OSHA Inspection: SOLVAY SPECIALTY POLYMERS USA, LLC

Issued

Aug 1, 2016

Abate by

Aug 22, 2016

Penalty

Initial $0 · Current $6,500

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complied with recognized and generally accepted good engineering practices:    c) D2 Vinylidene Fluoride Process (VF2): The employer failed to document that equipment complied with RAGAGEP, such as, but not limited to, API 520 part II 2003 sections 6.3.4(g) and 6.5. An administrative control or mechanical interlock was not provided for the three way safety relief valves, PSV-20945A/B, on V-218A, and PSV-20948A/B, on V-218B, to keep the valves from being positioned in the center, which would block flow to both relief valves, to ensure that the overpressure protection of the vessel was not compromised, on or about 2/9/16.     d) D2 Vinylidene Fluoride Process (VF2): The employer failed to document that equipment complied with RAGAGEP, such as, but not limited to, API 520 part II 2003 section 4.2.2. The analysis for PSV-20945A/B, on V-218A, and PSV-20948A/B, on V-218B, revealed inlet pressure losses in excess of 3% of set point, potentially compromising stable relief valve operation and adequate flow capacity, on or about 2/9/16.         NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 1, 2016

Abate by

Aug 22, 2016

Penalty

Initial $5,000 · Current $12,500

General-duty citation text

29 CFR 1910.119(e)(3)(iii): The process hazard analysis did not address engineering and administrative controls applicable to the hazards:    a) D2 Vinylidene Fluoride Process (VF2):  In the employer's 2011 PHA, the HAZOP did not list the safeguards in place for improper labeling of V-212 on P&ID F205 sheet 1(page 80 node 19), on or about 2/9/16.    b) D2 Vinylidene Fluoride Process (VF2):  In the employer's 2011 PHA, the HAZOP did not list the safeguards in place for high pressure due to failure of a check valve not holding downstream of DV-209 (page 84 node 20), on or about 2/9/16.    c) D2 Vinylidene Fluoride Process (VF2):  In the employer's 2011 PHA, the HAZOP did not list the safeguards in place for a compressor malfunction (page 85 node 20), on or about 2/9/16.    d) D2 Vinylidene Fluoride Process (VF2):  In the employer's 2011 PHA, the HAZOP did not list the safeguards in place for a deadleg located in line 20510 from V-213 to the air column (page 91 node 21), on or about 2/9/16.    e) D2 Vinylidene Fluoride Process (VF2):  In the employer's 2011 PHA, the HAZOP did not list the safeguards in place for a tube rupture in E-212 (page 102 node 24), on or about 2/9/16.    f) D2 Vinylidene Fluoride Process (VF2):  In the employer's 2011 PHA, the HAZOP did not list the safeguards in place for the manual valves to E 213.1 left open or by-passed (page 126 node 31), on or about 2/9/16.    g) D2 Vinylidene Fluoride Process (VF2):  In the employer's 2011 PHA, the HAZOP did not list the safeguards in place for out of service equipment including V 191 and related equipment for the 142b recovery (page 162 node 45), on or about 2/9/16.    h) D2 Vinylidene Fluoride Process (VF2):  In the employer's 2011 PHA, the HAZOP did not list the safeguards in place when an operator opens a by-pass around the condensate return valve on the re-boilers (page 174 node 47), on or about 2/9/16.          NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 1, 2016

Penalty

Initial $5,000 · Current $12,500

General-duty citation text

29 CFR 1910.119(f)(1)(i)(E): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information that addressed the steps for each operating phase, including emergency operations:    a) D2 Vinylidene Fluoride Process (VF2): The employer's written operating procedures failed to provide clear instructions for emergency operations, including temperature maintenance of the VF2 storage tanks, V217 A/B and V218 A/B, during extended power outages where generators are not available, on or about 2/9/16.

