OSHA Inspection: PRYOR CHEMICAL COMPANY

Issued

Dec 4, 2015

Abate by

Apr 1, 2016

Penalty

Initial $7,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): Process safety information pertaining to the equipment in the process did not include relief system design and design basis.     The employer does not ensure that process safety information pertaining to the equipment in the process includes relief system design and design basis.    The violation occurred on or about June 9th 2015 and at times prior thereto in the #4 anhydrous ammonia plant where the employer failed to document relief system design and design basis included but is not limited to the following:      a.  PSV-827/PSV-870 (P&ID PCC-230-0514. Rev. 2)  b.  PSV-88 (P&ID PCC-230-0514. Rev. 2)  c.  PSV-856  (P&ID PCC-230-0520 Rev. 2)  d.  PSV-710 (P&ID PCC-230-0523 Rev. 2)  e.  PSV-810/PSV-813 (P&ID PCC-230-0528 Rev. 2)   f.   PSV-860/PSV-897 (P&ID PCC-230-0532 Rev. 2)   g.  PSV-692 (P&ID PPC-230-0542 Rev. 2)    This condition exposed employees to inhalation, fire, and explosion hazards.      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 process safety information pertaining to the equipment in the process includes relief system design and design basis.

Issued

Dec 4, 2015

Abate by

May 1, 2016

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E): Process safety information pertaining to the equipment in the process did not include ventilation system design.    The employer does not ensure that process safety information pertaining to the equipment in the process includes ventilation system design.    The violation occurred on or about June 9th 2015 and at times prior thereto in the #4 ammonia plant where the employer failed to ensure the ventilation system design for the compressor building was documented.  This condition exposed employees to inhalation, fire, and explosion hazards.    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 process safety information pertaining to the equipment in the process includes the ventilation system design.

Issued

Dec 4, 2015

Abate by

Dec 17, 2015

Penalty

Initial $4,000 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i):  The process hazard analysis did not address the hazards of the process.     The employer does not ensure the process hazard analysis addressed the hazards of the process.      The violation occurred in the #4 Anhydrous Ammonia Plant on or about June 09, 2015 and times prior thereto. Employees were exposed to inhalation and contact hazards when the employer failed to ensure the initial process hazards analysis addressed the hazards resulting from liquid releases/spills from open ended caps that include, but not limited to the following:      a.  3 ammonia line North End of Ammonia Receiver (D-26)  b.  3 Natural gas line by PSV 6A/B      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 the steps it is taking to ensure the process hazard analysis addresses the hazards of the process.

Issued

Dec 4, 2015

Abate by

Apr 1, 2016

Penalty

Initial $7,000 · Current $3,500 Reduced

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 written procedures are developed and implemented to maintain the on-going integrity of process equipment.      The violation occurred in #4 Anhydrous Ammonia Plant on or about June 9, 2015 and times prior to where the employer failed to ensure that written procedures were developed and implemented for testing and inspecting safety systems.  Critical safety systems include but not limited to:      a.  Emergency Shutdown for C4 compressor    b.  Emergency Shutdown for C5 compressor  c.  Emergency Shutdown for C-967331 Compressor (Big Red)        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 written procedures were developed and implemented for testing and inspecting critical safety systems.

Issued

Dec 4, 2015

Abate by

Apr 1, 2016

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment.    The employer does not ensure that tests and inspections were performed on process equipment.      The violation occurred in the #4 Anhydrous Ammonia Plant on or about June 9, 2015 and times prior to where the employer failed to ensure critical safety systems were tested and inspected.  Critical safety systems include but not limited to:      a.  Emergency Shutdown for C4 compressor    b.  Emergency Shutdown for C5 compressor  c.  Emergency Shutdown for C-967331 Compressor (Big Red)      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 critical safety systems were tested and inspected.

Issued

Dec 4, 2015

Abate by

Apr 1, 2016

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

1910.119(j)(4)(ii): Inspection and testing procedures did not follow recognized and generally accepted good engineering practices (RAGAGEP).    The employer failed to document that inspections and testing procedures followed recognized and generally accepted good engineering practices (RAGAGEP).      a. The violation occurred in the #4 ammonia plant on or about June 9th 2015 and at times prior thereto where the employer failed to document corrosion rates according to recognized and generally accepted good engineering practices such as America Petroleum Institute (API) 570 (Piping Inspection Code: In-service Inspection, Rating, Repair, and Alteration of Piping System) that includes, but is not limited to  the following piping segments:    1) Natural Gas 8"-P-1101-204X from off site to the Sulfur Drums D-1A/B (P&ID PPC-230-0503 Rev.2)  2) Natural Gas 8"-P-1102-204X from the Sulfur Drums D-1A/B to Suction Drum D-3(P&ID PPC-230-0503/4 Rev.2)  3) Natural Gas line 6"-FG-1201-201X to the Primary Former F-1(P&ID PCC-230-0511 Rev. 2)  4) Process Gas line 16"-P-1301-204FX from the High Temperature Shift Converter R2-A to the Mix Gas Preheater E-6  (P&ID PPC-  230-0514 Rev.2)  5) Syngas line 12"-P-1606-204FX from the Methanator Cooler (West) E-41 to the Methanator Separator D-12 (P&ID PPC-230- 0520 Rev.2)  6) Ammonia line 2"-R-2101-204X from  the Ammonia Letdown Drum D-19 to the Primary Ammonia Condenser E-24 (P&ID PPC-230-0533 Rev.2)     This condition exposed employees to inhalation, fire, and explosion hazards from releases of hazardous materials.    b. The violation occurred in the #4 ammonia plant on or about June 9, 2015 and at times prior thereto where the employer failed to document corrosion rates were established according to recognized and generally accepted good engineering practices such as America Petroleum Institute (API) 510 (Pressure Vessel Code: In-service Inspection, Rating, Repair, and Alteration) that includes, but is not limited to the following vessels:      1) High Temperature Shift Converter R2-A(P&ID PCC 230-0514 Rev. 2)  2) Methanator Separator D-12 (P&ID PCC-230-0520 Rev. 2)  3) Ammonia Converter 105-D1 (P&ID PCC-230-0525 Rev. 2)  4) Primary Ammonia Condenser E-24 (P&ID PCC-230-0528 Rev. 2)  5) Ammonia Separator D-17 (P&ID PCC-230-0529 Rev. 2)  6) Ammonia Receiver D-26 (P&ID PCC-230-0532 Rev. 2)  7) Auxiliary Steam Boiler B-2 (P&ID PCC-230-0566 Rev. 2)      This condition exposed employees to inhalation, fire, and explosion hazards from releases of hazardous materials.      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 document that equipment in the process complies with recognized and generally accepted good engineering practices.

Issued

Dec 4, 2015

Abate by

Dec 17, 2015

Penalty

Initial $7,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(m)(1): The employer did not investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace.       The employer does not investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace.       The violation occurred in the #4 ammonia plant on or about June 9th 2015 and at times prior thereto where the employer failed to investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals that include, but is not limited to activation of the following:     a.     PSV-629 (P&ID PCC-230-0542)  b.     PSV-882 (P&ID PCC-230-0534)      This condition exposed employees to inhalation, fire, and explosion hazards from releases of flammable hydrocarbons and anhydrous ammonia.      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 investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace.