Text For Citation: 01 Item/Group: 002 Hazard: GUARDING

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 were likely to cause death or serious physical harm to employees in that the Process Hazard Analysis performed by the employer did not address the following conditions that created hydrogen sulfide exposure hazards to workers: a) The HAZOP performed in 2001 on the 2MET and TO26 processes did not address the following conditions: (1) 2-Mercapto Ethanol begins to decompose at 150 degrees Celsius, releasing highly toxic and flammable Hydrogen Sulfide gas; (2) Any 2-Mercapto Ethanol which passed through the condenser will encounter 160 degree Celsius steam lines; (3) Due to the presence of additives, any 2-Mercapto Ethanol which travels beyond the steam ejector system may polymerize and either partially or completely plug pipes through which it has the opportunity to travel, including the scrubber line and the surge tank vent line; (4) The absence of monitors in the scrubber line or in the surge tank vent line which would alert the operator in the control room to the presence of abnormal pressures or flow rates in these lines, which could be due to the presence of a blockage, such as 2-ME polymer; and (5) A common surge tank vent line which could become plugged was being used to vent both processes - to vent the 4E Ejector Vacuum System for the 2-MET Process and to vent the 4D Ejector Vacuum System for the TO-26 Process. Among other methods, one feasible and acceptable method to correct these hazards is to: (A) Install monitors into the scrubber line and into the surge tank vent line which would detect and alert the control room regarding any abnormalities in line flow rates and pressures which could be caused by an accumulating blockage in these lines; or (B) Test or inspect the Scrubber Line and the Surge Tank Vent Line for blockages on a frequent basis, and remove any accumulations of polymer which are found; (C) Install separate surge tank vent lines for the 4E System and for the 4D System; (D) Independently ventilate the drain lines for the Steam Ejector systems; (E) Install different types of vacuum systems which do not require the use of steam.e