OSHA Inspection: WESTLAKE VINYLS COMPANY, LP

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $5,000 · Current $5,550

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Process safety information pertaining to the equipment in the process did not include the piping and instrument diagrams (P&IDs):     Instance 1  In Area 2 of the VCM Unit: The employer did not ensure that the process safety information pertained to the equipment in the process by failing to update Drawing Number 73-0-0024 to reflect the current equipment in the process following the removal of FE-R7102A-A (orifice plate with meter run).  This violation was documented on or about 03/22/2012.    Instance 2  In Area 1 of the VCM Unit: The employer did not ensure that the process safety information pertained to the equipment in the process by failing to update the following drawings to reflect the current equipment in the process following the installation of car seals/ mechanical locking devices on intervening stop valves:  1. Drawing Number 71-0-0031, Revision 6;  2. Drawing Number 71-0-0035, Revision 13;  3. Drawing Number 71-0-0036, Revision 14;  4. Drawing Number 71-0-0038, Revision 11;  5. Drawing Number 71-0-0050, Revision 19;  6. Drawing Number 71-0-0051, Revision 14.  This violation was documented on or about 03/22/2012.

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $1,000 · Current $0 Reduced

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:     This violation was observed on or about May 10, 2012, when it was observed that the employer had not included the design code or standards in the process safety information for the safety interlock systems within Area 1 of the Vinyl Chloride Monomer Unit.

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $7,000 · Current $6,550 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): The employer does not include the information pertaining to the equipment in the process including the relief system design and design basis:     The employer's process safety information does not include complete design calculations for the following pressure vessels and relief valves within the Vinyl Chloride Monomer Unit:     a) The exchanger at the VCM Dryer (West)  PSV-E7204A-B and PSV-E7204B-B       b) The Refrigerant Storage Drum  PSV-V7212A-A and A-B      c) The exchanger at the EDC Steam Pre-Heater  PSV-E7213A-A       d) The exchanger at the EDC Steam Pre-Heater  PSV-E7213A-A     e) The Stripper Condenser  PSV-E7403      f) The Quench Recirculation Cooler  PSV-E7411-1

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $7,000 · Current $6,550 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process:     Instance 1  In Area 2 of the Vinyl Chloride Monomer (VCM) unit, the employer does not ensure that the 2009 process hazard analysis (PHA) is appropriate for the complexity of the process.  The 2009 PHA did not identify, evaluate, and control a process hazard; the inadvertent mixing of chlorine and vinyl chloride monomer due to reverse/other flow of chlorine into the VCM column.    Instance 2  In Area 3 of the Vinyl Chloride Monomer (VCM) unit, the employer does not ensure that the 2009 process hazard analysis (PHA) is appropriate for the complexity of the process and does not address highly hazardous chemicals relieving to an unsafe location.  The 2009 PHA did not identify, evaluate, and control a process hazard; highly hazardous vent gases containing ethyl chloride, ethylene, chloroform, and ethylene dichloride relieving through the incinerator bypass valve (PV-7401A) to atmosphere, to an area where employees could be working.

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors:     In Area 2 of the VCM Unit: The employer did not address the human factors related to closing the following specific isolation valves during emergency situations when it conducted its 2009 PHA: manual valve for chlorine (1 ball valve) and flow control valve (FCV R7102A-A) on line 1CL-72145-BC-I.

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(iii): The process hazard analysis (PHA) did not address the engineering and administrative controls applicable to the hazards and their interrelationship(s):     Instance 1  In Area 1 of the VCM unit: The employer did not adequately address the engineering and administrative controls applicable to the hazards of the process in the 2009 PHA by failing to recognize and evaluate the lack of appropriate safeguards to ensure that the following pressure relief devices (PRDs) did not have their relief capabilities diminished or eradicated by intervening stop valves:  1. PSV-E7101A-D, PSE-E7101A-C;   2. PSV-E7104A;   3. PSV-E7106A;   4. PSV-T7103A-B, PSE- T7103A-B;   5. PSV-V7108A-A, PSE-V7108A-A;   6. PSV-V7108A-B, PSE-V7108A-B;   7. PSV-E7102B-C, PSE-E7102B-C;   8. PSE-V7105A-A, PSE-V7105A-B;   9. PSE-V7106A-A, PSE-V7106A-B.    Instance 2  In Areas 1, 2, and 3 of the VCM unit: The employer did not adequately address the engineering controls applicable to the hazards of the process by failing to ensure that the following pressure relief valves (PRVs) provided sufficient relief for the equipment they protected prior to listing them as safeguards on the 2009 PHA:   1. PSV-T7103A-B;  2. PSV-E7313-B;  3. PSV-E7213A-A;  4. PSV-E7213A-B.

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(v): The employers process hazard analysis does not always address facility siting:    This employer does not ensure that the 2009 Facility Siting PHA addresses the potential encroachment of chlorine gas into the Vinyl Chloride Monomer Control Room.

