OSHA Inspection: KOPPERS INC.

Issued

Nov 7, 2019

Abate by

Mar 25, 2020

Penalty

Initial $7,104 · Current $7,104

Hazardous substances 1480

General-duty citation text

29 CFR 1910.1000(b)(2): Employee(s) were exposed to an airborne concentration of hydrogen sulfide listed in Table Z-2 in excess of the ceiling concentration of 50 ppm:  a. On or about October 16, 2019, in the naphthalene tank farm on top of tank 660, an employee required to gauge the product was exposed to hydrogen sulfide at a peak concentration of 88.5 parts per million (ppm), approximately 1.77 times the OSHA peak of 50 ppm.  This limit is established to prevent employees from suffering from adverse health effects such as target organ damage to the respiratory and central nervous systems.  The exposure level was established from direct reading instrument samples collected over a period of 7 minutes.

Issued

Nov 7, 2019

Abate by

Mar 25, 2020

Penalty

Initial $0 · Current $0

Hazardous substances 1480

General-duty citation text

29 CFR 1910.1000(e): Feasible administrative or engineering controls were not determined and implemented to achieve compliance with the limits prescribed in 29 CFR 1910.1000(a) through (d):  a. On or about October 16, 2019, on top of tank 660, an employee required to gauge the product level was exposed to hydrogen sulfide at a peak concentration of 88.5 parts per million (ppm), approximately 1.77 times the OSHA peak of 50 ppm.     In the storage tank area where tank gauging is required, general methods of control applicable in these circumstances include, but are not limited to the following:   1. Following the recommended practices of the American Petroleum Institute document  API 77  - Risk-based Approach for Managing Hydrocarbon Vapor Exposure during Tank Gauging, Sampling and Maintenance of Onshore Production Facilities. 2. Implement engineering controls such remote gauging.  3. Implement remote venting for the tanks.  4. Administratively limit the number of times a worker is required to manually gauge the tanks.  Abatement:   Step 1: Effective respiratory protection shall be provided and used by the exposed employees as an interim protective measure until engineering and/or administrative controls can be implemented, or whenever such controls fail to reduce employee exposure to within permissible exposure limits.   Date by Which Abatement is Due:  Incompliance    Step 2:  Submit to the Area Director a written detailed plan of abatement outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposure to the hazardous substances referenced in this citation.  The plan shall include, at minimum, target dates for the following actions which must be consistent with abatement dates required by this citation.   (1) Evaluation of engineering/administrative control options;   (2) Selection of optimum control methods and completion of design;   (3) Procurement, installation and operation of selected control measures; and   (4) Testing and acceptance or modification/redesign of controls.   Note: All proposed measures shall be approved for each particular use by a competent industrial hygienist or other qualified person. Thirty (30) day progress reports are required during the abatement period.   Date by Which Abatement is Due (60 days):  2/14/20                                   Step 3: Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.    Date by Which Abatement is Due (90 days):      3/30/20