OSHA Inspection: SUMITOMO BACKLITE NORTH AMERICA

Issued

2019-02-01 00:00:00

Abate by

2019-03-06 00:00:00

Penalty

Initial $8525.00 · Current $5967.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The process safety information did not include information pertaining to the equipment in the process such as piping and instrument diagrams (P&ID's).    a. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to ensure there was a piping and instrumentation diagram for the steam heating and cooling loop for reactor K-4002.  The company had some documented information for the system components directly adjacent to the reactor but there was no information for the steam heating and cooling loop upstream of the equipment.    b. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to ensure there was a piping and instrumentation diagram for the deluge water system for reactors K-4002, K-4001, K-4003, and K-4020.  The company had some documented information for the system components directly adjacent to the reactors but there was no information for the deluge water system upstream of the equipment.  The deluge water is considered a safety system and it is used to neutralize the reactions during upset or emergency conditions.    c. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to ensure there was an accurate piping and instrument diagram for the deluge water system.  The company had some documented information for the system components directly adjacent to the reactor but information regarding a Dwyer pressure switch monitoring the main water header was not identified on the piping and instrumentation diagram for the individual reactors. The deluge water is considered a safety system and it is used to neutralize the reactions during upset or emergency conditions.

Issued

2019-02-01 00:00:00

Abate by

2019-11-30 00:00:00

Penalty

Initial $8525.00 · Current $8525.00

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 (RAGAGEP).    a. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to document the oil change schedule for the agitator gear boxes on reactors AG-4001, AG-4002, AG-4003, and AG-4020, complied with RAGAGEP.  The employer changes the gear box oil annually instead of the manufacturers recommended change schedule of semi annually.

Issued

2019-02-01 00:00:00

Abate by

2019-05-31 00:00:00

Penalty

Initial $8525.00 · Current $0.00 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. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for pressure vessel inspections.  Procedures used by the company did not establish a set of specific actions and strategies detailing the scope, extent, methods and timing of specific inspection activities in order to determine the condition of a pressure vessel based on defined/expected damage. Actions and strategies that were not addressed in the inadequate procedure include at least; identification of the next inspection date for each inspection type; the specification of the inspection and NDE techniques to be used; and the specification of the extent and locations of inspection and NDE that was used. Pressure vessels inspected using inadequate written procedures include but are not limited to Kettle K-4001, Kettle K-4002, Kettle K-4003 and Kettle K-4020.    b. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for piping inspections.  The procedures used by the company did not establish a set of specific actions and strategies detailing the scope, extent, methods and timing of specific inspection activities in order to determine the condition of piping based on defined/expected damage. Actions and strategies that were not addressed in the inadequate procedure include at least; identification of the next inspection date for each inspection type; NDE techniques and methods to be used; and the specification of the extent and locations of inspection and NDE that was used. Piping inspected using inadequate written procedures include but are not limited to the formaldehyde piping loop.    c. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for rotating equipment inspections.  The procedure used by the company did not establish a set of specific actions and strategies detailing the scope, extent, methods and timing of specific inspection activities in order to determine the condition of rotating equipment based on defined/expected damage. Actions and strategies that were not addressed in the inadequate procedure include at least; identification of the next inspection date for each inspection type; NDE techniques and methods to be used; and the specification of the extent and locations of inspection and NDE that was used. Rotating equipment inspected using inadequate written procedures include but are not limited to the kettle agitator powertrain and kettle coolant water/steam/oil pumps for kettles AG-4001, AG-4002, AG-4003, and AG-4020.    d. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for bolted connections. Procedures need to specify many variables such as but not limited to torque values on threaded connectors, connector materials, torqueing patterns, torqueing equipment, temperature variables, and flange and seal inspections. Bolted connections include but are not limited to the formalin lines, kettle agitator equipment, and cooling water/oil/steam lines to kettles AG-4001, AG-4002, AG-4003, and AG-4020.    e. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for evaluating corrosion under insulation on process piping, piping components, and vessels. Procedures need to specify many variables such as but not limited to specific actions and strategies detailing the scope, extent, methods and timing of specific inspection activities in order to determine the condition of piping, piping components, and vessels, NDE techniques and methods to be used, and the specification of the extent and locations of inspection and NDE that was used based on defined/expected damage.  Corrosion under insulation inspection procedures would apply to piping, piping components, and vessels such as but not limited to cooling water/oil/steam lines to kettles AG-4001, AG-4002, AG-4003, and AG-4020 as well as the kettles themselves.    f. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for installing pressure relief disks on the relief vents for the process kettles. Procedures need to specify many variables such as but not limited to specific actions and strategies detailing relief system disassembly, inspection, installation, and reassembly  of the pressure relief system to kettles AG-4001, AG-4002, AG-4003, and AG-4020.    g. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for lubrication of rotating equipment. Procedures need to specify many variables such as but not limited to specific actions and strategies detailing the scope, extent, methods and timing of specific lubrication activities in order to ensure timely lubrication of process equipment, techniques and methods to be used, specification of locations of lubrication, and the proper types of lubrication to use.  Lubrication procedures would apply to rotating equipment such as but not limited to oil/steam/water cooling pumps and agitator drive components for kettles AG-4001, AG-4002, AG-4003, and AG-4020.    Abatement Note: One feasible and acceptable means of abatement would be for the employer to develop and implement an inspection plan per API Standard 510 (Pressure Vessel Inspection Code: In-service Inspection, Rating, Repair, and Alteration), API 570 (Piping Inspection Code: In-service Inspection, Rating, Repair, and Alteration of Piping Systems), API 572 Inspection Practices for Pressure Vessels, API 574 Inspection Practices for Piping System Components, API 676 (Positive Displacement Rotary Pumps), API 576 (Inspection of Pressure Relieving Devices), Center for Chemical Process Safety: Guidelines for Mechanical Integrity Systems, and equipment manufacturer's maintenance and inspection recommendations for each pressure vessel , piping circuit , and piece of rotating equipment at the facility.

