OSHA Inspection: EAGLE NATRIUM LLC

Issued

Oct 28, 2020

Penalty

Initial $9,639 · Current $13,494

Hazardous substances 06401410

General-duty citation text

1910.119(f)(1) The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and which addresses the applicable elements listed in 29 CFR 1910.119(f)(1)(i) and (f)(1)(ii):      (a)    8 Chlorine Circuit:    On or about July 12, 2020, per 29 CFR 1910.119(f)(1)(i)(C), Operating procedures did not provide clear instructions as to the location to safely add plane service water to the chlorine production cells during a temporary shutdown.  High water pressure could potentially damage the diaphragm and allow hydrogen to mix with the chlorine gas resulting an explosive mixture to form.       (b)    8 Chlorine Circuit:    On or about July 12, 2020, per 29 CFR 1910.119(f)(1)(i)(C), Operating procedures did not provide clear instructions for correcting a deviation from a low brine level in a cell which can result in arcing and ignition of any chlorine/hydrogen mixtures present. Employees were correcting excessive low brine levels in the cells by hooking up a direct feed line to the cells from the brine header, bypassing the flow control rotometer, which increased the flow rate into the cell up to three times the safe upper flow rate listed in the Safe Operating Envelope Table.      (c)    8 Chlorine Circuit:    On or about July 12, 2020, per 29 CFR 1910.119(f)(1)(ii), Operating procedures did not provide clear instructions for the 8 Chlorine Circuit that discussed the level of brine in a cell during startup and normal operations which used terms such as sufficient level, unacceptably low, and safe operating level without quantifying or defining these terms to coincide with the process safety information developed.       (d)    8 Chlorine Circuit:    On or about July 12, 2020, per CFR 1910.119(f)(1)(ii), Operating procedures did not provide clear instructions for the 8 Chlorine Circuit that discussed the level of brine in a cell during startup, normal, and emergency operations which did not list a method measuring the level of anolyte in the cell that coincided with the process safety information developed.  The Safe Operating Envelope Table - 1951 listed the safe and normal operating limits for anolyte level in a cell in inches about the top of the top cathode flange however there were no means of measurement available on the cells, such as markings, that coincided with these limits.      (e)     8 Chlorine Circuit:    On or about July 12, 2020, per CFR 1910.119(f)(1)(i)(D), Operating procedures did not provide clear instructions for emergency shutdown and the conditions requiring emergency shutdown.  The level of brine in a cell, as described in  company procedures, which would require a shutdown of the circuit was less that the safe lower limit for level listed in the Safe Operating Envelope Table for the process.

Issued

Oct 28, 2020

Abate by

Nov 24, 2020

Penalty

Initial $0 · Current $0

Hazardous substances 06401410

General-duty citation text

29 CFR 1910.119(g)(1)(i): The employer did not train each employee before being involved in operating a newly assigned process in the operating procedures as specified in paragraph (f) of this section:  (a)    8 Chlorine Circuit:    On or about July 12, 2020 the employer had not trained employees on the Safe Operating Envelope Tables for the process in that employees were not made aware that the lowest safe operating level of brine in a cell is four inches above the top of the top cathode flange.  (b)    8 Chlorine Circuit:    On or about July 12, 2020 the employer had not trained employees on the Safe Operating Envelope Tables for the process in that employees were not made aware that the highest safe flow rate of brine into an operating cell is ten gallons per minute.

Issued

Oct 28, 2020

Abate by

Nov 24, 2020

Penalty

Initial $9,639 · Current $9,639

Hazardous substances 06401410

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)    No. 8 Chlorine Circuit:    On or about July 12, 2020 the employer had not established and implemented a procedure for inspecting and testing the low brine flow alarm (FT-1671) that alerts operators of a hazardous low brine flow to the chlorine production cells.

Issued

Oct 28, 2020

Abate by

Nov 24, 2020

Penalty

Initial $0 · Current $0

Hazardous substances 06401410

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not certify annually that operating procedures were current and accurate:  (a) 8 Chlorine Circuit:    On or about July 12, 2020 the employer had not certified annually that operating procedures were current and accurate in that procedure 444 Bypass or Repair Brine Line to a Cell was last reviewed and certified as accurate on July 12, 2017.