Text For Citation: 01 Item/Group: 001 Hazard: EXPLOSION

SECTION 5(A)(1) OF THE OCCUPATIONAL SAFETY AND HEALTH ACT OF 1970: THE EMPLOYER DID NOT FURNISH EMPLOYMENT AND A PLACE OF EMPLOYMENT WHICH WERE FREE FROM RECOGNIZED HAZARDS THAT WERE CASUING OR LIKELY TO CAUSE DEATH OR SERIOUS PHYSICAL HARM TO EMPLOYEES IN THAT EMPLOYEES WERE EXPOSED TO THE RECOGNIZED HAZARD OF FIRE AND EXPLOSION. SPECIFICALLY: A) ADEQUATE PRECAUTIONS WERE NOT TAKEN TO PREVENT EXPLOSIONS, SUCH AS OCCURRED ON OCTOBER 15, 1990, WITHIN THE VAPOR SPACE OF THE MEA STORAGE TANK IN THE NITROGEN AREA OF THE FERTILIZER MANUFACTURING PLANT DUE TO THE PRESENCE OF HYDROGEN GAS IN EXPLOSIVE CONCENTRATIONS. FEASIBLE METHODS OF ABATEMENT INCLUDE BUT MAY NOT BE LIMITED TO THE FOLLOWING: 1) CONDUCT INTERNAL AUDITS THAT INCLUDE ITEMS SUCH AS A PROCESS HAZARD REVIEW, A JOB SAFETY ANALYSIS OR A HUMAN FACTORY ANALYSIS OF THE FERTILIZER PLANT OPRATIONS BY ADDRESSING SAFETY FACTORS IN, FOR EXAMPLE, A GENERAL HAZARD AND OPERABILITY STUDY (HAZOP), (WHAT IF), (CAUSE/CONSEQUENCE), (FAULT TREE), ETC., SUCH A REVIEW SHALL BE A STRUCTURED METHOD OF SYSTEMATICALLY INVESTIGATING EACH ELEMENT OF A PROCESS DESIGN, TO IDENTIFY ALL OF THE WAYS IN WHICH DEVIATIONS CAN OCCUR FROM INTENDED PROBLEMS, AND SHALL INCLUDE, BUT NOT NECESSARILY BE LIMITED TO, THE FOLLOWING: A) PREPARATION AND REVIEW OF PROCESS FLOW SHEETS TO DETERMINE POSSIBLE EMERGENCIES DURING START-UP, NORMAL OPERATING AND SHUTDOWN CONDITIONS AND TO EVALUATE THE CONSEQUENCES OF EXCESSIVE TEMPERATURES AND PRESSURES OR VARIATIONS IN MATERIAL CONTROLS. B) PREPARATION AND REVIEW OF A PIPING AND INSTRUMENTATION DIAGRAM (P&ID) TO ASSURE THAT CONTROLS AND INSTRUMENTATION WILL DETECT UNUSUAL CONDITIONS AND THAT THE SYSTEM WILL AUTOMATICALLY SHUT DOWN IN THE EVENT OF OPERATOR EQUIPMENT ERROR. C) REVIEW OF RAW MATERIAL MSDS (MATERIAL SAFETY DATA SHEETS), PRODUCT BULLETINS, TECHNICAL AND SCIENTIFIC LITERATURE CONSIDERING FIRE, EXPLOSION, HEALTH, STABILITY AND REACTIVITY CHARACTERISTICS INCLUDING HANDLING, STORAGE, EMERGENCY PROCEDURES AND SPECIAL PRECAUTIONS. D) REVIEW OF OPERATING DESIGN AND POTENTIAL FOR OPERATIONAL ERRORS CONSIDERING DETAILED OPERATING DESCRIPTIONS AND STANDARD OPERATING PROCEDURES; ACCURACY AND READIBILITY OF CONTROL INSTRUMENTATION AND OPERATOR TRAINING IN PROCESS CHEMISTRY, HAZARDS AND OPERATIONAL PROCEDURES. 2) EMPLOY A FEASIBLE AND USEFUL METHOD SUCH AS REDESIGNING THE PROCESS SYSTEMS TO PROVIDE FOR STORAGE TANKS WITH CONTINUOUS PURGE AND/OR VENTING SO THAT HYDROGEN GAS CONCENTRATIONS CANNOT RISE TO THE LOWER FLAMMABLE LIMIT. 3) EMPLOY FEASIBLE AND USEFUL METHODS SUCH AS REDESIGN OF LIQUID TRANSFERINTO TANKS WHICH WILL ELIMINATE IGNITION SOURCES SUCH AS STATIC ELECTRICITY GENERATED BY ALLOWING LIQUIDS TO FALL FREELY THROUGH THE VAPOR SPACE OF THE TANK.