OSHA Inspection: RHODIA INC.

Issued

Nov 21, 2012

Abate by

Dec 27, 2012

Penalty

Initial $7,000 · Current $7,000

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:  The employer does not ensure that equipment in the process complies with recognized and generally accepted good engineering practices.  Instance a: This violation occurred in the Sulfuric Acid Regeneration Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of anhydrous ammonia and/or flammable liquids or gasses without ensuring that the relieving back-pressure of conventional relief device(s) did not exceed 10% of the relief device set pressure in accordance with API 520 for relief device(s) such as, but not limited to:     1.  PSV 1170 (Anhydrous Ammonia Storage Tank)     2.  PSV 1277 (Ammonia Vaporizer, X-401)    3.  PSV 214 (Hydrogen Sulfide Knock Out Pot)  Instance b: This violation occurred in the Sulfuric Acid Regeneration Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of anhydrous ammonia and/or flammable liquids or gasses without ensuring that instrumentation designated to perform safety functions was designed and/or documentation developed for the safety system in accordance with ANSI/ISA-84 (IEC 61511) for safety-instrumented systems and/or interlocks such as, but not limited to:    1.  The furnace pressure (PT/PI-232) shown as a safeguard in 2007 Unit PHA and utilized to stop all feeds (including alternative raw material A.R.M.) to the furnace on a condition of high pressure in the furnace.      2.  The furnace oxygen content (AT/AI-201A & B) shown as a safeguard in the 2007 Unit PHA and utilized to stop all feeds (including A.R.M) to the furnace on a condition of low oxygen in the furnace.    Pursuant to 29 C.F.R. 1903.19, within ten (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 it is taking to ensure that equipment in the process complies with recognized and generally accepted good engineering practices.

Issued

Nov 21, 2012

Abate by

Dec 27, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(2):  The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment:   The employer does not ensure that procedures are written and implemented to ensure the mechanical integrity of process equipment such as but not limited to the low-pressure alarm on the steam ejector (PAL 216) that is designated as a safeguard in the 2007 Baytown Furnace process hazards analysis (PHA). This condition exposed employees to the hazards associated with uncontrolled releases of liquids/vapor and flammable materials 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 written procedures are established or implemented to maintain the on-going integrity of the process.

Issued

Nov 21, 2012

Abate by

Dec 27, 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 complete a periodic full functional test of plant safety instrumented systems and interlocks to reveal any undetected faults in accordance with recognized and generally accepted good engineering practices (RAGAGEP) such as ISA84/IEC61511 on process equipment including, but not limited to, the following:   a. Furnace Oxygen Analyzer (AT-201)   b. Furnace Fire Eyes   c. Furnace Pressure (PT-232)   These violation instances occurred in the Sulfuric Acid Regeneration unit where employees were exposed to the hazards associated with uncontrolled liquids/vapor releases of flammable materials 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 inspections and testing procedures performed on process equipment to maintain its mechanical integrity follow recognized and generally accepted good engineering practices.

Issued

Nov 21, 2012

Abate by

Dec 27, 2012

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected:  The employer does not document deficiencies found in the 2010 Facilitated Self-Assessment (FSA) have been corrected.  This includes, but is not limited, to the following audit deficiencies as documented in Rhodia Tracking ID PAT-ECO-BT-12-4:     b.  Number 3 - Ensure files are complete especially the design basis, standards, and codes used for the ammonia system relief valves.  c.  Number 5 - Determine and document safety integrity levels for the Ammonia and ARM feed system safety interlocks.  d.  Number 27 - Determine safety integrity levels and appropriate testing for all safety systems (ammonia and ARM feed systems)  These violation instances conditions exposed employees to the hazards associated with uncontrolled ammonia and ARM vapor releases 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 the description of the steps that it is taking to ensure that it promptly determines and documents an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.