OSHA Inspection: E. I. DUPONT DE NEMOURS AND COMPANY

Issued

Nov 14, 2014

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The information pertaining to the equipment in the process did not include accurate piping and instrumentation diagrams:    On or about 05/14/2014, in the Sulfuric Acid Plant, including Spent and SO3 units, the employer did not ensure that the piping and instrumentation diagrams (P&IDs) and drawings were up-to-date and accurately reflected what was in the field/process unit:       a.     The notation on P&ID W1244142 showed that DT-1764, the Crossover Duct, was constructed of stainless steel.  It is made of carbon steel.       b.    P&ID W1244142 reflected DT-1803, the Hot Gas Bypass, as an open-ended duct, when it actually feeds into DT-1763, the Cold Air Bypass.        c.     The notation on Drawing W1785585 showed that maintenance vent header line 7617 continues on to P&ID W1323207, but on P&ID W1323207 line 7617 was marked as line 7613.       d.    The notation on Drawing W1785585 showed that maintenance vent header line 7608 continues on to P&ID W1323207, but on P&ID W1323207 line 7608 was marked as line 7607.      e.     Notations on Drawing W1785585 designated the gasket and bolting material for maintenance vent header lines which include, but are not limited to, 7608, 7613, 7609, and 7617 as P1N705J while notations on P&ID W1323207 designated the gasket and bolting materials as P1N705G.  The proper designation is P1N705E.         Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing steps it is taking to ensure that the P&IDs and drawings are accurate and up-to-date.

Issued

Nov 14, 2014

Abate by

Mar 27, 2015

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that was performed on process equipment with documentation that identified the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test:    On or about 05/14/2014, the employer did not ensure that the Corrosion Monitoring Eq/Circ ID Analysis Report for thickness measurements taken on the following process equipment was properly documented to include the name of the person who performed the inspection/test:    a.    Cold Interpass (CIP) - Bottom Tray;      b.    CIP - Grid.

Issued

Nov 14, 2014

Abate by

Mar 27, 2015

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(6)(iii): The employer did not assure that maintenance materials, spare parts and equipment were suitable for the process application for which they were used:    On or about 05/14/2014, in the Sulfuric Acid Plant, including Spent and SO3 units, the employer did not ensure that the Advanced Drainage Systems (ADS) polyethylene single wall pipe/hose used in conjunction with the Maintenance Vent Header to mitigate SO2 and SO3 leaks from process equipment which includes, but is not limited to, the CIP (HX-532), Converter (R-502), HIP (HX-531), Hot Gas Bypass (DT-1803), and Superheater (HX-530) was designed for use in the process application and constructed of material suitable for application in a process characterized by high temperatures and the formation of acid in the presence of moisture.    Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing steps it is taking to ensure that maintenance materials, spare parts and equipment are suitable for the process application.

Issued

Nov 14, 2014

Abate by

Dec 30, 2014

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes (except for replacements in kind) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process:    On or about 05/14/2014, the employer failed to implement procedures to manage changes in process equipment prior to implementing the use of HTS4200-600X25 stainless steel hoses as part of its leak mitigation efforts.

Issued

Nov 14, 2014

Abate by

Dec 30, 2014

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.151(c): Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:     Instance 1: On or about 05/14/2014, both spray heads on eye wash #10 exhibited low flow.      Instance 2: On or about 05/14/2014, the left spray head on eye wash #45 was not equipped with a dust cover.      Instance 3: On or about 05/14/2014, the right spray head on eye wash #49 exhibited low flow.