OSHA Inspection: TROY CHEMICAL CORPORATION

Issued

Jan 10, 2024

Abate by

Mar 26, 2024

Penalty

Initial $10,046 · Current $5,000 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) Methanol storage tank T-203 The conservation vents with flame arrestors were missing on P&ID drawing EWR-PID-TF-METH for methanol storage tanks T-203.  b) Methanol storage tank T-206 The conservation vents with flame arrestors were missing on P&ID drawing EWR-PID-TF-METH for methanol storage tanks T-206. Violation occurred on or about 11/3/23.

Issued

Jan 10, 2024

Abate by

Mar 26, 2024

Penalty

Initial $10,046 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(H): Process safety information pertaining to the equipment in the process did not include the safety systems (e.g., interlocks, detection or suppression systems):   a) Methanol storage tank T-203 Process safety information specific to the conservation vents/flame arrestor on T-203 was not documented. A product specification sheet from the manufacturer was provided but this included several models each with their own specification. It was not specific to the conservation vent/flame arrestor in use.  b) Methanol storage tank T-206 Process safety information specific to the conservation vents/flame arrestor on T-206 was not documented. A product specification sheet from the manufacturer was provided but this included several models each with their own specification. It was not specific to the conservation vent/flame arrestor in use.  Violation occurred on or about 11/3/23.

Issued

Jan 10, 2024

Abate by

May 30, 2024

Penalty

Initial $10,046 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices:  a) Fractionator column CL-7160 The employer did not document the repair to the fractionator column CL-7160 completed in January 2011 complied with RAGAGEP including but not limited to NBIC 23 part 3 and API 510. The column received an R-Stamp but there is no further documentation related to the repair. Violation occurred on or about 11/9/23.

Issued

Jan 10, 2024

Abate by

May 30, 2024

Penalty

Initial $14,063 · Current $14,650

General-duty citation text

29 CFR  1910.119(e)(3)(v): The process hazard analysis did not address facility siting:  a) Facility The employer did not evaluate the consequences to building 71 and nearby structures including but not limited to tank farm 200, building 35, building 01, and building 101, in their process hazard analysis (PHA) to determine impact and damages from a blast wave and/or ignition flammable vapor clouds. Violation occurred on or around 7/12/2023.

Issued

Jan 10, 2024

Abate by

May 30, 2024

Penalty

Initial $10,046 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(B): The employer's written operating procedures covering safety and health considerations did not address the precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment:  a) Polyphase Part II & methanol recovery process Operating procedures did not require operators to wear FRC clothing to protect from methanol flash fires during job tasks including, but not limited to methanol unloading and checking for leaks while charging methanol to vessels/tanks. Violation occurred on or about 7/12/23.

Issued

Jan 10, 2024

Abate by

May 30, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.132(a): Protective equipment was not used when necessary whenever hazards capable of causing injury and impairment were encountered:  a) Polyphase Part II & methanol recovery process Operators were not required to wear flame resistant clothing to protect from methanol flash fires during job task including but not limited to methanol unloading and checking for leaks while charging methanol to vessels/tanks. Violation occurred on or about 7/12/23.

Issued

Jan 10, 2024

Abate by

Mar 26, 2024

Penalty

Initial $10,046 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(i): The employer, when selecting a contractor, did not obtain and evaluate information regarding the contract employer's safety performance and program:  a) Polyphase Part II & methanol recovery process The performance and safety program for contractors repairing piping for T-7119, including but not limited to R&S Contracting, was not evaluated prior to the start of their work. Violation occurred on or about 11/28/23.

