OSHA Inspection: BOULDER SCIENTIFIC COMPANY

Issued

Dec 21, 2012

Abate by

Feb 25, 2013

Penalty

Initial $3,927 · Current $3,927

General-duty citation text

29 CFR 1910.119(d)(3)(i)(A): The employers compiled written process safety information did not include all the necessary information pertaining to the equipment in the process in that the process safety information did not include materials of construction:  (a) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not ensure that the employers compiled written process safety information included all the necessary information pertaining to the equipment in the process in that the process safety information did not include materials of construction.  A chiller system utilizing approximately 3,500 gallons (23,000 pounds) of methanol and ethanol was used to control temperature of reactions taking place within reactors in the production building.  This process was a process safety management covered process.  Within the production building, carbon steel piping was used to direct the methanol and ethanol into the jacket of the reactors.  The fluid service rating for the flammable liquid piping was normal fluid service.  The chiller system was operated at -25 degrees Celsius to -40 degrees Celsius.  The employer did not have materials of construction information with regards to the carbon steel piping.  This condition exposed employees to a chemical hazard.

Issued

Dec 21, 2012

Abate by

Jun 26, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices:    (a) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not document that equipment complies with recognized and generally accepted good engineering practices.  Toluene was transferred from an approximate 10,000 gallon (78,000 pound) capacity process pressure vessel through carbon steel piping to reactors for processing chemicals.  This process was a process safety management covered process.  Sections of piping were connected via welded flanges.  The welding had been performed by Boulder Scientific Company employees.  The welding procedure used had not been qualified and the welders had not been qualified on such qualified welding procedures per Recognized and Generally Accepted Good Engineering Practices (RAGAGEP).  This condition exposed employees to a chemical hazard.    (b) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not document that equipment complies with recognized and generally accepted good engineering practices.  A chiller system utilizing approximately 3,500 gallons (23,000 pounds) of methanol and ethanol was used to control temperature of reactions taking place within reactors in the production building.  This process was a process safety management covered process.  Within the production building, carbon steel piping was used to direct the methanol and ethanol into the jacket of the reactors.  The fluid service rating for the flammable liquid piping was normal fluid service.  The chiller system was operated at -25 degrees Celsius to -40 degrees Celsius.  The carbon steel piping did not meet Recognized and Generally Accepted Good Engineering Practices (RAGAGEP).  This condition exposed employees to a chemical hazard.

Issued

Dec 21, 2012

Abate by

Jun 26, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(i):  Inspections and tests were not performed on process equipment:    (a) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not ensure that inspections and tests were performed on process equipment.  Toluene was transferred from an approximate 10,000 gallon (78,000 pound) capacity process pressure vessel through carbon steel piping to reactors for processing chemicals.  This process was a process safety management covered process.  Sections of piping were connected via welded flanges.  The welding had been performed by Boulder Scientific Company employees.  The welds were not inspected.  This condition exposed employees to a chemical hazard.    (b) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not ensure that the employer's frequency of inspections and tests of process equipment was consistent with applicable manufacturer's recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.  A chiller system utilizing approximately 3,500 gallons (23,000 pounds) of methanol and ethanol was used to control temperature of reactions taking place within reactors in the production building.  This process was a process safety management covered process.  Within the production building, carbon steel piping was used to direct the methanol and ethanol into the jacket of the reactors.  The piping service class was Class 2.  The employer did not perform thickness measurement inspections of the carbon steel piping consistent with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP).  This condition exposed employees to a chemical hazard.

Issued

Dec 21, 2012

Abate by

Mar 27, 2013

Penalty

Initial $2,618 · Current $2,618

General-duty citation text

29 CFR 1910.119(e)(3)(iv):  The employer's process hazard analysis did not address consequences of failure of engineering and administrative controls:    (a) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not ensure that the employer's process hazard analysis addressed consequences of failure of engineering and administrative controls.  The employer utilized isopar (petroleum distillates), toluene, and methanol/ethanol, each in excess of 10,000 pounds, in separate systems for processing of chemicals.  Each process was a process safety management covered process.  The Process Hazard Analyses developed by the employer were "What If" and "HazOps" methodologies.  For the toluene and chiller systems, the PHA's did not address failure of the pressure relief valves of the pressure vessels.  The employer did not ensure that the PHA's addressed consequences of failure of the engineering control.  This condition exposed employees to an explosion hazard.    (b) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not ensure that the employer's process hazard analysis addressed consequences of failure of engineering and administrative controls.  The employer utilized isopar (petroleum distillates), toluene, and methanol/ethanol, each in excess of 10,000 pounds, in separate systems for processing of chemicals.  Each process was a process safety management covered process.  The Process Hazard Analyses developed by the employer were "What If" and "HazOps" methodologies.  For the isopar, toluene, and chiller systems, the PHA's did not examine failure of the fire suppression systems.  The employer did not ensure that the PHA's addressed consequences of failure of the engineering controls.  This condition exposed employees to explosion and fire hazards.

