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

The employer is not limited to the abatement methods suggested by OSHA; the methods explained are general and may not be effective in all cases; and the employer is responsible for selecting and carrying out an effective abatement method. 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 R.O. Pittman was exposed to the recognized hazard of fire and explosion in that: I. The employer did not utilize effective Process Controls to prevent employee exposure to the hazards of fire and explosion in that: A. The employer did not design and operate the Oxide Recovery Process with effective process controls in that: a. The employer did not operate the Number One Oxide Recovery Still (No. 1 ORS Column) with redundant temperature in- dicator/transmitters. b. The employer did not utilize an effective Calibration Program for critical instrumentation such as the temperature indicator/transmitter in the Number One Oxide Recovery Still (No. 1 ORS Column). c. The employer did not utilize an effective means of determining if con- tamination such as water, caustic and acids existed or was introduced into the Number One Oxide Recovery Still (No. 1 ORS Column). A tube leak in the Number One Oxide Recovery Still poses a major process hazard in that the potential exists to dump hot condensate from the Calandria and into the column. d) The employer did not operate the Purifying Column Tails pump with an automatic shut-off device to prevent overheating. B. The employer did not utilize a means of detecting spot heating on equipment subject to spot heating or clad all appropriate equipment with nonabsorptive insulation which was not subject to spot heating. C. The employer did not design the Number One Oxide Recovery Still Reboiler (Calandria) of stainless steel or verify that the Reboiler (Calandria) was essentially rust-free. D. The employer did not utilize a means of prevent- ing equipment such as valves from being left in the wrong position during pre and post start-up of the Number One Oxide Unit. One feasible means of abatement among others would include the following: a. Utilize effective process control systems such as stipulated by the Guidelines for Vapor Release Mitigation of the Standard for Chemical Process Safety of the American Institute of Chemical Engineers. b. Utilize redundant temperature transmitter/ indicators which are readable in the control room and use an automatic shutoff device on the Purifying Column Tails Pump or elimination of ethylene oxide from the Purifying Column tails stream. c. Utilization of linear heat detectors on equipment which is clad with insulation subjecting it to spot heating or the use of appropriate insulation material which does not absorb water or ethylene oxide (e.g., cellular glass). d. Construct the Number One Oxide Recovery Still Reboiler (Calandria) of stainless steel or maintain the Reboiler (Calandria) essentially rust-free. e. Prepare and require employees to use pre and post-startup checklists. II. The employer did not use or implement adequate methods to minimize the consequences of fire and explosion in that: A. The employer did not locate the Ethylene Oxide Tank Farm a sufficiently safe distance from the Number One Oxide Unit. Adequate spacing is critical to minimize or eliminate the potential involvement of the Tank Farm due to a fire and or explosion in a high hazard process unit. B. The employer did not assure that the Oxide Control Building was able to withstand an explosion by being explosion resistant or explosion absorptive. The Oxide Control Building is in an extremely vuner- able location in the Oxide Unit and due to its design is likely to be severly damaged in an explosive event. One feasible means of abatement among others would include the following: 1) Comply with industry recognized custom and practices for spacing high hazard process units from high hazard Tank Farms. The industry recognized custom and practice is specified in the Industrial Risk Insurers publication entitled General Recommen- dations for Spacing in Refineries, Petrochemical Plants, Gasoline Plants, Terminals, Oil Pumps, Stations, and Offshore Properties, or comply with explosion resistant or explosion absorptive design specifications for building design.