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

Violation Detail

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

Inspection Nr: 451379.015

Citation: 01075

Citation Type: Serious

Abatement Status: Abatement Completed

Initial Penalty: $0.00

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): R

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	$0.00	02/27/2013	Willful
Penalty	Z: Issued	11/26/2012	$0.00	02/27/2013	Willful

Text For Citation: 01 Item/Group: 075 Hazard:

29 CFR 1910.119(f)(1)(ii)(B): 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: Steps required to correct or avoid deviation: In the building #27 phosphites production plant, the employer did not have written operating procedures that clearly provided instructions associated with steps required to correct or avoid deviation. The following procedures were found to be without steps required to correct or avoid 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 SOPM152, 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 (Recycled) Phenol n. PHOS SOPM 297, Trouble Shooting In-Process Batches o. PHOS SOPM 298, Computer Batch Transfer p. PHOS SOPM 299, Computer Batch Release to Storage 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, Hot Oil System Operation v. PHOS SOPM 402, Plate and Frame Filter Operation w. PHOS SOPM 403, Acid Absorber / Jet Tank / Fume x. PHOS SOPM 404, Charging Reactor y. PHOS SOPM 405, Carbon (Acid) Tower Operation z. PHOS SOPM 406, Carbon Tower Washout Procedure aa. PHOS SOPM 407, F2C Carbon Ball Washout Procedure 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, Calculating 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 steps required to correct or avoid deviation. The following procedures were found to be without steps required to correct or avoid deviation: gg. 1C-11, Chlorine Bleed Down hh. 1C-16 49 Reactor Operation ii. 1C-17, 8 Reactor Operation jj. 1C-18, 49 Reactor Shutdown kk. 1C-19, 63 Reactor Shutdown ll. 1C-20, Absorber Startup & Operation mm. 1C-21, 20 Reactor Operation nn. 1C-22, 19 Reactor Operation oo. 1C-23, 58 Reactor Operation pp. 1C-24, 18 Reactor Operation qq. 1C-26, 20 Reactor Shutdown rr. 1C-27, 19 Reactor Shutdown ss. 1C-29, Emergency Shutdown 19 & 20 tt. 1C-31, Unloading Tank Trucks uu. 1C-32, Raw Material Storage vv. 1C-45, Method for Reclaiming CCl4 ww. 1C-46, Chlorination Procedure for 20R and 49R xx. 1C-47, Feed Batch Chlorination yy. 1C-48, By-Passing 20Rx Isolation Devices In the building #6 Chlorination 1P production department, the employer did not have written operating procedures that clearly provided instructions associated with steps required to correct or avoid deviation. The following procedures were found to be without steps required to correct or avoid deviation: zz. 1P-002, Aeration Tower and Scrubber Operation aaa. 1P-003, Bromination 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 mmm. 1P-06, Unloading Railcars nnn. 1P-07, Unloading Chlorine ooo. 1P-08, Bromine Unloading ppp. 1P-09, Unloading Tank Trucks qqq. 1P-09A, Handling of C-14 and C-18 rrr. 1P-10, Unloading Caustic sss. 1P-11, Storage of Raw Material ttt. 1P-14, Loading Tank Trucks Acid uuu. 1P-14A, Acid Loading Tank Trucks vvv. 1P-15, Loading Tank Trucks Bleach www. 1P-20, Chlorine Bleed Down xxx. 1P-22, Air Blow Tanks Operation

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