Text For Citation: 01 Item/Group: 001 Hazard:

29 CFR 1910.119(d):Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer did not complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process. On or about and prior to April 8, 2021, the employer did not have a completed compilation of written process safety information (PSI) (as required for hazards of the chemicals, technology of the process and equipment in the process) for managers, engineers, operators, contractors and maintenance employees involved in operating and maintaining the process to understand the hazards of the process and equipment involving or affecting highly hazardous chemicals; and for having a completed compilation for process hazard analysis. The employer had not compiled and managed PSI for covered equipment; prepared files for each piece of equipment; populated those files with process safety information (PSI) required by 1910.119(d)(1)-(3), information utilized to document RAGAGEP compliance required by 1910.119(d)(3)(ii) and other process information, such as records of equipment operating conditions and records of mechanical integrity activities used to collect process safety information; such as but not limited to: a. For the kettle 3 reactor vessel the employer failed to compile: -materials of construction for the manway gasket; -accurate safe upper and lower limits (pressure) for the technology of the process; -PSI that documented compliance with applicable RAGAGEP for the alteration of the vessel related to management of change procedure 2191; -PSI for the alteration of the vessel related to the removal of the original atmospheric jacket; -PSI for the alteration of the vessel related to the installation of internal cooling water coils/piping; -PSI for maintaining vessel integrity by following RAGAGEP during inspection and testing; -complete relief system design and design basis information, such as but not limited to, when it did not address all relief scenarios; and -accurate P&IDs for the vessel, such as but not limited to, when the manway opening was not included in the RP-KT03 P&ID. b. For the kettle 3 Total Condenser the employer failed to compile; -materials of construction for process piping associated with the installation of the new condenser; -relief system design and design basis, -design codes and standards employed for the design of relief systems; -PSI for the installation of related process piping and for pressure vessel installation; and -PSI that documented the condenser installation complied with RAGAGEP. c. For the kettle 4 reactor vessel the employer failed to compile: -the materials of construction for the manway gasket; -complete P&IDs for the vessel to include rupture disk set points; -design codes and standards employed for the design of relief systems; and -complete relief system design and design basis, such as, but not limited to, when it did not address all relief scenarios. d. For the kettle 5 reactor vessel the employer failed to compile: -the materials of construction for the manway gasket; -complete P&IDs for the vessel to include rupture disk set points; -codes and standards employed for the design of relief systems -complete relief system design and design basis, such as, but not limited to, when it did not address all relief scenarios. e. For the kettle 8 reactor vessel the employer failed to compile: -the materials of construction for the manway gasket; -complete P&IDs for the vessel to include rupture disk set points; -codes and standards employed for the design of relief systems -complete relief system design and design basis, such as, but not limited to, when it did not address all relief scenarios. f. For the catch tank CT-8 the employer failed to compile: -the materials of construction for the rupture disk; -and a relief system design and design basis. g. For the K3 Bubble Cap Column; the employer failed to compile PSI that documented the column installation complied with RAGAGEP.