OSHA Inspection: FMC CORPORATION

Issued

2013-08-19 00:00:00

Penalty

Initial $5000.00 · Current $3750.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer did not compile information pertaining to the equipment in the process that includes piping and instrumentation diagrams (P&ID's):  a) On or about 5/16/13, the employer did not ensure that the compiled written process safety information included all the necessary information pertaining to the equipment in the process in that the process safety information did not include pressure relief valve PSV5198 on piping and instrumentation diagram (P&ID) D-17866-D for the Peracetic Acid Reactor area.  b) On or about 5/16/13, the employer did not ensure that the compiled written process safety information included all the necessary information pertaining to the equipment in the process in that the process safety information did not include pressure relief valves PSV5187, PSV5197, and PSV5194 on piping and instrumentation diagram (P&ID) D-15660-D for the Peracetic Acid Process Area.   c) On or about 5/16/13, the employer did not ensure that the compiled written process safety information included all the necessary information pertaining to the equipment in the process in that the process safety information did not include pressure relief valves PSV5185, PSV5186, PSV5188, PSV5189, PSV5190, PSV5191, and PSV5192 on piping and instrumentation diagram (P&ID) D-16551-D for the 70% Hydrogen Peroxide Tank.  NO ABATEMENT CERTIFICATION REQUIRED

Issued

2013-08-19 00:00:00

Penalty

Initial $5000.00 · Current $3750.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): The employer's Process Safety Information did not include the design codes and standards employed:    a) Peracetic acid building - On or about 5/15/13, the employer's Process Safety Information did not include the design codes and standards employed for the construction of the local exhaust ventilation system for the Peracetic Acid Reactor (Tank 4100) installed in 2004 or 2005.  NO ABATEMENT CERTIFICATION REQUIRED

Issued

2013-08-19 00:00:00

Abate by

2013-09-21 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment  a) Peracetic acid building - On or about 5/15/13, the employer did not perform inspections and tests on the local exhaust ventilation system at all following the modifications made to the system after the Peracetic Acid Reactor (Tank 4100) installation in 2004 or 2005.  ABATEMENT CERTIFICATION REQUIRED

Issued

2013-08-19 00:00:00

Abate by

2013-09-21 00:00:00

Penalty

Initial $5000.00 · Current $3750.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(iii): The employer did not determine and document that equipment used in the process was designed, maintained, inspected, tested, and operating in a safe manner:  a) Peracetic Acid Building - On or about 5/16/13, the employer did not determine that the Peracetic acid reactor (tank 4100) rupture disc (PSE4100) was maintained, inspected, tested, and operating in a safe manner.  b) Peracetic Acid buidling - On or about 5/16/13, the employer did not determine that the 70% hydrogen peroxide head or weigh tank (tank 4210) rupture disc (PSE4210) was maintained, inspected, tested, and operating in a safe manner.  c)  On or about 5/16/13 - The employer did not determine that the following 70% hydrogen peroxide pressure relief valves:  PSV5198 located in the peracetic acid reactor area, PSV5187, PSV5197, AND PSV5194 located in the peracetic acid process area, and PSV5185, PSV5186, PSV5188, PSV5189, PSV5190, PSV5191, and PSV5192 located in hydrogen peroxide lines were maintained, tested, and operating in a safe manner.  ABATEMENT CERTIFICATION REQUIRED

Issued

2013-08-19 00:00:00

Abate by

2013-09-21 00:00:00

Penalty

Initial $5000.00 · Current $3750.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not complete actions to resolve PHA recommendations as soon as possible:   a) On or about 5/21/13, the 3/28/2011 70% Hydrogen Peroxide Storage System Revalidation Process Hazard Analysis recommendation 9, page 9 of 10, stated "There are numerous PRVs on the piping to protect the piping from overpressurization in the event a peroxide decomposition in confined piping.  There is no MI program requirement to inspect, test or replace these devices.  An MI program component should be considered for these devices."  The employer did not complete actions to resolve PHA recommendation 9 as soon as possible.  PSV5185, PSV5186, PSV5188, PSV5189 have not been replaced.  PSV190, PSV191, and PSV 192 were installed in 2003 and replaced in 2013.  The hydrogen peroxide pressure relief valves were still in service beyond the recommended 5 year replacement deadline.  ABATEMENT CERTIFICATION REQUIRED

