OSHA Inspection: ARKEMA, INC.

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Penalty

Initial $7,000 · Current $4,900 Reduced

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:
The employer does not ensure that the information pertaining to the relief
system included back
pressure calculations and verifications; design calculations for the worst
case scenario; and
included pressure drop calculations.  The following violations of this
were observed on or about
January 14, 2012 where these conditions exposed employees working in
process unit 180 to an
explosion and fire hazard.
a.  For PSV 501/503 located on T-8074 CS2 Storage Tank in process unit
180, the 1997 S&B
Engineering Pressure Safety Valve Study did not have a field-verification
of the back pressure
for the relief sizing calculations.
b.  For PSV 0493/0495 located on T-8073 CS2 Storage Tank in process unit
180, the 1997 S&B
Engineering Pressure Safety Valve Study did not have a field-verification
of
the back pressure
for the relief sizing calculations.
c.  For PSV 509/511 located on T-8075 CS2 Storage Tank in process unit
180, the 1997 S&B
Engineering Pressure Safety Valve Study did not have a field-verification
of the back pressure
for the relief sizing calculations.
The employer does not ensure that the information pertaining to the
process Relief System
Design calculations included the worst case relief scenario.
d. For the 1994 Process Review of the Existing Flare Header Study in
process unit 180 from
Jacobs Engineering Group, the calculations for the worst case relief
scenario was not included.
The employer does not ensure that the information pertaining to the
process included pressure
drop calculations for the Relief System.
e.  For PSV 0501/0503 located on T-8074 CS2 Storage Tank in process unit
180,
the S&B
Engineering1997 Pressure Safety Valve study did not include the
calculations for the built-up
backpressure.
f.  For PSV 0493/0495 located on T-8073 CS2 Storage Tank in process unit
180, the 1997
Pressure Safety Valve study did not include the calculations for the
built-up backpressure.
g. For PSV 509/511 located on T-8075 CS2 Storage Tank in process unit 180,
the 1997 Pressure
Safety Valve Study did not include the calculations for the built-up
backpressure.
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 process safety
information pertaining to the
equipment in the process included the relief system design and design
basis to protect employees
from fire and explosion hazards.n

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Penalty

Initial $5,500 · Current $3,850 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(H): the employer did not compile all PSI related
to specific safety
systems;
The employer does not ensure that process safety information such as loop
drawings,
functional test records, recommended PM schedules, and set-points are
compiled for
Unit 180 interlock/alarms designated as safeguards such as but not limited
to:
a.The Flare Dump Valve consisting of PSHH 0174 and PV 0174 is shown to be
a safe guard in the 2007 PHA.
b.The hydrogen sulfide compressor motor amp alarms consisting of II 0308
and
II 0339 is shown to be a safe guard in the 2007 PHA.
These violation instances were observed on or about January 12, 2012 in
Unit 180
where these conditions exposed employees to the hazards associated with
uncontrolled
hydrogen sulfide 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 specific
process safety information is compiled for the Unit 180 safety
interlocks/alarms
designated as safeguards in the unit PHA.

