to:
a.The Chlorine Detection System at chlorine rail car unloading facility.
b.The Ammonia Detection System at the ammonia storage tank.
These violations occurred on or about in the Bromine Unit where these
conditions
exposed employees to the hazards associated with not having an early
warning of
uncontrolled releases of ammonia and/or chlorine into the atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including
describing the steps that it is taking to ensure that the process hazard
analysis addresses the
engineering and administrative controls applicable to the hazards and
their interrelationship to
methodologies to provide early warning of releases.

Issued

Jun 6, 2012

Abate by

Oct 1, 2012

Penalty

Current $5,000

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 safely conducting
activities involved in each
covered process.
The Employer failed to implement procedures instructing operators to lock
relief system
block valves in the open position.
a.The chlorine detection system in the rail-car loading/unloading area
b.The ammonia detection system located at the ammonia storage tank
(TK-01-027)
c.The chlorine rail car compressed air padding system reverse flow
prevention
system.
These violations occurred in the Bromine Unit where these conditions
exposed employees
to the hazards associated with uncontrolled releases of ammonia and/or
chlorine into the
atmosphere.
Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement
date the employer
must submit documentation showing that it is in compliance with the
standard, including
describing the steps that it is taking to ensure that specific safety
systems and their functions are
listed in its operating procedures.

Issued

Jun 6, 2012

Abate by

Oct 1, 2012

General-duty citation text

29 CFR 1910.119(f)(1)(iv):  The employer's written operating procedures
did not address
requirements for the safety systems and their functions:
The Employer does not list in its operating procedures specific safety
systems and their
functions such as, but not limited to the following:
a. The chlorine detection system in the rail-car loading/unloading area;
b. The ammonia detection system located at the ammonia storage tank
(TK-01-027);
c. The chlorine rail-car compressed air padding system reverse flow
prevention system.
These violations occurred on or about January 19, 2012 in the Bromine Unit
where these
conditions exposed employees to the hazards associated with uncontrolled
releases of ammonia
and/or chlorine into the atmosphere.
Pursuant to 29 CFR 1903.19, within (10) calendar days of the abatement
date the employer must
submit documentation showing that it is in compliance with the standard,
including describing
the steps that it is taking to ensure that specific safety systems and
their functions are listed in
its operating procedures.