Issued

Dec 21, 2012

Abate by

Mar 27, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(v): The employers process hazard analysis did not address facility siting:    (a) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not ensure that the employer's process hazard analysis addressed facility siting.  The employer utilized isopar (petroleum distillates), toluene, and methanol/ethanol, each in excess of 10,000 pounds, in separate systems for processing of chemicals.  Each process was a process safety management covered process.  The Process Hazard Analyses developed by the employer were "What If" and "HazOps" methodologies.  The PHA's did not address the impact of an explosion, deflagration, or fire upon the office trailers, located approximately eighty feet from the chiller, tank farm, and production building.  The employer did not ensure that the PHA's addressed all facility siting issues.  This condition exposed employees to a chemical hazard.

Issued

Dec 21, 2012

Abate by

Jan 26, 2013

Penalty

Initial $2,618 · Current $2,618

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D): The employer did not develop and implement written operating procedures that provided clear instruction for conducting activities during emergency shutdown:    (a)The employer did not establish and implement written procedures for maintenance employees to maintain the process equipment following an emergency shutdown of the chiller system in the even methanol/ethanol flow is misdirected to the boiler, including but not limited to possible shutdown of other affected systems

Issued

Dec 21, 2012

Abate by

Jan 26, 2013

Penalty

Initial $3,927 · Current $3,927

General-duty citation text

29 CFR 1910.119(g)(2): Operating procedures were not reviewed as often as necessary to assure that they reflected current operating practice:    (a) Boulder Scientific Company, at 598 Third Street, Mead, CO: In its refresher training, the employer did not assure that affected employees fully understood the current operating procedures of the process set forth in GEN-189, Gen-179, GEN-178, AND GEN -104 (batch records)    (b) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not ensure that operating procedures were reviewed as often as necessary to assure that they reflected current operating practice.  Toluene was transferred from an approximate 10,000 gallon (78,000 pound) capacity process pressure vessel through carbon steel piping to reactors for processing chemicals.  This process was a process safety management covered process.  For GEN-179, the written operating procedures (batch record) did not reflect current operating practices in the field.  This condition exposed employees to a chemical hazard.    (c) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not ensure that operating procedures were reviewed as often as necessary to assure that they reflected current operating practice.  Toluene was transferred from an approximate 10,000 gallon (78,000 pound) capacity process pressure vessel through carbon steel piping to reactors for processing chemicals.  This process was a process safety management covered process.  For GEN-178, the written operating procedures (batch record) did not reflect current operating practices in the field.  This condition exposed employees to a chemical hazard.    (d) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not ensure that operating procedures were reviewed as often as necessary to assure that they reflected current operating practice.  Isopar (petroleum distillates) was transferred from an approximate 10,000 gallon (62,000 pound) capacity process tank through carbon steel piping to reactors for processing chemicals.  This process was a process safety management covered process.  For GEN-104, the written operating procedures (batch record) did not reflect current operating practices in the field.  This condition exposed employees to a chemical hazard.

Issued

Dec 21, 2012

Abate by

Jan 26, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's compiled written process safety information did not include all the necessary information pertaining to the equipment in the process in that the process safety information did not include all affected equipment in the piping and instrument diagram (P&ID):  (a) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not ensure that the employer's compiled written process safety information included all the necessary information pertaining to the equipment in the process in that the process safety information did not include all affected equipment in the piping and instrument diagram (P&ID).  Toluene was transferred from an approximate 10,000 gallon (78,000 pound) capacity process pressure vessel through carbon steel piping to reactors for processing chemicals.  This process was a process safety management covered process.  The P & ID incorrectly identified valve 8 as a ball valve.  The employer did not ensure that the valve was correctly identified as a gate valve.  This condition potentially exposed employees to a chemical hazard.  (b) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not ensure that the employer's compiled written process safety information included all the necessary information pertaining to the equipment in the process in that the process safety information did not include all affected equipment in the piping and instrument diagram (P&ID).  Isopar (petroleum distillates) was transferred from an approximate 10,000 gallon (78,000 pound) capacity process tank through carbon steel piping to reactors for processing chemicals.  This process was a process safety management covered process.  The P & ID incorrectly identified the top and bottom valves of the tank sight glass as ball valves.  The employer did not ensure that the valves were correctly identified as gate valves.  This condition potentially exposed employees to a chemical hazard.  (c) Boulder Scientific Company, at 598 Third Street, Mead, CO: On and preceding 10/9/12 Boulder Scientific Company did not ensure that the employer's compiled written process safety information included all the necessary information pertaining to the equipment in the process in that the process safety information did not include all affected equipment in the piping and instrument diagram (P&ID).  Isopar (petroleum distillates) was transferred from an approximate 10,000 gallon (78,000 pound) capacity process tank through carbon steel piping to reactors for processing chemicals.  This process was a process safety management covered process.  The P & ID did not have present a ball valve isolating the pressure indicator for the nitrogen supply line to the tank.  The employer did not ensure that the valve was on the P & ID.  This condition potentially exposed employees to a chemical hazard.