Text For Citation: 02 Item/Group: 001 Hazard: CHEMICAL

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 likely to cause death or serious physical harm to employees in that employees were exposed to: 29 CFR 1910.106(h)(4)(iv)(a): Equipment was not designed and arranged to prevent the unintentional escape of liquids and vapors and to minimize the quantity escaping in the event of accidental release: a)In the ester reactor room (building 23), the catalyst charge pot (V-146) and associated controls were not sufficient to minimize uncontrolled over-pressurization of the vessel due to reaction from TPT (tetraisopropyl titanate), which is a combustible liquid (flashpoint approximately 140 degrees F), mixing with another chemical or water/steam. The process system design could not safely handle the temperatures and pressures that could potentially occur due to, but not limited to, the following: * no pressure vessel certification nor ASME certification for the catalyst charge pot (V-146) which was fabricated in-house; *no evaluation of the safe upper and lower limits such as, but not limited to, temperatures and pressures; *no relief system design and design basis; *no design codes and standards employed for the construction; and *no documentation that the catalyst charge pot (V-146) complied with recognized and generally accepted engineering practices.g