OSHA Inspection: HARCROS CHEMICALS INC.

Issued

Apr 19, 2016

Abate by

Oct 3, 2016

Penalty

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

General-duty citation text

29 CFR 1910.119(c)(2): Employers did not consult with employees and their representatives on the conduct and development of process hazard analyses and on the development of the elements of process safety management in this standard:  At the facility employee(s) had not been consulted on the conduct and development of the following elements of the corporate's process safety management procedure:  (a)  process safety information (b)  process hazard analysis (c)  process safety management training (d)  mechanical integrity (e)  management of change (f)   pre-start up safety review (g)  contractors (h)  incident investigations (i)   emergency planning and response (j)  compliance audits (k)  trade secrets  Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Jun 2, 2016

Penalty

Initial $5,000 · Current $3,750 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D): Safe upper and lower limits for such items as temperatures, pressures, flows or compositions pertaining to the technology of the process were not compiled before conducting any process safety analysis required by this standard:  At the Ethylene Oxide plant, the employer had not established safe upper and lower limits for temperatures, pressures, and flows for the equipment / piping in the covered process.  Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(G): Information pertaining to the equipment in the process did not include material and energy balances for processes built after May 26, 1982:  At the Ethylene Oxide plant, the employer had not created a material and energy balance for the Ethylene Oxide plant.  Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Oct 3, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(A): The employer did not complete a compilation of process safety information pertaining to the material of construction of  equipment in the process:  The employer had not compiled the materials of construction process safety information for the equipment and piping in the Ethylene Oxide plant such as, but not limited to the following:  (a) ethylene oxide scrubber (T-302) (b) 2 inch CS schedule 40 (c) 2 inch 316 SS schedule 40 (d) flexible hose used to transfer ethylene oxide from the rail car (e) flexible hose used to transfer propylene oxide from the rail car (f)  two R-202 catalyst feed pots (g) blast walls surrounding the reactors  Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Feb 1, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): Design codes and standards pertaining to the equipment in the process were not compiled before conducting any process safety analysis required by this standard:  At the Ethylene Oxide plant, the employer did not include design codes and standards employed in the process safety information pertaining to equipment, including, but not limited to the following:  (a) piping (b) pressure vessels (c) valves (d) fittings (e) piping / equipment insulation  Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Jun 2, 2016

