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

29 CFR 1910.119(e)(5): The employer did not assure that Process Hazard Analysis (PHA) recommendations were resolved in a timely manner: This violation occurred on or about October 16, 2020 and at times prior thereto in the alkoxylation unit where employees were exposed to fire and explosion hazards from ethylene oxide and other flammable chemicals without ensuring 2015 PHA recommendations were resolved in a timely manner such as but not limited to: (a) 2015 PHA recommendation #1, install blind flange on open end of all drain valves (including at least GL-500-5; GL-600-9), (BAZE-0000899); (b) 2015 PHA recommendation #2, evaluate replacing P-500 with a lower capacity pump so as to avoid potential to activate rail car internal excess flow valve, (BAZE-0000900); (c) 2015 PHA recommendation #3, Interlock BV-500 to close when P-500 is not running. (A timer will be required when BV-500 is first opened to allow P-500 to be started; e.g., 60 seconds - TBC during commissioning, (BAZE-0000901). (d) 2015 PHA recommendation #4, amend procedure to include requirement to cool down ethylene oxide tanks prior to arrival of rail car, so that tank pressure can be lowered to expected rail car pressure and vapor space will still remain in the non-decomposable zone, (BAZE-0000902); (e) 2015 PHA recommendation #5, include requirement in procedures to set ethylene oxide tank padding pressure to at least 5 psi greater than decomposable/non-decomposable limit, (BAZE-0000903); (f) 2015 PHA recommendation #6, reset low pressure alarms on ethylene oxide storage tanks to plus 5 psig above decomposable zone, and LL pressure to plus 0 psig above decomposable zone. (This will keep storage tanks with safe level of nitrogen padding, and above rupture disc set point on reactors.), (BAZE-0000904); (g) 2015 PHA recommendation #7, evaluate adding interlock to stop P-100 on high-high level in T-100 when FRV-101 open (T-101 circulating), or in T-101 when FRV-100 open (T- 100 circulating. (Protects against inadvertent transfer from one tank to the other.), (BAZE-0000905); (h) 2015 PHA recommendation #8, evaluate replacing P-100 with a magnetic drive (seal-less) pump, similar to P-500, P-600, (BAZE-0000906); (i) 2015 PHA recommendation #9, provide chart for minimum required total tank pressure vs. tank temperature in order to keep vapor space in safe region (i.e., nondecomposable). (Include chart in appropriate procedures.), (BAZE-0000907); (j) 2015 PHA recommendation #10, provide catwalk with stairway access to top of tanks to allow for safe access and operation of valves; secondary egress will also be required (stair or ladder), (BAZE-0000908); (k) 2015 PHA recommendation #11, install a minimum flow line from discharge side of P-600 back to T-102 so that P-600 minimum flow is satisfied when there is no flow through mass transmitter to reactors, (BAZE-0000909); (l) 2015 PHA recommendation #13, revise operating procedures to include step to purge / blow hoses prior to connecting to process, to remove air/water/debris, (BAZE-0000911).