Issued

Jan 10, 2024

Abate by

May 30, 2024

Penalty

Initial $14,063 · Current $14,650

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:  a) Polyphase Part II & methanol recovery process - Inspections were not conducted for process piping, including but not limited to piping segments from T-206 to E-206C, from reactor R7149 to E-7149A, from T-7119 to fractionator.  b) Polyphase Part II & methanol recovery process - Formal internal and external inspections for above ground storage tanks including T-203 & T-206, were not being conducted as per STI SP001-2011.  c) Polyphase Part II & methanol recovery process - Inspection for corrosion under insulation for vessels and tanks, including but not limited to CL-7160, R-7149, T-203, T-206, T-7152, T-7119 were not being conducted as per STI SP001 and API 510.  d) Polyphase Part II & methanol recovery process - Inspections on T-7119 mother liquor tank's safety systems such the level indicator interlock and vent condenser as well as inspections as per STI SP001-2011 have not been conducted.   e) Polyphase Part II & methanol recovery process - Sparkler filter F-7115, has not been inspection as per API 510 nor has it been receiving its weekly cleaning as required in the employer's preventative maintenance schedule.   f) Polyphase Part II & methanol recovery process - Reactor R-7149 inspections as per API 510 were not being conducted, nor inspection for safety systems on the vessel, such as but not limited to high level switch, and reactor system pump seals.  Violations occurred on or about 11/2/23.

Issued

Jan 10, 2024

Abate by

May 30, 2024

Penalty

Initial $14,063 · Current $14,650

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment to maintain its mechanical integrity, was not consistent with applicable manufacturer's recommendations and good engineering practices, or more frequently determined to be necessary by prior operating experience:  Location: Polyphase Part II & methanol recovery process a) R-7149 agitator lubrication preventative maintenance was not being completed monthly as identified in the PM Summary table.  b) F-7115 Sparkler filter weekly cleaning was not being completed weekly as identified in the PM Summary table.  c) T-7119 agitator lubrication preventative maintenance was not being completed monthly as identified in the PM Summary table.  Violations occurred on or about 11/28/23.

Issued

Jan 10, 2024

Abate by

May 30, 2024

Penalty

Initial $10,046 · Current $14,650

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that was performed on process equipment:   a) Reactor R-7149 Inspection and test documentation for Reactor R-7149 indicated the vent condenser inspection, shaft mount inspections, and agitator lubrication were completed. However, documentation did not include the results of the inspection or test.   b) Mother Liquor T-7119 Inspection and test documentation for T-7119 indicated the agitator lubrication was completed.  However, documentation did not include the results of the inspection or test.  c) Sparkler Filter F-7115 Inspection and test documentation for F-7115 indicated the rupture disk inspection and the cleaning were completed. However, documentation did not include the results of the inspection or test. Violations occurred on or about 11/28/23.

Issued

Jan 10, 2024

Abate by

May 30, 2024

Penalty

Initial $14,063 · Current $14,650

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) in a safe and timely manner when necessary means were not taken to assure safe operation:  a) Polyphase Part II & methanol recovery process Several valves upstream to the mother liquor tank T-7119 were severely corroded, including with missing valve handles, but in methanol service. Valves included VP-7370, VP-7369, VP-7367, and an unidentified 1-inch ball valve between VP-7101 and VP-7367. Violation occurred on or about 7/12/23.

Issued

Jan 10, 2024

Abate by

Mar 26, 2024

Penalty

Initial $14,063 · Current $5,241 Reduced

General-duty citation text

29 CFR 1910.119(n): The employer's emergency action plan did not include procedures for handling releases:  a) Polyphase part II and methanol recovery process area PSM11 for Emergency Evacuation Plan did not include procedures for mitigating release, including small spills of highly hazardous chemicals, including but not limited to methanol. Violation occurred on or about 11/2/23.

Issued

Jan 10, 2024

Abate by

Mar 26, 2024

Penalty

Initial $14,063 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.120(q)(6): The employer did not provide training in accordance with 29 CFR 1910.120(q)(6)(i) through (q)(6)(v) for employees who participated in or were expected to participate in emergency response:  a) Facility Employees responded to mitigate and clean up chemical spills, including but not limited to methanol, without training based on their level of response. Violation occurred on or about 11/3/23.