Text For Citation: 01 Item/Group: 008 Hazard:

29 CFR 1910.119(e)(3): The process hazard analysis did not address: 29 CFR 1910.119(e)(3)(i):The hazards of the process; On or about and prior to April 8, 2021, the employer's process hazard analysis revalidation failed to address the hazards of the Resin Plant high temperature kettle process for Kettles 3, 4, 5 and 8: a. The employer failed to address atmospheric venting hazards associated with rupture disk - did not verify rupture disk vents to a safe discharge location, did not address hazards of material accumulation in relief system vent piping (e.g. blocking relief vent piping), and failed to address hazards associated with multi-relief scenarios (simultaneous) from more than one reactor vessel relieving to the Catch Tank for the Alcoholysis node WHAT-IF question "rupture disk is blown (no one notices)." Employees working on and in the vicinity of equipment containing highly hazardous chemicals are exposed employees to fire, explosion and contact hazards. b. The employer failed to address the hazards for loss of agitation, listed "Kettle will not mix material" as the hazard with the stated Consequence "None." Hazards associated with loss of agitation include rapid pressurization during agitator restart and loss of cooling water for the Alcoholysis node WHAT-IF question "The agitator fails/will not start." On April 8, 2021, the kettle 3 reactor vessel manway cover to manway flange gasket failed and released vapor into the kettle 3/kettle 4 room. This catastrophic failure resulted in the explosion event that resulted in a fatality and multiple disabling injuries. c. The employer failed to address the hazards of high reactor vessel internal pressure due to eductor/scrubber system high water level for the employer's Scrubber system and Fusion Processing nodes. Employees working on and in the vicinity of equipment containing highly hazardous chemicals are exposed employees to fire, explosion and contact hazards. d. The employer failed to address the hazards for loss of agitation for the Esterification node WHAT-IF question "The agitator fails/will not start" the employer failed to address the hazards for loss of agitation, listed "Kettle will not mix material" as the hazard with the stated Consequence "None." Hazards associated with loss of agitation include rapid pressurization during agitator restart and loss of cooling water. On April 8, 2021, the kettle 3 reactor vessel manway cover to manway flange gasket failed and released vapor into the kettle 3/kettle 4 room. This catastrophic failure resulted in the explosion event that resulted in a fatality and multiple disabling injuries. e. The employer failed to address hazards associated with water returning to the reactor vessel creating "foaming" or ("frothing") of the reactor vessel and depositing resin material and obstructing pressure relief system and downstream process piping for the Esterification node WHAT-IF question "Total condenser leaks water internally." Employees working on and in the vicinity of equipment containing highly hazardous chemicals are exposed employees to fire, explosion and contact hazards. f. The employer failed to address hazards associated with high temperature in the overhead system such as presence of vapor or liquid flow disruption, increased pressure in overhead system components for the Overhead node WHAT-IF question "A false temperature is read from vapor or liquid thermocouple to or from this system." Employees working on and in the vicinity of equipment containing highly hazardous chemicals are exposed employees to fire, explosion and contact hazards.