OSHA Inspection: BAKER PETROLITE CORPORATION

Issued

Feb 1, 2013

Abate by

May 26, 2014

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 (RAGAGEP).       Instance a:  The violation occurred in the EP Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of ethylene, propylene, and other flammable/toxic liquids or gasses without ensuring that the discharge from relief devices were to a safe location in accordance with a RAGAGEP such as the Pressure Vessel Code  (BPVC), Division 1, Section VIII, UG-135(f) and API 521 for relief devices such as but not limited to:      1.  The PSV-2018, 2019, and PSV 2020 for Additive "B" blend tanks C-2018, C-2019 and C-2020 Additive "B" storage   tank share a common vent line that relieves to atmosphere onto a stairway.   2.  The PSV-3020 on C-3020 (PET-storage tank), PSV-3021 on C-3021 (PET-2501) relieve into a pit   3.  The PSV-1245 for C-1003 (Dry solvent storage tank) relieves to atmosphere       Instance b:  The violation occurred in the EP Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of ethylene, propylene, and other flammable/toxic liquids or gasses without ensuring that adequate controls were in place to ensure that intervening valves upstream or downstream of a relief device(s) remained in the open position in accordance with a RAGAGEP such as the Pressure Vessel Code (BPVC), Division 1, Section VIII, UG-135(d) for such pressure relief device(s) as but not limited to:      1.  The inlet and outlet of PSV 1014 on PET 2500 weigh tank C-1005   2.  The inlet and outlet of PSV 3020 on the PET storage tank C-3020   3.  The outlet of PSV 3021 on the PET 2501 weigh tank C-3021  4.  The inlet to PSV 1360 and/or PSV 1361 for Ethylene storage tanks C-1000/1001   5.  The inlet to PSV 4030 on Reactor #4 C-4000 6.  The inlet to PSV 4073 on Reactor #5 C-4003.      Instance c:  The violation occurred in the EP Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of ethylene, propylene, and other flammable/toxic liquids or gasses without ensuring that a rupture disk(s) installed between a pressure relief valve and a pressure vessel had a method that would detect a disk rupture or leakage in accordance with a RAGAGEP such as the ASME Boiler and Pressure Vessel Code, Division 1 (BPVC), Section VIII, UG-127(b) for rupture disk(s) such as but not limited to:       1.  PSE 701B to PSV 801 on Reactor #1 C-2001    2.  PSE 702B to PSV 802 on Reactor #2 C-2002       Instance d: The violation occurred in the EP Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of ethylene, propylene, and other 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.  EP-2 PET-2500 Tank Truck Unloading Trip    2.  EP-3 PET-2501 Tank Truck Unloading Trip    3.  EP-23 Reactor No.2 Rate of Rise Pressure Trip during PET Addition    4.  EP-40 Lower Explosive Limit (LEL) to the Flare Trip.     Instance e:  : The violation occurred in the EP Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of ethylene, propylene, and other flammable liquids or gasses without ensuring that all relieving scenarios were considered for pressure relief valves  in accordance with API 521 for the following for relief valves such as but not limited to:     1. PSV-1029 on Dry Solvent Tank C-1029   2. PSV-1002 on Solvent Storage Tank C-1002     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

Feb 1, 2013

Abate by

May 26, 2014

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not implement written procedures to maintain the on-going integrity of process equipment.    The employer does not ensure that written procedures are developed and implemented to maintain the on-going integrity of process equipment.    The violation occurred in the EP Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of ethylene and propylene and other flammable liquids or gasses without ensuring that written procedures were developed and implemented to maintain the on-going integrity of process equipment in accordance with ANSI/ISA-84 (IEC 61511) for safety-instrumented systems and/or interlocks such as, but not limited to:    1.  EP-2  PET-2500 Tank Truck Unloading Trip  2.  EP-3  PET-2501 Tank Truck Unloading Trip  3.  EP-23  Reactor No.2 Rate of Rise Pressure Trip during PET Addition  4.  EP-40  Lower Explosive Limit (LEL) to the Flare Trip    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 written procedures are developed and implemented to maintain the on-going integrity of process equipment.