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Penalty

Initial $7,000 · Current $4,900 Reduced

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:
In Unit 180 the employer does not ensure that interlocks and/alarms in the
process
comply with Recognized and Generally Accepted Good Engineering Practices
such as
but not limited to ISA-84.  The following violations of this were observed
on or about
January 11, 2012 where these conditions exposed employees working in
process unit
180 to the hazards associated with uncontrolled hydrogen sulfide vapor
releases.
a.The high pressure shutdown of the hydrogen sulfide compressor consisting
of
PI 0322 and PI 0349 is shown as a safeguard in 2007 Unit 180 PHA.
b.The 2007 Unit 180 PHA indicates that a high temperature hydrogen sulfide
compressor shutdown consisting of TI 0307 and TI 0381 is shown as a
safeguard in 2007 Unit 180 PHA.
c.The Flare Dump Valve consisting of PSHH 0174 and PV 0174 is shown to be
a safeguard in the 2007 Unit 180 PHA.
d.The hydrogen sulfide compressor motor amp alarms consisting of II 0308
and
II 0339 is shown to be a safe guard in the 2007 Unit 180 PHA.
In Unit 180 the employer does not ensure that Relief Device(s) in the
process comply
with Recognized and Generally Accepted Good Engineering Practices such as
but not
limited to ASME Boiler and Pressure Vessel Code (BPVC), Division I,
Section VIII,
UG-135(f) and discharge to a safe location.  The following violations of
this were
observed on or about January 11, 2012 where these conditions exposed
employees
working in process unit 180 to the hazards associated with uncontrolled
hydrogen
sulfide vapor releases.
e.The Carbon Disulfide (CS2) storage tank T-8073 rupture disk PSE 0498.
f.The Carbon Disulfide (CS2) storage tank T-8074 rupture disk PSE 0506.
g.The Carbon Disulfide (CS2) storage tank T-8075 rupture disk PSE 0512.
In Unit 180 the employer does not ensure that Car Seals of intervening
block valve(s)
comply with Recognized and Generally Accepted Good Engineering Practices
such as
but not limited to ASME BPVC, Division 1, Section VIII, UG-135(d).  The
following
violations of this were observed on or about January 11, 2012 where these
conditions
exposed employees working in process unit 180 to the hazards associated
with
uncontrolled hydrogen sulfide vapor releases.
h.The three way valves on the inlet and outlet of PSV 0257 and/or PSV 0259
on
west H2S compressor where linkage was missing.
i.The three way valves on the inlet and outlet of PSV 0493 and/or PSV 0495
on
the CS2 storage tank T-8073 where linkage was missing.
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 has taken to
ensure that
equipment and instrumentation complies with recognized and generally
accepted good
engineering practices (RAGAGEP) such as but not limited to ISA-84 for
instrumentation designated to perform safety functions, and ASME Boiler and
Pressure Vessel Code  (BPVC), Division 1, Section VIII, UG-135(f)
regarding relief
devices relieving to a safe location and ASME BPVC, Division 1, Section
VIII, UG-
135(d) regarding the use of intervening block valves for relief
devices.ing

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Penalty

Initial $7,000 · Current $4,900 Reduced

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;
The employer does not ensure that the 2007 process hazard analysis (PHA)
for the
180 Unit addresses the engineering and administrative controls applicable
to the
hazards and their interrelationships for controls such as but not limited
to:
a.The Flare Dump Valve consisting of PSHH 0174 and PV 0174 and designated
as a safeguard in the 2007 Unit 180 PHA. The solenoid operated block valve
PV 0174 had an upstream and downstream manual block valve that was not
car sealed or locked open and were not in the car seal/lock program.
b.The block valves to the interlock (PSHH 0174 and PV 0174) and high
pressure
alarm associated with PIC 0173 could be blocked in allowing the interlock
and
alarm to be inoperable. The inlet block valve(s) to the pressure switch
(PSSH
0174) and PIT 0173 were not car sealed or locked in the open position and
the
block valves were not in the car seal/lock program.
These violation instances were observed on or about January 12, 2012 in
Unit 180
where these conditions exposed employees to the hazards associated with
uncontrolled
hydrogen sulfide vapor and carbon disulfide liquids/vapor releases into
the atmosphere
and/or fire and explosions.
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 has taken to
ensure that the
PHA addressed the engineering and administrative controls applicable to
hazards and
their interrelationship.

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(e)(3)(iv):  The process hazard analysis did not address
the consequences
of failure of engineering and administrative controls:
The employer does not ensure that the 2007 process hazard analysis (PHA)
for the
180 Unit addresses the failure of an administrative control for but not
limited to the
following intervening block valves for relief devices:
a.The valve on the outlet of the rupture disk on the CS2 push pot (V-8099)
b.The three way valves on the inlet and outlet of PSV 0257 and/or PSV 0259
on
west H2S compressor where linkage was missing
c.The 12" valve in the flare line to the vertical flare pot
d.The 12" valve in the flare line from the vertical flare pot
e.The 6" valve in the main flare line west of the V-8071 (T-87) in the
pipe rack.
f.The three way valves on the inlet and outlet of PSV 0493 and/or PSV 0495
on
the CS2 storage tank T-8073.
These violation instances were observed on or about January 12, 2012 in
Unit 180
where these conditions exposed employees to the hazards associated with
uncontrolled
hydrogen sulfide vapor and carbon disulfide liquids/vapor releases into
the atmosphere
and/or fire and explosions.
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 has taken to
ensure that the
consequences of failure of administrative or engineering controls have
been addressed.g

