OSHA Inspection: ELAN CHEMICAL COMPANY INC .

Issued

Feb 4, 2016

Abate by

Mar 26, 2016

Penalty

Initial $4,900 · Current $672 Reduced

General-duty citation text

29 CFR 1910.23(c)(1): Open-sided floors and/or platforms four feet or more above adjacent floor or ground level were not guarded with standard railings (or equivalent) and toe boards:    a) Establishment - autoclave area    Employees were exposed to fall hazards of 10ft while working on an autoclave with an unguarded side to the platform near the autoclave. A wood plank was used to gain access to the rear of the autoclave.     Violation observed on or 8/4/2015.

Issued

Feb 4, 2016

Abate by

Mar 26, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Information pertaining to equipment in the process did not include piping and instrument diagrams (P&IDs):    a) Establishment - PEEB Process    The employer did not ensure that the written process safety information included all necessary information pertaining to equipment in the process when piping specifications were not shown for ethyl chloride storage tank T-153 on PEEB Process P&ID TCPA Rev. Dated 6 11/01/2014.    b) Establishment - PEEB Process    The employer did not ensure that the written process safety information included all necessary information pertaining to equipment in the process when hand valve A1-CH-002, a bleed line and valve between A1-CV-NIT and A1-HV-NIT and a flex line between WT-HV-NIT and WT-100 were not shown on on PEEB Process P&ID TCPA Rev. Dated 6 11/01/2014.    c) Establishment - PEEB Process    The employer did not ensure that the written process safety information included all necessary information pertaining to equipment in the process when valves NIT-HV-004 and NIT-HV-005 were not shown to be normally padlocked on PEEB Process P&ID TCPA Rev. Dated 6 11/01/2014.      d) Establishment - PEEB Process    The employer did not ensure that the written process safety information included all necessary information pertaining to equipment in the process when valves 153-HV-002 and WT-HV-SV were not shown to be normally padlocked or car sealed open on PEEB Process P&ID TCPA Rev. Dated 6 11/01/2014.    e) Establishment - PEEB Process    The employer did not ensure that the written process safety information included all necessary information pertaining to equipment in the process when compressed air to pneumatic valves WT-CV-VENT, WT-CF-NIT, A1-CV-ETC, A1-CV-NIT and A1-CV-VA were not shown on PEEB Process P&ID TCPA Rev. Dated 6 11/01/2014.    f) Establishment - PEEB Process    The employer did not ensure that the written process safety information included all necessary information pertaining to equipment in the process when design temperature and pressure ratings, size or capacity for tank T-153,  tank WT-100 and autoclave A1 were not shown on PEEB Process P&ID TCPA Rev. Dated 6 11/01/2014.    g) Establishment - PEEB Process    The employer did not ensure that the written process safety information included all necessary information pertaining to equipment in the process when failure modes of automatic valves were not shown on PEEB Process P&ID TCPA Rev. Dated 6 11/01/2014.    h) Establishment - PEEB Process    The employer did not ensure that the written process safety information included all necessary information pertaining to equipment in the process when flash arresters on tanks T-153 and WT-100,  a pressure relief valve upstream of NIT-HV-001, scales on tank WT-100 and autoclave A1 and an agitator on A1 were not labeled on PEEB Process P&ID TCPA Rev. Dated 6 11/01/2014.      i) Establishment - PEEB Process    The employer did not ensure that the written process safety information included all necessary information pertaining to equipment in the process when blackening of certain hand valves including but not limited to 153-HV-DRN and WT-HV-SV was not explained on PEEB Process P&ID TCPA Rev. Dated 6 11/01/2014.      Violations occurred on or about 8/10/15.

Issued

Feb 4, 2016

Abate by

Jun 30, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D): Process safety information pertaining to the technology of the process did not include the safe upper and lower limits for such items as temperatures, pressures, flows or compositions:    a) Establishment -PEEB process storage tank T-153    Pressure vessel T-153 was used to store approximately 7,500 gallons of ethyl chloride, a flammable liquid, without basic process safety information such as maximum allowable working pressure, maximum allowable external pressure. The vessel is normally under 45-50 psig nitrogen at ambient temperature.    Violation occurred on or about 8/4/2015

Issued

Feb 4, 2016

Abate by

Jun 30, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(A): Process safety information pertaining to the equipment in the process did not include materials of construction:    a) Establishment -PEEB process storage tank T-153    Pressure vessel T-153 was used to store approximately 7,500 gallons of ethyl chloride, a flammable liquid, without basic process safety information, including but not limited to design/manufacture information such as materials of construction. The vessel is normally under 45-50 psig nitrogen at ambient temperature.     Violation occurred on or about 8/4/2015.