Issued

Aug 1, 2016

Abate by

Aug 22, 2016

Penalty

Initial $5,000 · Current $12,500

General-duty citation text

29 CFR 1910.119(f)(3): The operating procedures were not reviewed as often as necessary to assure that they reflected current operating practice, including changes that resulted from changes in process chemicals, technology, and equipment, and changes to facilities:    a) D2 Vinylidene Fluoride Process (VF2): Operating Procedures 6.1 Monomer Area Alarm Relief Interlocks incorrectly listed PSE 20123 and PSV 20123 as being a part of E231, the monomer reactor economizer's relief system, on or about 2/9/16.    b) D2 Vinylidene Fluoride Process (VF2): Operating Procedures 6.1 Monomer Area Alarm Relief Interlocks incorrectly listed PSV 21338 as being a part of C210, the acid absorber tails tower, on or about 2/9/16.    c) D2 Vinylidene Fluoride Process (VF2): Operating Procedures 6.1 Monomer Area Alarm Relief Interlocks incorrectly listed two PSVs 20618 on E216, the monomer column condenser, on or about 2/9/16.    d) D2 Vinylidene Fluoride Process (VF2): Operating Procedures 5.6 Caustic Scrubbing System incorrectly listed pH probe AE20398 as measuring the spent caustic in C206, the primary monomer scrubber, on or about 2/9/16.    e) D2 Vinylidene Fluoride Process (VF2): Operating Procedures 5.11 Monomer Column incorrectly listed C203, the lights column, as still in service, on or about 2/9/16.     f) D2 Vinylidene Fluoride Process (VF2): Operating Procedures 6.2 Operating Deviations incorrectly listed C203, the lights column, as still in service, on or about 2/9/16.    g) D2 Vinylidene Fluoride Process (VF2): Operating Procedures 5.12 Recycling Column incorrectly listed C203, the lights column, as still in service, on or about 2/9/16.    h) D2 Vinylidene Fluoride Process (VF2): Operating Procedures 6.1 Monomer Area Alarm Relief Interlocks incorrectly listed PAH-20749 on the distillation recycle column C204, set at 110 psig, on or about 2/9/16.    i) D2 Vinylidene Fluoride Process (VF2): Operating Procedures 6.1 Monomer Area Alarm Relief Interlocks did not list PAHH-20749 on the distillation recycle column C204, which is an interlock that activates an area shutdown switch, HS-206100, on or about 2/9/16.    NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 1, 2016

Abate by

Aug 22, 2016

Penalty

Initial $5,000 · Current $12,500

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspections and tests on process equipment:    a) D2 Vinylidene Fluoride Process (VF2): The employer did not inspect and test the high pressure alarm (PAHH) 20509, a control device, on the first stage suction pressure of compressor K-201, on or about 2/9/16.     b) D2 Vinylidene Fluoride Process (VF2): The employer did not inspect and test an emergency shutdown switch, HS-206100, for the 200 area monomer distillation process, on or about 2/9/16.    c) D2 Vinylidene Fluoride Process (VF2): The employer did not inspect and test a level control indicator (LIC-20607), a control device, on condenser E-214 for distillation column C-201, on or about 2/9/16.      NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 1, 2016

Abate by

Aug 22, 2016

Penalty

Initial $25,000 · Current $0 Reduced

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) D2 Vinylidene Fluoride Process (VF2): The employer did not establish written procedures to maintain the on-going integrity of a high pressure alarm (PAHH-20509), a control device, on the first stage suction pressure of compressor K-201, on or about 2/9/16.     b) D2 Vinylidene Fluoride Process (VF2): The employer did not establish written procedures to maintain the on-going integrity of an emergency shutdown switch, HS-206100, for the 200 area monomer distillation process, on or about 2/9/16.    c) D2 Vinylidene Fluoride Process (VF2): The employer did not establish written procedures to maintain the on-going integrity of a level indicator control (LIC-20607), a control device, on condenser E-214 for distillation column C-201, on or about 2/9/16.    d) D2 Vinylidene Fluoride Process (VF2): The employer did not establish written procedures to maintain the on-going integrity of C-112 the Drowning Tower, on or about 2/9/16.     NOTE: IN ADDITION TO ABATEMENT CERTIFICATION, THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT DOCUMENTATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.     Solvay Specialty Polymers LLC USA was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.119(j)(2), which was contained in OSHA inspection number 925822, citation number 1, item number 4 and was affirmed as a final order on 2/21/14 with respect to a workplace located at 17005 State Route 7 Marietta, OH 45750.