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

General-duty citation text

29 CFR 1910.119(f)(1): the employer did not develop or implement operating
procedures for
the administrative control of the use of intervening block valves for
relief devices;
The employer does not ensure that standard operating procedures were
written and
implemented to administratively control the use of intervening block
valve(s) on relief
devices in the 180 unit such as but not limited to:
a.The valve on the outlet of the rupture disk on the CS2 push pot (V-8099)
b.The three way valves on the inlet and outlet of PSV 0257 and/or PSV 0259
on
west H2S compressor where linkage was missing
c.The 12" valve in the flare line to the vertical flare pot
d.The 12" valve in the flare line from the vertical flare pot
e.The 6" valve in the main flare line west of the V-8071 (T-87) in the
pipe rack.
f.The three way valves on the inlet and outlet of PSV 0493 and/or PSV 0495
on
the CS2 storage tank T-8073.
These violation instances were observed on or about January 12, 2012 in
Unit 180
where these conditions exposed employees to the hazards associated with
uncontrolled
hydrogen sulfide and carbon disulfide liquids/vapor releases into the
atmosphere
and/or fire and explosions.
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 has taken to
ensure that the
failure of administrative or engineering controls have addressed as per
ASME Boiler
and Pressure Vessel Code, Division 1 (BPVC), Section VIII, UG-135(d) and
Appendix M.pendix

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Penalty

Initial $7,000 · Current $4,900 Reduced

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 ensure that procedures are written and implemented
to ensure
the mechanical integrity of process equipment in the 180 Unit such as but
not limited
to:
Use of intervening block valve(s) used on relief devices;
a.The valve on the outlet of the rupture disk on the CS2 push pot (V-8099)
b.The three way valves on the inlet and outlet of PSV 0257 and/or PSV 0259
on
west H2S compressor where linkage was missing
c.The 12" valve in the flare line to the vertical flare pot
d.The 12" valve in the flare line from the vertical flare pot
e.The 6" valve in the main flare line west of the V-8071 (T-87) in the
pipe rack.
f.The three way valves on the inlet and outlet of PSV 0493 and/or PSV 0495
on
the CS2 storage tank T-8073.
Inspection and testing of protective instruments as per Arkema MI program
Section
VII.
g.The Flare Dump Valve consisting of PSHH 0174 and PV 0174 is designated to
be a safeguard in the 2007 Unit 180 PHA.
h.The hydrogen sulfide compressor motor amp alarms consisting of II 0308
and
II 0339 is designated to be a safe guard in the 2007 Unit 180 PHA.
Ruptured Discs leaking by identified during audits.
i.   PSE-0104 and PSE-0106 were leaking by and identified on rupture disc
audits since February 2011.
j.   PSE-0246 and PSE-0248 were leaking by and identified on rupture disc
audits since February 2011.
These violation instances were observed on or about January 12, 2012 in
Unit 180
where these conditions exposed employees to the hazards associated with
uncontrolled
hydrogen sulfide and carbon disulfide liquids/vapor releases into the
atmosphere
and/or fire and explosions.
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 has taken to
ensure that the
failure of administrative or engineering controls have addressed as per
ASME Boiler
and Pressure Vessel Code, Division 1 (BPVC), Section VIII, UG-135(d),
Appendix
M and ANSI/ISA 84.00.001 as per Arkema MI Program Section XVI, Subsection
E.
Also, employer must submit documentation showing a program wil be written
and
implemented to address  ruputured discs leaking by.

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Penalty

Initial $5,500 · Current $3,850 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iv):  The documentation of the inspection or test
that had been
performed on process equipment to maintain its mechanical integrity did
not identify the date
of the inspection or test, a description of the inspection or test, and
the results of the
inspection or test:
The employer does not ensure that the documentation of the inspection and
testing of
the following interlocks in the Unit 180 is performed for such equipment
as, but not
limited to:
a.This violation was observed on or about January 12, 2012 in the Unit 180
where employees were exposed to the hazards associated with uncontrolled
hydrogen sulfide vapor releases into the atmosphere when the date,
description, and results of the inspection or test of the hydrogen sulfide
compressor pressure shutdown consisting of PI 0322 and PI 0349 were not
documented.
b.This violation was observed on or about January 12, 2012 in the Unit 180
where employees were exposed to the hazards associated with uncontrolled
hydrogen sulfide vapor releases into the atmosphere when the date,
description, and results of the inspection or test of  the hydrogen sulfide
compressor temperature shutdown consisting of TI 0307 and TI 0381 were not
documented.
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
inspection or test that had been performed on process equipment is
documented and
maintained to ensure the mechanical integrity of the equipment.