Issued

Feb 4, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

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 (RAGAGEP).    a) Tank T-153 Intervening/Stop Valve 153-HV-002    The employer did not comply with RAGAGEP such as, but not limited to, ASME Boiler and Pressure Vessel Code, Section VIII, UG-135(d) when it failed to provide adequate controls to ensure that an intervening stop valve (Isolation Valve 153-HV-002 on ethyl chloride tank T-153) upstream from pressure relief devices remained in the open position during pressure vessel operation.    Violation occurred on or about 8/4/15.      b) Weigh tank Intervening/Stop valve WT-HV-SV    The employer did not comply with RAGAGEP such as, but not limited to, ASME Boiler and Pressure Vessel Code, Section VIII, UG-135(d) when it failed to provide adequate controls to ensure that an intervening stop valve (Isolation Valve WT-HV-SV on ethyl chloride weigh tank WT-100) upstream from pressure relief devices remained in the open position during pressure vessel operation.      Violation occurred on or about 8/4/15.

Issued

Feb 4, 2016

Abate by

Jun 30, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting:    a) Establishment - PEEB Process    The 2013 PHA did not address potential ethyl chloride vapor cloud explosion over pressure impact on site equipment, buildings & personnel. Scenarios in the 2008 TCPA risk assessment calculated boundaries of  1, 2.3 and 5 psi  over pressure waves but an evaluation of the on site consequences of the over pressure was not conducted.      Violation occurred on or about 8/4/2015.

Issued

Feb 4, 2016

Abate by

Mar 26, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(G): The employer's written operating procedures covering the steps for each operating phase did not address startup following an emergency shutdown:    a) Establishment - PEEB    The employer did not write operating procedures for startup after an emergency shutdown or interruption of the PEEB process, where ethyl chloride and/or product remain in the process equipment following the shutdown. The existing written start up procedure assumes the process equipment is empty.    Violation occurred on or about 8/4/2015.

Issued

Feb 4, 2016

Abate by

Jun 30, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(i): The employer, when selecting a contractor, did not obtain and evaluate information regarding the contract employer's safety performance and programs:    a) Establishment - PEEB Process    An outside contractor conducted calibration and service on scales that are part of the covered PEEB process. Safety performance and programs were not evaluated.    b) Establishment - PEEB Process    An outside contractor conducted service & testing on the deluge system on T-153, the 15,000gallon storage tank filled with ethyl chloride. Safety performance and programs were not evaluated.    c) Establishment - PEEB Process    An outside contractor conducted service on the nitrogen system, which provided nitrogen blanket pressure of 40PSIG to the covered process. Safety performance and programs were not evaluated.    Violation occurred on or about 9/22/2015.

Issued

Feb 4, 2016

Abate by

Jun 30, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(ii):  The employer did not inform contract employees of the known potential fire, explosion or toxic release hazards related to the contractor's work and the covered process:    a) Establishment - PEEB Process    An outside contractor conducted calibration and service on scales that are part of the covered PEEB process, without receiving information about the fire/explosion hazards related to ethyl chloride, a highly flammable liquid.     b) Establishment - PEEB Process    An outside contractor conducted service & testing on the deluge system on T-153, the 15,000gallon storage tank filled with ethyl chloride, without receiving information about the fire/explosion hazards related to ethyl chloride, a highly flammable liquid.     c) Establishment - PEEB Process    An outside contractor conducted service on the nitrogen system, which provided nitrogen blanket pressure of 40PSIG to the covered process, without receiving information about the fire/explosion hazards related to ethyl chloride, a highly flammable liquid.     Violation occurred on or about 9/22/2015.

Issued

Feb 4, 2016

Abate by

Jun 30, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(iii): The employer did not explain to contract employees the applicable provisions of the emergency action plan as required by 29 CFR 1910.119(n):    a) Establishment - PEEB Process    An outside contractor conducted calibration and service on scales that are part of the covered PEEB process, without receiving information from emergency action plan; specifically evacuation procedures, emergency notification procedures.    b) Establishment - PEEB Process    An outside contractor conducted service & testing on the deluge system on T-153, the 15,000gallon storage tank filled with ethyl chloride, without receiving information from emergency action plan; specifically evacuation procedures, emergency notification procedures.    c) Establishment - PEEB Process    An outside contractor conducted service on the nitrogen system, which provided nitrogen blanket pressure of 40PSIG to the covered process, without receiving information from emergency action plan; specifically evacuation procedures, emergency notification procedures.    Violation occurred on or about 9/22/2015.

Issued

Feb 4, 2016

Abate by

Jun 30, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment:    a) Establishment - PEEB Process    The employer did not establish and implement written procedures for internal and external inspection of tank WT-100.     Violation occurred on or about 8/4/15.      b) Establishment - PEEB Process    The employer did not establish and implement written procedures for internal and external inspection of autoclave A1.     Violation occurred on or about 8/4/15.      c) Establishment - PEEB Process    The employer did not establish and implement a written procedure for external inspection of process piping.     Violation occurred on or about 8/4/15.      d) Establishment - PEEB Process    The employer did not establish a written procedure for testing grounding of tanks and equipment.    Violation occurred on or about 8/4/15.      e) Establishment - PEEB Process    The employer did not establish and implement a written procedure for inspection of pressure relief valves upon removal.    Violation occurred on or about 8/4/15.    f) Establishment - PEEB Process    The employer did not implement procedure Mech-SOP-003 and Mech-SOP-004 which specify locking isolation valve 153-HV-002 on ethyl chloride tank T-153 and isolation valve WT-HV-SV on weight tank WT-100 open when vessels T-153 & WT-100 are in-service.    Violation occurred on or about 8/4/2015.

