Dover Chemical Corporation | Occupational Safety and Health Administration osha.gov

Violation Detail

Standard Cited: 19100119 F01 II A Process safety management of highly hazardous chemicals.

Inspection Nr: 451379.015

Citation: 01074

Citation Type: Serious

Abatement Status: Abatement Completed

Initial Penalty: $70,000.00

Current Penalty: $7,000.00

Issuance Date: 11/26/2012

Nr Instances: 78

Nr Exposed: 160

Abatement Date: 09/30/2014

Gravity: 10

Report ID: 0522500

Contest Date: 12/12/2012

Final Order: 03/10/2014

Related Event Code (REC):

Emphasis:

**Penalty and Failure to Abate Event History**
Type	Latest Event	Event Date	Penalty	Abatement Due Date	Citation Type
Penalty	F: Formal Settlement	03/13/2014	$7,000.00	09/30/2014	Serious
Penalty	C: Contested	12/19/2012	$70,000.00	02/27/2013	Willful
Penalty	Z: Issued	11/26/2012	$70,000.00	02/27/2013	Willful

Text For Citation: 01 Item/Group: 074 Hazard:

29 CFR 1910.119(f)(1)(ii)(A): The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements: Consequences of deviation: In the building #27 phosphite production plant, the employer did not have written operating procedures that clearly provide instructions associated with consequences of deviation. The following procedures were found to be without consequences of deviation: a. PHOS SOPM 101, Unloading Phosphorous Trichloride (PCl3) From ISO Containers and Tank Trucks b. PHOS SOPM 150, General Start Up c. PHOS SOPM 151, General Shut Down d. PHOS SOPM 152, Power Failure Emergency Shutdown e. PHOS SOPM 200, Unloading Railcars-Raw Materials f. PHOS SOPM 201, Unloading Trucks Raw Materials g. PHOS SOPM 204, Operation of 383 Tank h. PHOS SOPM 205, Unloading PCl3 From Railcars i. PHOS SOPM 206, Changing Filter for 44Rx and 75Rx j. PHOS SOPM 207, Replacing Dirty TCP in 508T/510T k. PHOS SOPM 208, Charging Phenol to 75Rx l. PHOS SOPM 220, Storage of Raw Materials m. PHOS SOPM 295, Charging Used (Distilled) Phenol Back to Reactors n. PHOS SOPM 297, Trouble-Shooting In Process Batches o. PHOS SOPM 298, Batch Transfer p. PHOS SOPM 299, Batch Release q. PHOS SOPM 301, 51R Doverphos DP4 Production r. PHOS SOPM 303, 44R Doverphos DP10 Production s. PHOS SOPM 304, 75R Doverphos DP4 Production t. PHOS SOPM 310, Hi-Pure Unit Operation u. PHOS SOPM 401, #23 Hot Oil System Operation v. PHOS SOPM 402, Plate and Frame Filter Operation w. PHOS SOPM 403, Acid Absorber / Jet Tank / Fume Scrubber System Operation x. PHOS SOPM 404, Charging Reactors y. PHOS SOPM 405, Carbon (Acid) Tower Operation z. PHOS SOPM 406, Carbon Tower Washout / Neutralization Procedure aa. PHOS SOPM 407, Carbon Tower Operation bb. PHOS SOPM 409, 9228 Production in 36R (PCl3 Process) cc. PHOS SOPM 410, Production of 9228 in 32R dd. PHOS SOPM 411, 12 Lb Nitrogen Pad to 35R Between Batches ee. PHOS SOPM 800, Tank Capacities ff. NPP-70, Phenol Recovery Charging 399 Tank from 135 Tank In the building #17 chlorination 1C production department, the employer did not have written operating procedures that clearly provided instructions associated with consequences of deviation. The following procedures were found to be without consequences of deviation: gg. 1C-11, Chlorine Bleed Down Procedure hh. 1C-16, 49 Reactor Operating Procedure ii. 1C-17, 8 Reactor Operating Procedure jj. 1C-18, 49 Reactor Shutdown Procedure kk. 1C-19, 63 Reactor Shutdown Procedure ll. 1C-20, Absorber Startup & Operation mm. 1C-21, 20 Reactor Operating Procedure (#32 Reactor) nn. 1C-22, 19 Reactor Operation oo. 1C-23, 58 Reactor Operation pp. 1C-24, 18 Reactor Operation qq. 1C-26, 20 Reactor Shut Down rr. 1C-27, 18 & 19 Reactor Shut Down ss. 1C-29, Emergency Shutdown Power Failure tt. 1C-31, Unloading Raw Material-Tank Trucks uu. 1C-32, Storage of Raw Material vv. 1C-45, Method for Reclaiming Chloroform/Carbon Tetrachloride Solvent (CHCl3/CCl4). ww. 1C-46, Chlorinating Fresh Batches in 20R or 49R xx. 1C-47, Feed Batch Chlorination for C24-C28 Products yy. 1C-48, By-Passing 20 Reactor Isolation Devices In the building #6 chlorination 1P production department, the employer did not have written operating procedures that clearly provided instructions associated with consequences of deviation. The following procedures were found to be without consequences of deviation: zz. 1P-002, Aeration Tower and Scrubber Operation aaa. 1P-003, Brominations bbb. 1P-02, Utility Plant Start Up and Operation ccc. 1P-025, Absorber Start Up and Operation ddd. 1P-03, General Plant Start Up and Operating Instructions eee. 1P-03A, 1 and 2 Reactor Start Up and Operating Instructions fff. 1P-03B, 1 and 2 Reactor Shutdown ggg. 1P-03C, 4 Reactor Operating Procedure hhh. 1P-03D, 5 Reactor Operating Procedure iii. 1P-03E, 40 Reactor Operating Procedure jjj. 1P-03F, 45 Reactor Operating Procedure kkk. 1P-04, General Plant Shutdown lll. 1P-05, Emergency Shutdown Procedures mmm. 1P-06, Unloading Raw Material Railcars nnn. 1P-07, Unloading Chlorine Railcars ooo. 1P-08, Bromine Unloading ppp. 1P-09, Unloading Raw Materials-Tank Truck qqq. 1P-09A, Handling Instructions for C-14 and C-18 Alpha Olefins rrr. 1P-10, Unloading Caustic Tank Trucks sss. 1P-11, Storage of Raw Materials ttt. 1P-14, Acid Loading Tank Truck and Railcar uuu. 1P-14A, Acid Loading Tank Truck (Driver Responsibility) vvv. 1P-15, Loading Tank Trucks-Bleach www. 1P-20, Chlorine Bleed Down Procedure xxx. 1P-22, Air Blow Tanks

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