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Violation Detail
Standard Cited: 19100119 L05 Process safety management of highly hazardous chemicals.
Inspection Nr: 451379.015
Citation: 01051
Citation Type: Serious
Abatement Status: Abatement Completed
Initial Penalty: $0.00
Current Penalty: $7,000.00
Issuance Date: 11/26/2012
Nr Instances: 6
Nr Exposed: 160
Abatement Date: 05/12/2014
Gravity: 10
Report ID: 0522500
Contest Date: 12/12/2012
Final Order: 03/10/2014
Related Event Code (REC):
Emphasis:
| Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
|---|---|---|---|---|---|---|
| Penalty | F: Formal Settlement | 03/13/2014 | $7,000.00 | 05/12/2014 | Serious | |
| Penalty | C: Contested | 12/19/2012 | $0.00 | 02/27/2013 | Serious | |
| Penalty | Z: Issued | 11/26/2012 | $0.00 | 02/27/2013 | Serious |
Text For Citation: 01 Item/Group: 051 Hazard:
29 CFR 1910.119(l)(5): If a change covered by this paragraph results in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices shall be updated accordingly: Operating procedures were not updated as a result of management of change (MOC) processes including but not limited to: a. Changes were not made to the phosphites department operating procedures for 36 R reactor, PHOS SOPM 409, 9228 Production in 36R (PCL3 Process), following the MOC process, RFC-11-044, charge PCL3 from Main Street into 44R, 51R, and 36R. PHOS SOPM 409 still contains instructions for charging 44R reactor with the day tank and not Main Street (the PCL3 supply piping circuit for building #27 phosphites.) b. Changes were not made to the phosphites department operating procedures for 44R reactor, PHOS SOPM 303, 44R Doverphos DP10 Production, following the management of change process, RFC-11-044, charge PCL3 from Main Street into 44R, 51R, and 36R. PHOS SOPM 303 still contains instructions for charging 44R reactor with the day tank and not Main Street (the PCL3 supply piping circuit for building #27 phosphites.) c. Changes were not made to the phosphites department operating procedure, PHSO SOPM 150, General Start Up following the management of change process, RFC-11-044, Charge PCL3 from Main Street into 44R, 51R, and 36R. PHOS SOPM 150 still contains instructions for padding 224T and 261T (the former PCl3 day tanks) and no mention of main street (the PCL3 supply piping circuit for building #27 phosphites.) d. Changes were not made to the phosphites department operating procedure, PHOS SOPM 152, Power Failure Emergency Shutdown, following the management of change process, RFC-11-044, Charge PCL3 from Main Street into 44R, 51R, and 36R. PHOS SOPM 152 still contains instructions for stopping additions to 224T and 261T (the former PCl3 day tanks) and no mention of main street (the PCL3 supply piping circuit for building #27 phosphites.) e. Changes were not made to the phosphites department operating procedure, PHSO SOPM 151, Phosphite Plant General Shutdown following the management of change process, RFC-11-044, Charge PCL3 from main street into 44R, 51R, and 36R. PHOS SOPM 151 still addresses tanks 224T and 261T (the former PCl3 day tanks) and no mention of actions related to main street (the PCL3 supply piping circuit for building #27 phosphites.) f. Changes were not made, or procedures implemented, for transesterification reaction processes associated with 34R reactor following the management of change process, MOC-12-158, replace 34R off gas demister to 13 column with a spool piece. There were no normal operating procedures in place for this reactor.