Issued

2019-02-01 00:00:00

Abate by

2019-11-30 00:00:00

Penalty

Initial $11934.00 · Current $8353.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process.    a. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer did not ensure process hazard analysis addressed the hazards  of toxic exposure to employees working in the building #40 control room which could be subjected to toxic levels of formaldehyde during different release scenarios.

Issued

2019-02-01 00:00:00

Abate by

2019-11-30 00:00:00

Penalty

Initial $8525.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting.    a. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer did not ensure the process hazard analysis regarding facility siting adequately addressed the overpressure hazards posed to occupied process buildings such as but not limited to Building #40 control room.  Employees working in the control room were exposed to significant overpressure explosion and deflagration hazards from the process area and the control room was not equipped with appropriate blast resistant construction or other protective measures.

Issued

2019-02-01 00:00:00

Abate by

2019-09-30 00:00:00

Penalty

Initial $8525.00 · Current $5967.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): Inspections and tests were not performed on process equipment.    a.Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to perform piping and piping component inspections on the 2" stainless steel insulated formaldehyde circulation loop piping, 2"-C16-316LSS150, to determine the integrity and reliability of the piping system.  The piping segment receives formaldehyde from the offloading truck and transfers the substance to the storage tank and circulates it to the various reaction kettles AG-4001, AG-4002, AG-4003, and AG-4020.      b.Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to perform piping and piping component inspections on the 4" carbon steel insulated hot oil circulation loop piping, 4"-HTO-CS-300, to determine the integrity and reliability of the piping system.  The piping segment is used to add and remove heat from kettle AG-4001 by circulating oil through internal coils and the jacket of the vessel.     c. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to perform piping and piping component inspections on the 3" carbon steel insulated hot oil circulation loop piping, 3"-HTO-CS-150, to determine the integrity and reliability of the piping system.  The piping segment is used to add and remove heat from kettle AG-4020 by circulating oil through internal coils and the jacket of the vessel.     d. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to perform piping and piping component inspections on the 4" carbon steel insulated hot oil circulation loop piping, 4"CS-300-HTO-3, to determine the integrity and reliability of the piping system.  The piping segment is used to add and remove heat from kettle AG-4003 by circulating oil through internal coils and the jacket of the vessel.     e. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to perform piping and piping component inspections on the 2" steel insulated steam circulation loop piping, 2"-STM, and 4" carbon steel hot oil circulation loop piping, 4"-HTO-CS300, to determine the integrity and reliability of the piping systems.  The steam piping segment is used to add and remove heat from kettle AG-4002 by circulating oil through the jacket of the vessel and steam through the internal coils.     f.Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to ensure equipment such as but not limited to the hot oil circulation pumps for reactors AG-4001, AG-4002, AG-4003, and AG-4020 were inspected in a manner that complied with RAGAGEP.      g. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to ensure equipment such as but not limited to the water pumps providing water to the company's steam system header used for heating and cooling of reactors AG-4001, AG-4002, AG-4003, and AG-4020 were inspected in a manner that complied with RAGAGEP.

Issued

2019-02-01 00:00:00

Abate by

2019-03-06 00:00:00

Penalty

Initial $8525.00 · Current $2131.00 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.    a. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio:  On or about August 8, 2018 the employer failed to follow their management of Change (MOC) program and evaluate the safety and health effects of a leaking Dwyer series H2 dual action explosion proof pressure switch on the deluge water system for kettle AG-4003.