Text For Citation: 01 Item/Group: 002 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 THE RECOGNIZED HAZARDS OF FIRE EXPLOSION, MISSILES AND EXPOSURE TO TOXIC CHEMICALS. SPECIFICALLY: A) ADEQUATE PRECAUTIONS WERE NOT TAKEN TO PROTECT EMPLOYEES FROM FIRE, EXPLOSION, MISSILE AND TOXIC CHEMICAL EXPOSURE HAZARDS IN THE AMMONIA PROCESS CONTROL ROOM WHICH HAS A WINDOW ON WEST WALL WHICH MEASURES APPROXIMATELY 4' 4" BY 17' 8" AND A WINDOW ON THE EAST WALL WHICH MEASURES APPROXIMATELY 4' 4" BY 16' 4", IN THAT A FIRE, EXPLOSION, MISSILE AND/OR TOXIC CHEMICAL FROM AN EXPLOSION OF VESSELS LOCATED AS CLOSE AS 25', CALCULATED TO HAVE AN EQUIVALENT EXPLOSIVE FORCE WHICH COULD RANGE AS HIGH AS 10 TO 50 POUNDS OF TNT, WOULD DESTROY THE WINDOWS EXPOSING THE CONTROL ROOM EMPLOYEES TO SERIOUS INJURIES. GENERAL METHODS OF CONTROL INCLUDE BUT MAY NOT BE LIMITED TO THE FOLLOWING: 1) PERFORM AN ANALYIS OF CONTROL ROOM SAFETY FACTORS AND DESIGN USING 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 THE PROCESS DESIGN, TO IDENTIFY ALL OF THE WAYS IN WHICH DEVIATIONS CAN OCCUR FROM INTENDED DESIGN PARAMETERS TO CREATE HAZARDS OR OPERABILITY PROBLEMS, AND INCLUDES BUT NOT NECESSARILY BE LIMITED TO, THE FOLLOWING: A) REVIEW OF RAW MATERIAL MSDS (MATERIAL SAFETY DATA SHEETS), PRODUCTS BULLETINS TECHNICAL AND SCIENTIFIC LITERATURE CONSIDERING FIRE, EXPLOSION, HEALTH, STABILITY AND REACTIVITY CHARACTERISTICS INCLUDING HANDLING, STORAGE, EMERGENCY PROCEDURES AND SPECIAL PRECAUTIONS. B) REVIEW MATERIALS PRESENT AND TYPES OF REACTIONS OCCURRING, OPERATING PRESSURES AND TEMPERATURES, QUANTITIES OF MATERIAL PRESENT IN THE EQUIPMENT OR THAT COULD BE RELEASED, CALCULATE THE EXPLOSIVE FORCE THAT WOULD RESULT FROM VESSEL EXPLOSIONS AND COMPARE TO THE TYPE AND STRENGTH OF THE CONTROL ROOM CONSTRUCTION AND THE LOCATION OF THE CONTROL ROOM IN REFERENCE TO THE EQUIPMENT, INCLUDING RELIABILITY IN THE EVENT OF AN EXPLOSION, FIRE PROTECTION FACILITIES PROVIDED, AND PRESENCE OF IGNITION SOURCES IN PROXIMITY TO THE CONTROL ROOM. 2) BASED ON THE ANALYSIS INDICATED IN PARAGRAPH (1) ABOVE, INSTITUTE MEASURES TO REMEDIATE DEFICIENCIES IN MATERIALS OF CONSTRUCTION OF PLANT STRUCTURE AND/OR RELOCATE STRUCTURE(S) CRITICAL TO SAFE PLANT OPERATIONS TO AREAS WHICH WOULD REMAIN UNAFFECTED BY THE FORCE OF POTENTIAL EXPLOSIONS.