Issued

Feb 1, 2013

Abate by

May 26, 2014

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 to maintain its mechanical integrity:    The employer does not ensure that tests and inspections were performed on process equipment to maintain its mechanical integrity.    The violation occurred in the EP Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of ethylene and propylene and other flammable liquids or gasses without ensuring that instrumentation designated to perform safety functions is inspected and tested in accordance with ANSI/ISA-84 (IEC 61511) for safety-instrumented systems and/or interlocks such as, but not limited to:    1.	EP-2  PET-2500 Tank Truck Unloading Trip  2.	EP-3  PET-2501 Tank Truck Unloading Trip  3.	EP-23  Reactor No.2 Rate of Rise Pressure Trip during PET Addition  4.	EP-40  Lower Explosive Limit (LEL) to the Flare Trip    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 process equipment such as instrumentation designated to perform safety functions is inspected and tested.

Issued

Feb 1, 2013

Abate by

May 26, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5):  The employer did not correct deficiencies in equipment that were outside acceptable limits in a timely manner:    The employer does not address deficiencies of equipment performing safety functions such as but not limited to:    Instance a:  The violation occurred in the EP Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of ethylene, propylene, and other flammable/toxic liquids or gasses without ensuring that a rupture disks upstream of pressure relief valves are replaced in a timely manner such as but not limited to:    1)  PSE-702A on Reactor #2 (C-2002)  2)  PSE-2100 on A2 Polymer Recovery Flash Vessel (C-2101)  3)  PSE-2102 on A2 Polymer Recovery Flash Vessel (C-2103)      Instance b:  The violation occurred in the EP Unit where employees were exposed to inhalation, fire, and explosion hazards from potential releases of ethylene and propylene and other flammable liquids or gasses by not ensuring that the control room was assessed for risk associated with fire, explosions, and toxic releases.    1)  EP Plant Control Room    Instance c: The violation occurred in the EP Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of ethylene, propylene, and other flammable liquids or gasses without ensuring that pressure relief valves were adequately sized in accordance with API 521 for the following instances, but not limited to:    1. PSV-1029 on Dry Solvent Tank C-1029  2. PSV-1002 on Solvent Storage Tank C-1002      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 equipment deficiencies are corrected in a timely manner.

Issued

Feb 1, 2013

Abate by

May 26, 2014

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(e)(5):  The employer did not establish a system to promptly address the process hazard analysis team's findings and recommendations:    The employer does not ensure that a system was established to promptly address the process hazard analysis teams findings and recommendations and that the recommendations are addressed in a timely manner this include but are not limited to the following PHA's:     a)  2007 EP Reactor Area PHA  b)  2009 Polymer Recovery Revalidation PHA  c)  2011 UNICID Revalidation PHA      These violations instances occurred on or about November 8, 2012 at BakerHughes  Petrolite where these conditions exposed employees to the hazards associated with fire and explosion.    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 a system is established to promptly address the process hazard analysis teams finding and recommendations.

Issued

Feb 1, 2013

Abate by

Feb 19, 2013

Penalty

Initial $7,000 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1):  The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities in each covered process.    The employer does not ensure that written operating procedures are developed and implemented to provide clear instructions for safely conducting activities in the covered process.    Instance a:  The violation occurred in the EP Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of ethylene, propylene, and other flammable/toxic liquids or gasses without ensuring that written operating procedures were developed and implemented to control for the use of chains, locks, or car-seals to ensure the intervening block to/from relief devices were open during operation such as but not limited to:    1.  The inlet and outlet of PSV 1014 on PET 2500 weigh tank C-1005.  2.  The inlet and outlet of PSV 3020 on the PET storage tank C-3020.  3.  The outlet of PSV 3021 on the PET 2501 weigh tank C-3021.  4.  The inlet to PSV 1360 and/or PSV 1361 for Ethylene storage tanks C-1000/1001   5.  The inlet to PSV 4030 on Reactor #4 C-4000  6.  The inlet to PSV 4073 on Reactor #5 C-4003.    Instance b:  The violation occurred in the EP Unit where employees were exposed to inhalation, fire and explosion hazards from potential releases of ethylene, propylene, and other flammable/toxic liquids or gasses without ensuring that written operating procedures were developed and implemented for auditing and/or inspecting rupture disks that would detect a disk rupture or leakage such as but not limited to:    1.  PSE 701B to PSV 801 on Reactor #1 C-2001  2.  PSE 702B to PSV 802 on Reactor #2 C-2002.    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 written operating procedures are developed and implemented to provide clear instructions for safely conducting activities in the covered process.