Penalty

Initial $5,000 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process:   At the Ethylene Oxide plant, the employer had not verified that all P&ID's were up to date and accurate for use by Harcros Chemical employee(s) and contractors for the process hazard analysis, line breaks, equipment/piping replacement/repairs, and etc., the following was noted:  (a) triple check valves were observed after FE 301-06 on the ethylene oxide line during the walk around, but not drawn on the p&ids  (b) during the walk around the ethylene oxide line split into 2 directions at PRV 301; one direction the 2 inch pipe had a reducer that reduced pipe to 1 inch that led to the PRV 301, the other direction the 2 inch line had a reducer that reduced the pipe to 1 inch that led toward the ethylene oxide intermediate tank T-301; neither line was drawn on the p&id.  (c) pump selector switch HS 313 was drawn on the p&id, but not observed during the walk around.  (d) two pressure gages were observed on opposite sides of a normally open gate valve that was located on the ethylene oxide line between the feed pump P-301A and the cooler E-301 was not drawn on the p&id.  (e)  pressure gage 314 and two other gate valves drawn on the p&id was not observed during the walk around.  (f) a pressure gage was observed on the ethylene oxide line after a gate valve prior to pipe slope to the reactors  (g) triple check valves were observed during the walk around prior to on/off flow control valve (XV 201-20) leading to reactor R-202  (h) no gate valve was observed during the walk around on the ethylene oxide line leading to reactor R-205, reactor R-204, and the scrubber tank T-302  (i) a two inch to one inch reducer was observed on the ethylene oxide pipe line before the on/off flow control valve (XV 301-21) leading to reactor R-204 was not drawn on the p&id  (j) a nitrogen line was observed connected to the ethylene oxide pipe line that was exiting from the ethylene oxide cooler (E-301), but not drawn on the p&id  (k) on/off control valve (XV 303-4) was drawn on the p&id, but was not observed on the propylene oxide pipe line during the walk around  (l) after the blue lever ball valve on the propylene oxide line, a propylene oxide pipe line leading to a truck tanker intersected the propylene oxide pipe line to the intermediate tank (T-303), was not drawn on the p&id  (m) a ball valve was observed on the propylene oxide pipe line after the piping intersection to the truck tanker;  this ball valve was not drawn on the p&id  (n) a pressure gage and two gate valves were not observed during the walk around after propylene oxide feed pump (P-303A), but drawn on the p&id  (o) a pipe reducer labeled two inch to one inch was observed during the walk around to be 1 inch to 2 inches after propylene oxide feed pump (P-303A), but not drawn on the p&id  (p) two pressure gages and a needle valve were observed between the propylene oxide feed pump (P-303A) and the propylene oxide cooler (E-303), but not drawn on the p&id  (q) a two inch to 1 inch reducer was observed during the walk around between the propylene oxide feed pump (P-303A) and on/off control valve (XV 303-21) leading to reactor R-204, but not drawn on the p&id  (r) two flanges were observed during the walk around after the unlabeled on/off control valve leading to reactor R-205, but not drawn on the p&id  (s) a 3/4 inch gate valve on the 3" 316SS pipe line was not observed during the walk around, but drawn on the p&id  (t) a gate valve between FE 204-7 and TW204-6 on 3" 316SS pipe line was observed during the walk around, but not drawn on the p&id  (u) a 3/4" pipe line with a 3/4" gate valve were observed connecting two hose connection pipe lines prior to their 3/4" gate valves during the walk around of the reactor exchanger (E-204A), bottom section  (v) a 3/4" gate valve and pipe line were observed during the walk around attached to the reactor exchanger (E-204A), but not drawn on the p&id  (w) pressure indicator/transmitter number 204 had moved to a new location on ethylene oxide transfer system pipe line 2"316SS, the pressure indicator/transmitter #204 was observed before the triple check valves prior to the propylene oxide transfer section piping intersection  (x) after flow valve 204-1 on pipe line 2"316SS leading to the ethylene oxide reactor (R-204) the following was observed during the walk around, but not drawn on the p&id: triple check valves, pipe and flange, gate valve, pipe and flange  (y) pressure indicators 210 and 215 were not observed during the walk around, but were drawn on the p&id  (z) on drawing D156PD04A the majority of the pipe lines were not labeled to identify their size and material of contruction  (aa) a 6 inch to 4 inch reducer was observed during the walk around before pump P-204A, but not drawn on the p&id  (bb) a 3 inch to 2 inch reducer was observed during the walk around after pump P-204A, but not drawn on the p&id  (cc) ethylene / propylene oxide vent transfer line 2"316SS SCH 40 Process to the ethylene oxide water jet scrubber tank (T-302) had a flange, check valve, and gate valve observed during the walk around, but not drawn on the p&id  (dd) propylene oxide vent line 2"316SS SCH 40 Process to the ethylene oxide water jet scrubber tank (T-302) had a flange, check valve, and gate valve observed during the walk around, but not drawn on the p&id  (ee) no triple check valves or a gate valve were observed during the walk around of the ethylene oxide feed line 2"316 SS Process to the ethylene oxide reactor (R-202), but were drawn on the p&id (D156PD03)  (ff) no pressure indicator or transmitter were observed after the flow transmitter (202-1) during the walk around of the ethylene oxide feed line 2"316 SS Process to the ethylene oxide reactor (R-202), but were drawn on the p&id (D156PD03)  (gg) during the walk around an approximate 8 inch braided hose and flange were connected to the ethylene oxide feed line 2"316 SS Process to the ethylene oxide reactor (R-202) after the flow valve (FV 202-1), this was not drawn on the p&id  (hh) a pressure transmitter was observed during the walk around on the propylene oxide feed line 2"316 SS Process to the ethylene oxide reactor (R-202), but not drawn on the p&id  (ii) a pressure gage was observed between the propylene oxide feed pump (P-303A) and reactor (R-204), reactor (R-205), and scrubber tank (T-302), but not drawn on the p&id   Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Oct 3, 2016