Issued

Aug 1, 2016

Abate by

Aug 22, 2016

Penalty

Initial $5,000 · Current $12,500

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish or implement written procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process:    a) D2 Vinylidene Fluoride Process (VF2): The employer did not implement a management of change form for the discontinued use of the waste caustic discharge line, 20310, off of C-206, the primary monomer scrubber, on or about 2/9/16     b) D2 Vinylidene Fluoride Process (VF2): The employer did not implement a management of change form for the discontinued use of C203, the lights column, on or about 2/9/16.    c) D2 Vinylidene Fluoride Process (VF2): The employer did not implement a management of change form for the installation of HS100, the 200 Area Shut Down Switch, on the DCS, on or about 2/9/16.    d) D2 Vinylidene Fluoride Process (VF2): The employer did not implement a management of change form for the change in the testing procedure used for interlock ESS33214 for the gasholder compressor K-319, on or about 2/19/16.    e) D2 Vinylidene Fluoride Process (VF2): On or about 5/12/16 the employer did not implement a management of change form for FR-72094, the flow recorder measuring low temperature glycol flow to the header, when it was bypassed due to malfunctioning.    f) D2 Vinylidene Fluoride Process (VF2): On or about 5/14/16 the employer did not implement a management of change form  FR-20301, the flow recorder measuring low temperature glycol flow, when it was bypassed due to malfunctioning.    g) D2 Vinylidene Fluoride Process (VF2): On or about 4/22/16 the employer did not implement a management of change form FRC-20633, the flow recorder measuring well water flow to the C-205 tails tower, when it was bypassed due to malfunctioning.    h) D2 Vinylidene Fluoride Process (VF2): On or about 3/6/16 the employer did not implement a management of change form FRC-20633, the flow recorder measuring well water flow to the C-205 tails tower, when it was bypassed due to malfunctioning.    i) D2 Vinylidene Fluoride Process (VF2):  On or about 2/9/16 the employer did not implement a management of change form for an LEL detector in the discharge piping from the dryers to the atmosphere that did not accurately measure flammability, on or about 2/9/16.    NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 1, 2016

Abate by

Aug 22, 2016

Penalty

Initial $5,000 · Current $12,500

General-duty citation text

29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies had been corrected:    a) D2 Vinylidene Fluoride Process (VF2):The employer did not document an appropriate response for action number 2,551 from the 2014 compliance audit to consider how the site will make SOPs available when the network is down. The item was incorrectly marked as completed on 6/11/15 and was closed on 6/27/15, but was the system was not actually implemented until 4/5/16.    b) D2 Vinylidene Fluoride Process (VF2): The employer did not document an appropriate response and failed to take the recommended action to action number 2,541 from the 2014 compliance audit to review incidents from the 2011 process hazard analysis (PHA). The item was closed on 4/10/15, but no completed date was listed, on or about 2/9/16.    c) D2 Vinylidene Fluoride Process (VF2): The employer did not document an appropriate response and failed to take the recommended action to action number 2,544 from the 2014 compliance audit, which required the employer to review/update/locate paper files with resolution of older action items. The item was closed on 4/10/15, but no action was taken, on or about 2/9/16.     NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 1, 2016

Abate by

Aug 22, 2016

Penalty

Initial $25,000 · Current $12,500 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Written process safety information pertaining to the equipment in the process did not include piping and instrumentation diagrams (P&IDs).    a) D2 Vinylidene Fluoride Process (VF2): P&ID F-206 Sht. 1 incorrectly depicted line CMN-1"-Eb-20677 leading to TK-213, on or about 2/9/16.    b) D2 Vinylidene Fluoride Process (VF2): P&ID F-206 Sht. 1 does not depict which side of the three way valve leading to PSE20630 and PRV20630 for C-201 was car sealed closed, on or about 2/9/16.    c) D2 Vinylidene Fluoride Process (VF2): P&ID F-209 does not depict which side of the three way valve leading to PSE20947 A/B and PRV20947 A/B for V-218 was car sealed closed, on or about 2/9/16.    d) D2 Vinylidene Fluoride Process (VF2): P&ID F-209 does not depict which side of the three way valve leading to PSE20944 A/B and PRV20945 A/B for V218 A was car sealed closed, on or about 2/9/16.    e) D2 Vinylidene Fluoride Process (VF2): P&ID F-208 incorrectly depicted LAHH03 for V217A, on or about 2/9/16.    f) D2 Vinylidene Fluoride Process (VF2): P&ID F-207 Sht. 1 incorrectly depicted C-203, light column, as in service, on or about 2/9/16.    g) D2 Vinylidene Fluoride Process (VF2): P&ID F-209 incorrectly listed carbon steel for tank vent condenser E-223 A/B when it should have said stainless steel, on or about 2/9/16.     h) D2 Vinylidene Fluoride Process (VF2): P&IDF-205 Sht.1 incorrectly depicted two valves on DV-209 when there was only one, on or about 2/9/16.     i) D2 Vinylidene Fluoride Process (VF2): P&ID F-209 did not depict the drain valve on seal pot SP-221, on or about 2/9/16.    j) D2 Vinylidene Fluoride Process (VF2): P&ID F-209 incorrectly depicted the 4 inch valve for the level bridle on V-218A as CSO instead of the three inch valve from the monomer check tank pump P-216 A/B, on or about 2/9/16.     NOTE: IN ADDITION TO ABATEMENT CERTIFICATION, THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT DOCUMENTATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.     Solvay Specialty Polymers, USA LLC was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.119 (d)(3)(i)(B)which was contained in OSHA inspection number 925822, citation number 1, item number 2 and was affirmed as a final order on 2/21/2014, with respect to a workplace located at 17005 State Route 7 South Marietta, OH 45750.