Issued

2013-08-19 00:00:00

Penalty

Initial $5000.00 · Current $3750.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment:  a) Peracetic Acid building - On or about 5/15/13, The employer did not establish written procedures to maintain the on-going integrity of the local exhaust ventilation system for the Peracetic Acid Reactor (Tank 4100).  b) Peracetic Acid building - On or about 5/16/13, the rupture disc (PSE4100) on the Peracetic Acid Reactor (Tank 4100) had not been inspected or replaced since its installation in 2004 or 2005.  The employer failed to implement their written Mechanical Integrity procedure "Field Replacement of Rupture Discs" (MI-60606) which requires annual external inspections and field replacement of rupture discs every two years."  c) Peracetic Acid building - On or about 5/16/13, the rupture disc (PSE4210) on the Hydrogen Peroxide weigh or head tank (T-4210) had not been inspected or replaced since its installation in 2005.  PSE4210 was replaced in June 2013.  The employer failed to implement their written Mechanical Integrity procedure "External Visual Inspection of Relief Valves and Piping" MI-60601 which requires field replacement of pressure relief valves every five years.  d) Hydrogen Peroxide Weigh tank - On or about 5/16/13, the hydrogen peroxide pressure relief valve (PSV5198) had not been replaced since its installation in 2004 or 2005.  PSV5198 was replaced in 2013.  The employer failed to implement their written Mechanical Integrity procedure "External Visual Inspection of Relief Valves and Piping" MI-60601 which requires field replacement of pressure relief valves every five years.  e) Hydrogen Peroxide Storage tanks - On or about 5/16/13, the hydrogen peroxide pressure relief valves (PSV5185, PSV5186, PSV5188, and PSV5189) had not been replaced since their installation in 2003.  The employer failed to implement their written Mechanical Integrity procedure "External Visual Inspection of Relief Valves and Piping" MI-60601 which requires field replacement of pressure relief valves every five years.  f) Hydrogen Peroxide Storage tanks - On or about 5/16/13, the hydrogen peroxide pressure relief valves (PSV5190, PSV5191, and PSV5192) were installed in 2003 and replaced in 2013.  The employer failed to implement their written Mechanical Integrity procedure "External Visual Inspection of Relief Valves and Piping" MI-60601 which requires field replacement of pressure relief valves every five years.    ABATEMENT CERTIFICATION REQUIRED  NO ABATEMENT CERTICATION REQUIRED FOR ITEMS C, D, and F

Issued

2013-08-19 00:00:00

Abate by

2013-09-21 00:00:00

Penalty

Initial $5000.00 · Current $3750.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that had been performed on process equipment.  The documentation did not identify the date of the inpsection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.  a) Peracetic Acid building and Hydrogen Peroxide Storage Tanks - On or about 5/1/13, the employer did not document each inspection that had been performed on the following processs equipment:  1) Unloading pump (P-5030)  This pump is inspected every four weeks when it is lubricated.  2) Transfer pump (P-4205) This pump is inspected every four weeks when it is lubricated.  3) Transfer pump (P-5022) This pump is inspected every four weeks when it is lubricated.   ABATEMENT CERTIFICATION REQUIRED

Issued

2013-08-19 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(m)(2): An incident investigation was not initiated as promptly as possible, and was later than 48 hours following the incident.  a) On or about 5/15/13, a 2/24/2012 Category 3 Process Safety Incident (Event ID 22504) occurred at 12:00 AM.  A minor leak of 70% hydrogen peroxide occurred near the fast/slow addition valves.  This incident was not reported until 3/1/2012 at 12:19 PM.  It was investigated on 3/2/2012.  NO ABATEMENT CERTIFICATION REQUIRED