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(e)(1): The process hazard analysis was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in the process:   (a) the employer did not address  or evaluate the safe upper and lower pressures, temperatures, and flows of the equipment compared to the safe upper and lower pressures, temperatures, and flows of the operating procedures   (b) the process hazard analysis did not address or evaluate the possibility of flooding or levee failure   (c) the process hazard analysis did not address or evaluate the consequences of not providing temperature probes for all ethylene oxide rail cars   (d) the process hazard analysis did not address or evaluate the consequences of an ethylene oxide or propylene oxide rail car derailment within the boundary of the Ethylene Oxide plant   (e) the process hazard analysis did not control the hazards of pressure relief devices not being provided for R-202 and R-204 catalyst feed pots in the Ethylene Oxide plant   Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Dec 1, 2016

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address the hazards related to facility siting:   The employer failed to adequately address fire / explosion hazards related to the facility siting of occupied structures including, but not limited to the control room inside the Ethylene Oxide plant.  There was no process safety information for the design or construction of the walls surrounding the reactors.    Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Oct 1, 2017

Penalty

Initial $6,000 · Current $6,000

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 involved in each covered process consistent the safety information and which address the elements listed in 29 CFR 1910.119(f)(1)(i) through (f)(1)(v):   (a) The operating procedures for the Ethylene Oxide plant were missing the following sections:       (1) emergency shutdown including conditions under which emergency shutdown is required       (2) startup following an emergency shutdown       (3) emergency operations       (4) temporary operations       (5) steps required to correct a deviation       (6) measures to be taken if physical contact or airborne exposure were to occur       (7) quality control for raw materials  (b) At the Ethylene Oxide plant, the employer did not develop and implement a written operating procedure for shift change.  (c) At the Ethylene Oxide plant, the employer did not develop and implement a written operating procedure for the management of valves such as identifying all critical valves, identifying all car sealed valves, and etc.  (d) At the Ethylene Oxide plant, the employer did not develop and implement a written operating procedure for inserting / removing temperature probes inside of railcars containing either ethylene or propylene oxide.  (e) At the Ethylene Oxide plant, the employer did not develop and implement a written operating procedure for providing clear instructions on accepting railcars containing Ethylene or Propylene Oxide.  The operating procedure shall include, but not limited to the following:                (1) that the maintenance and pressure relief valves labels on the outside of the railcars are not overdue      (2) that the railcars are not significantly damaged or corroded      (3) that the railcars are the correct railcars for transporting Ethylene and Propylene Oxide   Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Aug 1, 2016

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(g)(1)(i): The employer did train each employee in an overview of the process:   (a) Maintenance employee(s) performing preventive maintenance and maintenance on process equipment and piping in the Ethylene Oxide plant were not provided training on the company's process safety management policy.   (b) Tug operators moving Ethylene and Propylene Oxide rail cars in or out of the Ethylene Oxide plant were not provided training on the company's process safety management policy.   (c) Management representative(s) responsible for elements of the company's corporate process safety management policy have not been provided training on the company's process safety management policy.   Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Dec 1, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

1910.119(g)(3):  The employer shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training:  At the establishment the employer had not developed nor implemented a verification process to determine if employees understood the training over the operating procedures. The workers working in the ethylene / propylene oxide process conducted their own training over the written operating procedures.  Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Jun 2, 2016

Penalty

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

General-duty citation text

29 CFR 1910.119(h)(2)(i): 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 program:  (a) At the establishment the employer had not obtained and evaluated all of the contractor's safety / health performance and programs for the Ethylene Oxide plant.  The following contractor performs technical support, remote system diagnosis, emergency response access, and software updates for the DeltaV software program that operates the Ethylene Oxide Plant:  Experitec  (b) At the establishment the employer had not obtained and evaluated all of the contractor's safety / health performance and programs for the Ethylene Oxide plant.  The following contractor performs non-destructive testing at the facility:  Acuren  Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Apr 19, 2017

