OSHA Inspection: CARDOLITE CORPORATION

Issued

Aug 13, 2012

Abate by

Sep 25, 2012

Penalty

Initial $3,500 · Current $6,000

General-duty citation text

29 CFR 1910.119(d)(2)(i)(A): The process safety information pertaining to the technology of the process did not include a block flow diagram or simplified process flow diagram.    a) Establishment    The process flow diagram for EPI batch processing did not show the decanter, K/O pot or any main flow streams.  It showed a heat exchanger between the first and second vacuum stages which was not present.     Violation occurred on or about 4/3/12.

Issued

Aug 13, 2012

Abate by

Sep 25, 2012

Penalty

Initial $3,500 · Current $6,000

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process.    a)  Building 2, Unit 160    The P&ID for Unit 160 (Drawing D-160) had errors including, but not limited to:    1.  The decanter was not shown.  2.  Feeds were shown that were no longer used or had been cut:  RM-2188 (ethylene diamine) and  PC-2661 (xylene cardanol wash solvent, clean).  3.  Input of recovered epichlorohydrin (PC-2047) and caustic (RM-244) was not shown.  4.  An input line for phenol (PC-3124) was shown which was now used for caustic (RM-244).  5.  Unit 160 marked was as 23 PSI/FV instead of 15 psi.  6.  Unit 160 rupture disk set pressure was listed as 15 psi instead of 14 psi.  7.  There were no vapor inputs shown for the K/O pot, only two outputs.    Violation occurred on or about 4/3/12.      b)  EPI tank wagon unloading area    The P&ID for Y-26 and Y-29 had errors including, but not limited to:    1.  Piping for the unloading pump bypass was not shown  2.  Flanged ball valves were shown on the P&ID where threaded fittings were used  3.  The diagram indicated EPI could be pumped to Unit 595 in Building 2    Violation occurred on or about 4/3/12.    c)  Building 2 roof    The P&ID for Surge Tanks for EPI and EDA Reactors had errors including, but not limited to:    1.  No indication of the relief vent line from Unit 160 receiver.  2.  Only seven inputs were shown; there were at least 15.    Violation occurred on or about 4/3/12.

Issued

Aug 13, 2012

Abate by

Sep 25, 2012

Penalty

Initial $3,500 · Current $6,000

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D):  The process safety information pertaining to the equipment in the process did not include relief system design and design basis.    a) Building 2, Unit 160 and receiver    There was no design or design basis available for outlet piping from rupture disks on Unit 160 and its receiver which ran to a surge tank on the roof.    Violation disclosed on or about 3/29/12.

Issued

Aug 13, 2012

Abate by

Sep 25, 2012

Penalty

Initial $3,500 · Current $6,000

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): Process safety information pertaining to the equipment did not include the design codes and standards employed;    a) Epichlorohydrin process    Design codes and/or standards had not been compiled and were not readily available for all equipment in the epichlorohydrin process including, but not limited to, hoses, valves, interlocks, Unit 160, condenser, air pump, receiver, decanter, K/O pot and surge tank.    Violation observed on or about 4/3/12.

Issued

Aug 13, 2012

Abate by

Sep 25, 2012

Penalty

Initial $3,500 · Current $6,000

General-duty citation text

29 CFR 1910.119(e)(3)(v):  The process hazard analysis did not address facility siting.    a) Epichlorohydrin process    The 2011 process hazard analysis did not address the hazards to employees in Buildings 1 and 2 of severe blast injuries from flying projectiles and falling blocks as a result of 2.3 psi overpressure from explosive ignition of epichlorohydrin leaking from piping to Building 2.  The pressure wave would cause major damage to total collapse of the structures.         Violation occurred on or about 4/3/12.

Issued

Aug 13, 2012

Abate by

Sep 25, 2012

Penalty

Initial $3,500 · Current $6,000

General-duty citation text

29 CFR 1910.119(g)(2): Refresher training was not provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process.    a) Building 2    Chemical operators using epichlorohydrin were not provided refresher training at least every three years on current operating procedures.    Violation occurred on or about 6/13/12.

Issued

Aug 13, 2012

Abate by

Sep 25, 2012

Penalty

Initial $3,500 · Current $6,000

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment    a) Building 2    Inspection and testing was not conducted on epichlorohydrin piping inside Building 2, Unit 160 condenser, receiver or decanter.    Violation occurred on or about 4/18/12.

Issued

Aug 13, 2012

Abate by

Sep 25, 2012

Penalty

Initial $3,500 · Current $4,250

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not verify that the procedures and practices developed under the standard were being followed:    a) Epichlorohydrin process    The 2011 Compliance Audit Report did not identify:    a.  Errors and omissions in P&IDs  for Unit 160, EPI tank wagon unloading area and Building 2 surge tanks.  b.  Absence of design codes and standards specific to equipment in the epichlorohydrin process  c.  Lack of inspection and testing of epichlorohydrin piping within Building 2    Violation occurred on or about 4/3/12.