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Violation Detail

Standard Cited: 5A0001 OSH Act General Duty Paragraph

Violation Items

Nr: 107607863 Citation: 02189 Issuance: 10/31/1991 ReportingID: 0625700

Viol Type:Unclass NrInstances:5 Contest Date:
Abatement Date:12/01/1994 X Nr Exposed:5 Final Order:
Initial Penalty: $50,000.00 REC:A Emphasis:
Current Penalty: $43,475.00 Gravity:07 Haz Category:EXPLOSION

Penalty and Failure to Abate Event History
Type Event Date Penalty Abatement Type FTA Insp
Penalty Z: Issued 10/31/1991 $50,000.00 01/01/1992 Unclass  
Penalty I: Informal Settlement 10/31/1991 $43,475.00 12/01/1994 Unclass  

Text For Citation: 02 Item/Group: 189 Hazard: EXPLOSION

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 the hazard of fire and explosion: A) The employer did not protect its employees from the recognized hazard of fire and explosion in that pipes containing nitromethane and/or a nitromethane/nitroethane mixture located in pipe racks in the nitroparaffin plant were not adequately protected from exposures to heat and shock. Feasible abatement methods to correct this condition may include, but are not limited to, using barricades to protect the piping. B) The employer did not protect its employees from the recognized hazard of fire and explosion in that pipes, one-half inch or greater in diameter containing nitromethane and/or a nitroethane mixture, located in pipe racks in the nitroparaffin plant were not equipped with detonation traps. Feasible abatement methods to correct this condition may include, but are not limited to, installing detonation traps at appropriate locations in the nitromethane and nitromethane/nitroethane piping. C) The employer did not protect its employees from the recognized hazard of fire and explosion in that the propane bullet, GT-01, was unsuitable for use due to its material of construction and due to the closeness of its operating pressure to its design pressure. Feasible abatement methods to correct this condition may include, but are not limited to, replacing the propane bullet, GT-01, with a vessel having adequate ductility and an adequate margin between its operating pressure and its design limit pressure. D) The employer did not protect its employees from the recognized hazard of fire and explosion in that the relief valves for the propane bullet, GT-01, the vent gas recovery compressor, RJ-29, and the recovered propane compressor, RJ-27, were vented near ground level. Feasible abatement methods to correct this condition may include, but are not limited to, reconfiguring the relief valve piping on these items of equipment to assure that venting of flammable gases occurs at a safe location. E) The employer did not protect its employees from the recognized hazard of fire and explosion in that adequate separation distances were not provided between process units and the NP plant control room building and the front gate security building. Feasible abatement methods to correct this condition may include, but are not limited to, following the guidelines for plant layout and spacing such as those contained in Dow's Fire & Explosion Index Hazard Classification Guide (American Institute of Chemical Engineers) and Nitroparaffins and Their Hazards, (National Board of Fire Underwriters, 1959 edition). Additional feasible abatement methods to correct all of the above conditions A-E may include, but are not limited to, implementing an effective chemical process safety management program that includes such elements as a process hazard review, a job safety analysis, and a human factors analysis of the nitroparaffins plant. Effective process safety management assures prompt corrective action to eliminate hazardous conditions. A comprehensive process safety management program should at a minimum (a) systematically investigate each element of a process design and its hardware, to identify all of the ways in which deviations can occur from intended design parameters to create hazards or operability problems, (b) examine working conditions which influence the performance of human operators, maintenance staff, technicians and other personnel, and identify features of the job design likely to produce significant human error or accident event sequences, and (c) systematically list the process hazards and types of human errors likely to be encountered during normal and upset/emergency conditions, the factors creating such process hazards and potential accident sequences, and the proposed system modifications and corrective action to eliminate the hazards and/or the potential for human error.

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