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

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 causing or likely to cause death or serious physical harm to employees in that employees were exposed to: a) Conditions which periodically allowed liquid levels inside process vessels (such as tank 84-61) to drop down to dangerously low levels, exposing hot bare heating coils, and presenting an opportunity for organic materials to become dried, heated, ignited and involved in serious flash fires. Among other methods, one feasible and acceptable abatement method to correct this hazard is the installation of guages or sensors which accurately and reliably monitor the level of liquid inside tank #84-61 (and other vessels which present a similar potential fire hazard) and which automatically present an audible and/or visual warning when the level of liquid inside the tank drops down to the minimum safe level (approximately 105 inches down from the top). At the same time, the accuracy, reliability and consistency of some redundant safety systems such as the non-automated manual checks of the liquid level inside the tank which boils down LC12-15 mother liquor must be improved. Actual measurements with a tape measure or calibrated probe while the agitator has been briefly turned off must be taken at least once every 3 hours, and the resultant reading must be written down on a log which is maintained and passed on to the next shift. Completely different methods of concentrating, treating or disposing of the substances present in the LC 12-15 mother liquor may, in the alternative, be implemented. for example, chemical precipitation, removal, or breakdown of certain components of the LC 12-15 mother liquor could render it fit for disposal into sewer systems. Also, vacuum systems can be used to remove excess water from mother liquors before the concentracted residue is handled as hazardous waste. Interim methods of control, which must be developed while engineering controls are being implemented, include, but are not limited to the use of a graduated pole dipped into the kettle after the agitator had been stopped find the liquid/slurry level. This procedure must be accomplished frequently enough to predict, through documentation of the readings, the time at which the level of the reduced substance will reach the minimum safe level but not less than every three hours. The procedure must be accomplished after first training the employees on the procedure and enforcing it accomplishment and documentation.