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $7,000 · Current $6,550 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D): The employer does not ensure that written operating procedures provide clear instructions for safely conducting activities involved in each covered process:     This violation was observed on or about March 28, 2012, when it was observed that the employer had not included, in the T-7203A VCM Column Emergency Shutdown Procedure, the shutting off the chlorine vaporization feed by manual control and by the console controlled flow control (FIC-R7102A).

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(B): The employers written operating procedures covering safety and health considerations did not address the precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment:     This violation was observed on or about May 8, 2012. The operating procedures do not address any controls (i.e. detection device or other method) for the prevention of intrusion of chlorine gas into the VCM Control Room.

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $5,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iv): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and which addressed safety systems and their function:     In Area 1 of the VCM unit: The employer did not develop or implement operating procedures for the administrative control of car seals/mechanical locking elements on intervening stop valves in the upstream and downstream lines to/from the following pressure relief devices (PRDs) to ensure they remained in the open position during operation:   1. PSV-E7101A-D, PSE-E7101A-C;  2. PSV-E7106A-A;  3. PSV-T7103A-A, PSE- T7103A-A, PSV-T7103A-B, PSE- T7103A-B;   4. PSV-V7108A-A, PSE-V7108A-A;   5. PSV-E7102B-C, PSE-E7102B-C;  6. PSE-V7105A-A;  7. PSE-V7106A-A.     This violation was documented on or about 03/22/2012.

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $0 · Current $0

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):     In Area 1 of the VCM unit: The employer did not comply with RAGAGEP by failing to provide adequate controls to ensure that intervening stop valves on the upstream and downstream lines to/from the following pressure relief devices (PRDs) remained in the open position during operation when a pressure vessel was the possible source of a relieving event, per UG-135(d) and Appendix M of the 2007 ASME Boiler & Pressure Vessel Code VIII, Division 1 - Rules for Construction of Pressure Vessels:   1. PSV-E7101A-D, PSE-E7101A-C;  2. PSV-E7104A;  3. PSV-E7106A-A;  4. PSV-T7103A-B, PSE-T7103A-B, PSV-T7103A-A, PSE-T7103A-A;  5. PSV-V7108A-A, PSE-V7108A-A;  6. PSV-E7102B-C, PSE- E7102B-C;   7. PSE-V7105A-A, PSE-V7105A-B;   8. PSE-V7106A-A, PSE-V7106A-B.    This violation was documented on or about 03/22/2012.

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $7,000 · Current $6,550 Reduced

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation:     This violation was documented on or about May 10, 2012, when it was observed that the employer had not adequately sized the pressure relief valves of the following pressure vessels within Areas 1, 2, 3 of the Vinyl Chloride Monomer Unit and the Tank Farm:     Area 1   a) Direct Chlorination Reactor A/PSV  R7101A-A was not sized according to API 520 worst case scenario; Exposure to External Fire-Wetted Vessel. This scenario requires the PRV to be sized with a J orifice verses a D orifice that the valve is currently fitted per Bertrand Engineering Report dated July 19, 1999.    b) Exchanger on the Direct Chlorination Reactor R7101A/PSV  E7101-A-C and A-A: As according to API 520 this relief valve is undersized for its service and could not relieve under the loss of cooling water per Bertrand Engineering Report dated July 19, 1999.     c) Recovery Column T7103/PSV-T7103A-B: According to API 520 the calculations for this relief valve is undersized for loss of cooling water scenario per the Bertrand Engineers, Inc. 12/1999.     d) Old Steam Stripper T7401/PSV-T7401-B and A: According to API 520 this relief valve is undersized for the blocked outlet scenario per the Bertrand Engineers, Inc. dated July 22,1999. According to the relief calculations both valves together could sufficiently relieve if both relief valves were car-sealed open but one valve was car-sealed closed.     e) New Steam Stripper T7402/PSV-T7402-1 and PSV-T7402-2: According to API 520 as per the Bertrand Engineers, Inc. 6/1999 relief calculations show these relief valves are undersized for the control valve failure scenario per the Bertrand Engineers Report dated June 16, 1999.     f) Ethylene Stripper Bottoms Cooler E7314A/PSV-E7314A: The fire scenario calculations according to API 520 show the present relief valve is undersized per the CDI Engineering Report dated January 8, 2005.      g) Stripper Feed Interchanger E7313/PSV-E7313-B: The fire scenario calculations according to API 520 show the relief device is undersized per the CDI Engineering Report dated November 14, 2004.       Tank Farm     h) Chlorine Expansion Bottle V7621/PSV-V7621-1: The pressure relief calculations were incomplete due to insufficient information. The engineers report says the PSV is undersized due to the fire scenario according to API 520.

Issued

Sep 18, 2012

Abate by

Oct 2, 2012

Penalty

Initial $7,000 · Current $6,550 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer does not ensure that it implements written procedures to manage changes:     This violation was observed on or about April 19, 2012, at the VCM Unit 2, when it was observed that the employer had failed to conduct a management of change when the chlorine control loop (R 7102A-A) containing a chlorine flow meter (FE-R7102A-A) was removed and changed and thus was not a replacement in-kind.