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Penalty

Initial $7,000 · Current $4,900 Reduced

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 ensure rupture discs upstream from pressure relief
valves in the
180 Unit are replaced for such items but not limited to.
a.  Rupture Discs PSE-0104 and PSE-0106 on the C2S Product tower, D-8060
were
ruptured and leaking by affecting the integrity of the relief device it
was designed to
protect from CS2.
b.  Rupture Discs PSE-0246 and PSE-0248 on the H2S Tower, D-8040 were
ruptured
and and leaking by affecting the integrity of the relief device it was
designed to protect
from H2S.
This violation was observed on or about January 12, 2012 in the 180 unit
where this
condition exposed employees to an inhalation and explosion hazard.
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,
to ensure that the deficient rupture discs are corrected in a safe and
timely manner.

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Penalty

Initial $7,000 · Current $4,900 Reduced

General-duty citation text

29 CFR 1910.119(o)(4):  The employer did not determine and document an
appropriate response
to each of the findings of the compliance audit required by 29 CFR
1910.119(o)(1), and
document that the deficiencies had been corrected:
The employer does not document that deficiencies found in the 2008
compliance audits
have been corrected.  This includes, but is not limited to the following
audit deficiencies:
a)2008 Corporate Compliance Audit PHA 1 recommendation to expedite the
completion of the final report for PHA revalidations that include, but are
not limited to
180 Unit.
b)2008 Corporate Compliance Audit PHA 2 recommendation to enter
recommendations from the 2007 PHA revalidations for process that include,
but are not
limited to Process 180.
c)2008 Corporate Compliance Audit MI 2 recommendation to document the MI
procedures for Emergency Shutdown Devices and process critical controls in
the plant
written MI program, to include a listing of included ESDs and controls,
and the
methodology employed in determining the included items, include but are
not limited to
Process 180.
These violation instances were observed on or about January 12, 2012 in
Unit 180 where
these conditions exposed employees to the hazards associated with
uncontrolled hydrogen
sulfide 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 compliance audit findings have been corrected.  The documentation will
include the
date, a description, and report a detailed report of resolution.

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Penalty

Current $7,000

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Penalty

Initial $35,000 · Current $24,500 Reduced

General-duty citation text

29 CFR 1910.119(f)(3):  The operating procedures were not reviewed as
often as necessary to
assure that they reflect current operating practice, including changes
that result from changes in
process chemicals, technology, and equipment, or changes to facilities:
The employer does not ensure that operating procedures are reviewed as
often as
necessary to assure that they reflect current operating practice exposing
employees to
injury.
a) This violation was observed on or about January 12, 2012 in Unit 180
where
operating procedures such as, but not limited to start-up and shutdown
procedures
were not revised and reflected current operating practice exposed
employees to
the hazards associated with uncontrolled hydrogen sulfide vapor release.
b) This violation was observed on or about January 12, 2012 in Unit 197
where
operating procedures such as, but not limited to start-up and normal
operation
procedures were not revised and reflected current operating practice
exposed
employees to the hazards associated with uncontrolled hydrogen sulfide
vapor
release.
Arkema, Inc. was previously cited for a violation of this occupational
safety and health
standard or its equivalent 29 CFR 1910.119(f)(3), which was  contained in
OSHA
inspection number 314414517, citation number 1, item number 1 and was
affirmed as
a final order on January 13, 2011, with respect to a workplace located at
2231 Haden
Road, Houston, TX 77015.
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,
the documentation will include the date, procedure updates or revisions to
include current
operating practice, and annual certification.

Issued

Jul 10, 2012

Abate by

Aug 12, 2012

Penalty

Initial $1,100 · Current $770 Reduced

General-duty citation text

29 CFR 1910.119(f)(4):  The employer did not develop and implement safe
work practices for
employees and contractor employees to provide for the control of hazards
during operations such
as lockout/tagout; confined space entry; opening process equipment or
piping; and control over
entrance into a facility by maintenance, contractor, laboratory, or other
support personnel:
The employer does not develop safe work practices to control the entrance
into covered
processes that include, but is not limited to 180 Unit.
a)Contractors were given a plant wide permit to perform work such as but
not
limited to fire extinguisher checks and were only required to sign in or
out once, at the
main control room.
b)"Other support personnel" such as but not limited to operations manager,
production superintendent, and process engineer were not required to sign
into the unit.
These violation instances were observed on or about January 12, 2012 in
Unit 180 where these
conditions exposed employees to the hazards associated with uncontrolled
hydrogen sulfide 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 there is control
access by contractor and
"other support personnel" into covered units despite of the type of
activities undertaken.  The
documentation will include the date, a description, and safe work
practices put in place to
control access into covered units.  This condition exposed employees to
fire and explosion
hazards.