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment:    a)  The employer did not develop and implement a written mechanical integrity procedure that addressed maintaining the on-going integrity of the following process equipment:  pressure vessels, valves, piping, and etc.   b)  The employer did not develop and implement a written mechanical integrity procedure for corrosion under the insulation inspections for pressure vessels and piping.  c)  The employer did not develop and implement a written mechanical integrity procedure to monitor and recommend follow-up inspections on equipment such as pressure vessels or piping that are operating with a deficiency.   d)   The employer did not develop and implement a written mechanical integrity procedure to address anomalous reading pertaining to metal thickness in pressure vessels and piping.  e)   The employer did not develop and implement a written mechanical integrity procedures for addressing foundation supports, pipe racks, and metal to metal corrosion.   Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Nov 1, 2017

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on the following process equipment and piping:  (a) Ethylene Oxide Cooler (E-301)  (b) Propylene Oxide Cooler (E-303)  (c) Ethylene Oxide Jet Scrubber Tank (T-302)  (d) Catalyst Charge Pot (V-203A)  (e) Neutralizing Charge Pot (V-203B)  (f) Ethylene Oxide Pump Seal Pot (V-302)  (g) Propylene Oxide Pump Seal Pot (V-304)  (h) R204 Glycol Heating (E-214B)  (i) R202 Glycol Expansion Tank (ET-202)  (j) R202 Glycol Cooling (E-213A)  (k) R202 Glycol Heating (E-213B)  (l) Glycol piping  (m) Nitrogen piping  (n) PSV - 1x1 150x150 located at T301 Top, West had not receive annual inspection  (o) PSV - 1x1 150x150 located at T303 Top, West had not receive annual inspection  (p) PSV - 1x1 MxF located at T301, T303, N2 Line West of R201 had not receive annual inspection  (q) PSV - 1x1 MxF located at R202, N2 line above ECV's had not receive annual inspection  (r) PSV - 14 valves attached to the Glycol pipe line had not received their annual inspection  Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Nov 1, 2016

Penalty

Initial $6,000 · Current $5,000 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:    At the facility the employer had not implemented the management of change program to address changes to the ethylene and propylene processes; there has been several changes to the processes such as but not limited to the following:  (a) the installation of a manual gate valve and regulator on R-204B recirculating head  (b) replacing the pressure relief valve on T-301 (ethylene oxide intermediate tank) with a new size pressure relief valve  (c) replacing the pressure relief valve on T-303 (propylene oxide intermediate tank) with a new size pressure relief valve  (d) for the removal of pressure gage (PG 338) and 2 gate valves from the propylene oxide pipe line exiting from feed pump P-303A  (e) for the removal of a 3/4 inch flanged gate valve on the product line after a 3 inch gate valve headed toward the bottom of E204A (reactor exchanger)   (f) for the removal of on/off flow control valve (XV 303-4) for the propylene oxide pipeline exiting the rail car and entering the propylene oxide intermediate tank (T-303)  (g) for the removal of a backflow preventer valve on the ethylene oxide feed line to the reactor (R-202), prior to the flow transmitter (202-1)  (h) for the removal of a pressure transmitter / indicator on the ethylene oxide feed line to the reactor (R-202), prior to the on / off flow control valve (XV 202-1)  Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Aug 1, 2016

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(n): The employer did not implement an emergency plan for the entire plant in accordance with the provisions of 29 CFR 1910.38:  The employer's emergency action plan requires all ethylene oxide railcars to be monitored upon arrival at the ethylene / propylene oxide process with a wireless temperature probe for any type of reaction inside the railcars.  The following ethylene oxide rail cars were observed without temperature probes:  (a) UTLX 930296   (b) UTLX 902053    (c) UTLX 902299   Employee(s)  were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2016

Abate by

Oct 3, 2016

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.120(q)(1): The employer did not develop and implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:    At the Ethylene Oxide plant, the employer had not developed and implemented an emergency response plan to address leaks or drips of Ethylene Oxide or Propylene Oxide in the covered process, thus exposing employee(s) to health hazards.

Issued

Apr 19, 2016

Abate by

Oct 3, 2016

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.120(q)(6): The employer did not provide training in accordance with 29 CFR 1910.120(q)(6)(i) through (q)(6)(v) for employees who participated in or were expected to participate in emergency response:    Employee(s) working in the Ethylene Oxide plant were exposed to health hazards in that the employees were not trained in the procedures required for stopping ethylene or propylene oxide leaks or drips.