Issued

Feb 4, 2016

Abate by

Jun 30, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment    a) Establishment - PEEB Process    The employer failed to perform inspection and testing of flame arresters on vent lines of tank T-153 and WT-100.    Violation occurred on or about 8/4/15.      b) Establishment - PEEB Process    The employer failed to perform inspection and testing of grounding wires for tank T-153 and autoclave A1.    Violation occurred on or about 8/4/15.

Issued

Feb 4, 2016

Abate by

Jun 30, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(ii): Inspection and testing procedures did not follow recognized and generally accepted good engineering practices (RAGAGEP):    a) Establishment - PEEB Process    The chemical manufacturing employer did not document that it complied with recognized and generally accepted good engineering practice, such as API 510 (2014), Section 4.4, when pressure vessel inspection (T-153 and WT-100) were conducted without a qualified inspector being directly involved in the inspections exposing employees to the hazards of fire and explosion.    Violation occurred on or about 8/4/15.      b) Establishment - PEEB Process    The chemical manufacturing employer did not document that it complied with recognized and generally accepted good engineering practices, such as but not limited to API Std. 510 (2014), Section 6.6 when the employer did not inspect or test pressure relief valves it replaced, as a result inspection and testing information was not available for determining appropriate inspection intervals for these valves exposing employees to the hazard of fire and explosion.     Violation occurred on or about 8/4/15.

Issued

Feb 4, 2016

Abate by

Jun 30, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:    a) Establishment - PEEB Process    Pressure relief valves were not inspected and replaced by their required due dates.  Valve 153-PSV-1 was last replaced 6/15/2013 (WO 182); WT-PSV-1 was last replaced 6/15/2013 (WO 183).  Replacement on a two year basis required completion by 6/15/2015.     Violation occurred on or about 8/4/15.      b) Establishment - PEEB Process    Tank pressure switches were not inspected and tested by their required due dates.  PS1 was last tested 7/2/2014 (WO 310); PS2 was last tested 7/2/2014 (WO101).  Retesting on an annual basis required reinspection and testing by 7/2/2015.    Violation occurred on or about 8/4/15.      c) Establishment - PEEB Process    Loading hoses were not inspected and tested by their required due dates.  Hoses were last tested 7/2/2014 (WO 312).  Retesting on an annual basis required reinspection and testing by 7/2/2015.    Violation occurred on or about 8/4/15.

Issued

Feb 4, 2016

Abate by

Jun 30, 2016

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process:    a) Establishment - PEEB Process    The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2014 TCPA compliance audit including changing valve notification on the programmable logic controller to flow/not flow    Violation occurred on or about 8/4/15.    b) Establishment - PEEB Process    The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for installing a pressure transducer on TK-153 with low pressure alarm (completed 12/31/13)    Violation occurred on or about 8/4/15.    c) Establishment - PEEB Process    The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for installing a pressure gauge in the nitrogen line upstream of NIT-RV-1 (completed 3/2014)    Violation occurred on or about 8/4/15.    d) Establishment - PEEB Process    The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for installing a blank flange in the sample line off autoclave A1.    Violation occurred on or about 8/4/15.    e) Establishment - PEEB Process    The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for providing PLC logic to close the steam supply valve on high autoclave pressure (completed 12/2013)    Violation occurred on or about 8/4/15.    f) Establishment - PEEB Process    The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for adding instructions to operating procedures to explicitly instruct operator not to start the agitator if temperature is at setpoint (completed 11/2013)    Violation occurred on or about 8/4/15.    g) Establishment - PEEB Process    The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for installing separate actuated valves and lines, one for the process vent to atmosphere separate from vacuum line (completed 12/2013)    Violation occurred on or about 8/4/15.    h) Establishment - PEEB Process    The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for installing a cap or plug in bleed valve line after usage (completed 12/1/2013)    Violation occurred on or about 8/4/15.    i) Establishment - PEEB Process    The employer did not follow management of change (MOC) procedures for installation of a Programmable Logic Controller (PLC) for the covered process in 2013.    Violation occurred on or about 8/4/15.      j) Establishment - PEEB Process    The employer did not follow management of change (MOC) procedures when process piping was converted to stainless steel in 2012.    Violation occurred on or about 8/4/15.    k) Establishment - PEEB Process    The employer did not follow management of change (MOC) procedures when recalculating MAWP for WT-100.    Violation occurred on or about 8/4/2015.

Issued

Feb 4, 2016

Abate by

Mar 26, 2016

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met:    a)  Establishment    The employer did not implement the labeling provisions of its written hazard communication program when it failed to label a 15,000 gallon storage tank for ethyl chloride, a flammable, liquefied gas.    Violation occurred on or about 8/4/15.

Issued

Feb 4, 2016

Abate by

Mar 26, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(f)(5): The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged, or marked with the identity and appropriate hazard warnings regarding the chemicals contained therein:    a)  Establishment    The employer did not ensure that a 15,000 gallon storage tank for ethyl chloride, a flammable, liquefied gas was labeled or marked with the identity of the chemical.    Violation occurred on or about 8/4/15.