OSHA Inspection: TEXMARK CHEMICAL

Issued

Dec 6, 2019

Abate by

Jun 1, 2020

Penalty

Initial $9,282 · Current $5,570 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.    a) On or about 6/10/2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer did not ensure that the set pressure of PSV-1313 on the piping and instrument diagram (PI-150-002) represented the set pressure of the pressure safety PSV-1313 installed in the field.  The PSV nameplate indicates a set pressure of 280 psig, the PSV tag indicates a set pressure of 700 psig and the piping and instrument diagram indicates a set pressure of 520 psig.

Issued

Dec 6, 2019

Abate by

Jun 1, 2020

Penalty

Initial $9,282 · Current $5,570 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i): The employer did not consider the hazards of highly hazardous chemical designed to be vented to atmosphere from relief devices when it conducted the PHA    (a) On or about 6/10/2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer did not evaluate/consider in its most recent NBA Unit PHA performed in 2014 whether the atmospheric relief of PSV - 1620 relieved to a safe location. PSV - 1620 protects the Distillation column which is designed to relief Normal Butyl Alcohol(flammable liquids) and could have the potential to produce vapor clouds, fires and explosions.       (b) On or about 6/10/2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer did not evaluate/consider in its most recent DCPD Unit PHA performed in 2014 whether the atmospheric relief of PSV - 1420 relieved to a safe location. PSV - 1420 protects the Distillation column which is designed to relief Dicyclopentadiene (flammable liquid) and could have the potential to produce vapor clouds, fires and explosions.

Issued

Dec 6, 2019

Abate by

Jun 1, 2020

Penalty

Initial $9,282 · Current $5,570 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(iii): The employer did not address engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases;                                                                                        -In the Alternative-     29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.                   (a) On or about June 10, 2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer did not address the engineering and administrative controls applicable to the hazards of flammable vapors that may enter into the administrative building through ventilation systems.

Issued

Dec 6, 2019

Abate by

Jun 1, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The Process Hazard Analysis did not address human factors:    (a) On or about June 10, 2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer's NBA (1-Butanol) unit Process Hazard Analysis which was conducted on August 2014 did not address Human Factors such as but not limited to, are safe operating limits documented, providing consequences of deviation from limits and actions to take when a deviation occurs, is the number of manual adjustments during normal operations sufficient to avoid mistakes, are new employees trained in the hazards of the processes,  are automatic safety features provided when a process upset requires a rapid response, are operators overwhelmed by alarms during emergencies, do operators have a alarm mangement system that prioritizes or differentiate the most critical alarms, etc..     (b) On or about June 10, 2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer's Pilot Project Process Hazard Analysis which was conducted on March 2018, did not address Human Factors such as but not limited to, are safe operating limits documented, providing consequences of deviation from limits and actions to take when a deviation occurs, is the number of manual adjustments during normal operations sufficient to avoid mistakes, are new employees trained in the hazards of the processes,  are automatic safety features provided when a process upset requires a rapid response are operators overwhelmed by alarms during emergencies, do operators have a alarm mangement system that prioritizes or differentiate the most critical alarms, etc..

Issued

Dec 6, 2019

Abate by

Jun 1, 2020

Penalty

Initial $5,304 · Current $3,183 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) On or about June 10, 2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer did not develop and implement a written piping inspection procedure for PSM covered process piping.

Issued

Dec 6, 2019

Abate by

Nov 2, 2020

Penalty

Initial $9,282 · Current $5,570 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment    (a) On or about 6/10/2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer failed to inspect the following piping circuits:         a)  8"-NBA-P150CS-1231      b)  4"-P150CS-2232

Issued

Dec 6, 2019

Abate by

Nov 2, 2020

Penalty

Initial $7,956 · Current $4,770 Reduced

General-duty citation text

1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable Recognized and Generally Accepted good engineering practices        a) On or about June 10, 2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer failed to follow its chosen pressure vessel inspection RAGAGEP (API 510, section 6.4.  Internal and On-stream inspection) when the period between internal or on-stream inspections and thickness measurements on the distillation column C-5210 exceeded 10 years.         b) On or about June 10, 2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer failed to follow its chosen pressure vessel inspection RAGAGEP (API 510, section 6.4.  Internal and On-stream inspection) when the period between internal or on-stream inspections and thickness measurements on the distillation column C-5213 exceeded 10 years.

Issued

Dec 6, 2019

Abate by

Jun 1, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(ii): The employer did not list the operating limits in the operating procedure:    a) On or about 6/10/2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer did not define the safe upper and lower limits in the NBA (1-Butanol) standard operating procedure (Rev IV-2012) for process variables such as but not limited to the pressure for plant air, operating pressure, operating temperature for the cooling tower and operating temperature for the chillers.     (b) On or about 6/10/2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer did not define the safe upper and lower limits in the Propanol Heads SOP standard operating procedure (Rev 2-2013) for process variables such as but not limited to the pressure for plant air, operating pressure, operating temperature for the cooling tower and operating temperature for the chillers.

Issued

Dec 6, 2019

Abate by

Jun 1, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(A): The employer did not list the consequences of deviation in the operating procedure;    a) On or about 6/10/2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer did not define the consequences of deviation in the NBA (1-Butanol) standard operating procedure (Rev IV-2012) for process variables such as but not limited to operating pressure, operating temperature for the cooling tower and operating temperature for the chillers.     (b) On or about 6/10/2019, at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer did not define the consequences of deviation in the Propanol Heads SOP standard operating procedure (Rev 2-2013) for process variables such as but not limited to the operating pressure, operating temperature for the cooling tower and operating temperature for the chillers.

Issued

Dec 6, 2019

Abate by

Jun 1, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(3): The operating procedures were not reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities.    (a) On or about June 10, 2019,at the Texmark Chemical facility located at 900 Clinton Dr. Galena Park, Texas, the employer did not annually certify:         a)  The Propanol heads standard operating procedure      b)  The NBA standard operating procedure