OSHA Inspection: IMTT- BAYONNE LLC

Issued

Nov 15, 2016

Abate by

May 25, 2019

Penalty

Initial $12,471 · Current $12,471

General-duty citation text

29 CFR 1910.119(c)(1): The employer did not develop a written plan of action regarding the implementation of the employee participation required by 29 CFR 1910.119:    a) Chem South Tank 12646    The employer had no written plan of action for employee participation in process safety management. Employees monitored Tank 12646, an atmospheric storage tank containing 812,925 lbs. of Tebol99 (t-Butyl-alcohol), a flammable liquid, heated to 100-110F by external steam panels.     Violation occurred on or about 5/17/2016.

Issued

Nov 15, 2016

Abate by

May 25, 2019

Penalty

Initial $12,471 · Current $12,471

General-duty citation text

29 CFR 1910.119(d)(3)(i): Process safety information pertaining to the equipment in the process did not include the elements specified in 29 CFR 1910.119(d)(3)(i)(A) through (H):    (a) Chem South, Tank 12646    The process safety information on the equipment used by employees operating the Tebol99 process, failed to include,     (A) materials of construction for pumps, valves, relief system and safety system designs;  (D) Relief systems and design basis;  (F) design codes and standards employed;  (H) safety systems    Employees monitor the nitrogen pressure and temperature of the Tebol99 process (812,925 lbs of t-Butyl Alcohol), a category 2 flammable liquid stored in a steam jacketed atmospheric storage tank.    Violation occurred on or about 5/17/2016.

Issued

Nov 15, 2016

Abate by

May 25, 2019

Penalty

Initial $12,471 · Current $0 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 Instrumentation Diagrams (P&IDs):    a) Yard 5 Tk-5057    The employer did not ensure that information pertaining to process equipment was included on P&ID F-3226 when valves 5057-I1.2 and 5057-IB.1 on the butane injection process were observed to be car sealed closed in the field and not marked as such on the P&ID.      b) Chem South Tank 12646    The employer did not ensure that information pertaining to process equipment was included on P&ID B1-80600-646 when a nitrogen pressure gauge, nitrogen regulator, conservation vent/pressure relieve valve, and temperature thermometer were installed on the tank in the field and not marked as such on the P&ID.    Violations observed on or about 5/17/2016.

Issued

Nov 15, 2016

Abate by

May 25, 2019

Penalty

Initial $12,471 · Current $12,471

General-duty citation text

29 CFR 1910.119(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910.119:    a) Tebol99 Process    The employer did not conduct an initial process hazard analysis for the covered process of heated Tebol99 (t-butyl alcohol), a flammable liquid, in an atmospheric storage tank. The storage tank is heated by panels at temperatures of 100-110F to control moisture. The quantity of flammable liquid in the process is 812,925lbs.    b) Butane Process    The butane PHA failed to consider the hazards associated with the storage of gasoline in atmospheric storage tanks in close proximity to the covered butane process.    Violation occurred on or about 5/25/2016.

Issued

Nov 15, 2016

Abate by

Nov 25, 2019

Penalty

Initial $12,471 · Current $12,471

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting.    a) Butanization Process, yard 4, 6, 9    The 2010, 2014, and 2015 PHAs did not address potential butane vapor cloud explosion (VCE) scenarios and the associated over pressure impact on an occupied metal operator shanty building located 25-50 feet from the butane railcars and lines.     b) Butanization Process, yard 9    The 2014 & 2015 PHAs did not address potential butane vapor cloud explosion (VCE) scenarios and the associated over pressure impact on a contractor trailer 300 ft away from the rail cars and lines. The trailer, occupied by a tenant, is not involved in the covered process but would be iimpacted by the VCE.    c) Butanization Process, yard 4 & 6    The 2010, 2014, and 2015 PHAs did not address potential butane vapor cloud explosion (VCE) scenarios and the associated over pressure impact on occupied permanent buildings used by contractors. The building is used by US Ecology and both yard 4 & 6 VCE overlap the building at pressures greater than 1atm.    Violation occurred on or about 5/17/2016.

Issued

Nov 15, 2016

Abate by

May 25, 2019

Penalty

Initial $12,471 · Current $12,471

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) Chem South Tank 12646    Written procedures were not developed to ensure on-going integrity of the equipment on Tank 12646 during maintenance. Tank 12646 contains approximately 812,925 lbs. of Tebol 99 (t-butyl alcohol), a flammable liquid. Equipment on the tank include but are not limited to, conservation breather vent, temperature instrumentation, and nitrogen pressure instrumentation.    b) Butanization Process    Written procedures did not require documentation of observations (e.g. physical condition, material deposits, plugging, etc.), actual pressure readings & measurements  when conducting set pressure tests & seat leak tests on pressure relief valves on the butane line.    Violation occurred on or about 5/17/2016.

Issued

Nov 15, 2016

Abate by

May 25, 2019

Penalty

Initial $12,471 · Current $12,471

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment to maintain its mechanical integrity:    a) Chem South, Tank 12646    The employer failed to conduct inspections and tests on process equipment used to monitor a heated tank containing 812,925 lbs. of Tebol99 (t-butyl alcohol), a flammable liquid.     Violation occurred on or about 5/17/2016.

Issued

Nov 15, 2016

Abate by

May 25, 2019

Penalty

Initial $12,471 · Current $12,471

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) Butanization Process    Management of change procedures were not implemented when the procedure "Work Instruction #50-010-Wi5" was changed to include how to check for butane leaks in 2015.    b) Butanization Process    Management of change procedures were not implemented when the procedure "Work Instruction #50-010-Wi5" was changed to include how to check the R/C sump and butane line bleed valve in 2015.    c) Butanization Process    Management of change procedures were not implemented when an audible/visual alarm at 25% LEL setpoint at road entrance to unloading area was implemented in 2015.    d) Butanization Process    Management of change procedures were not implemented when an alarm at 40% LEL to activate shutdown/deluge was implemented in 2015.    e) Butanization Process    Management of change procedures were not implemented when INPR-9-01 & NPRR-9-01 bypass valves were car sealed closed in 2015.    Violation occurred on or about 5/17/2016.