Document 1gLbDj73JpGXV69Jx8avxxdkZ

UCC 047989 TEXAS cm PLANT SO. 0[riCIEHCY AUbTf REFERENCE POINT ACTION REQUIRED RESPONSIBILITY CftftlTIGN DATE 3 The following procedures nee I.B.5. An Asbestos Handling Procedure and Hand-Held Abrasive Maintenance Shops to be issued and implemented Blasting Procedure that Incorporate the practices used and Department Head - Hand tieio Abrasive Blastin' required are being developed for Inclusion into the - A;T.Ciiij* P.enoval Procedure Maintenance/Materials Procedures Manual. 2nd qtr 63 E^br/u Fetal Protection 1.6.5. Plant procedure has been revised and forwarded to . Policy needs updating, (repei 0 managers for final approval. I.H. Director Feb. `83 Sbise.'."-;4ring Conservation -rocec.reiTdo not mention re ronitoring within 60 da/s of a process change. I.B.5. Revised plant procedure on Noise and Hearing Conservation is being developed for Introduction to Plant Procedures CoTMittee In first quarter 1983. I.H. Director 2nd qtr 83 Tney also do not require notification of employees within 21 days if daily expo sure is above 65 dBA. Chemical data sheets In II.C. (1) Purchasing is In process obtaining USDS's on materials Unit' Department Head 4th qtr*83 several units were either current in plant. (2) Review of unit chemical data sheets not up to date or were misstr 1 wilt be included In 1983 Unit Safety Hazard Review which in several unit manuals. covers entire plant. p ( Driger sampling tubes are 1I1.D.2 A new video tape training program on the selection and use I.H. Director being improperly used to mea (d)(6) of toxic gas/vapor measuring instruments will be released' sure TLVs In barges and tank ;rs in February 1983. prior, tc [*./;:cal entry by product handlers. .! ; Feb.'83 s swid Nomv 2861 > e e 047990 t. PERSONAL HEALTH (cent.) p. 2 JO. DEFICIENCY TEXAS CITY PLANT 1982 PERSONNEL SAFETY & HEALTH AUDIT ACTION FLAN /> K- 5 JZ%7} **INSS CONFIDEhfllAL tea: t REFERENCE POINT ACTION REQUIRED RESPONSIBILITY GCHFlCTIOH DATE . '..'aiding was performed without IV.O. (1) Sour* ventilation in open area is only required when Maintenance Shops source exhaust ventilation, neiding other than wild steel. Available ventilation is Department Head .elder's helper was not :urrently being upgraded in pipe and structural shop. (2) wearing a proper hood and larrler curtains will be evaluated 1st qtr 83. Uelders carrier curtains were not use 1. and helpers are Issued and required to use proper protective equipment including welding hoods. Incident observed was in Isolated occurrence. 7. Contractors do not always III.E.3 The Maintenance procedure on asbestos handlinq will be com Maintenance Shops Tallow UC?safety A health (2) pleted 2nd qtr and a copy of the procedure and the training Department Head procedures on Asbestos. proaram will be provided to Maintenance Contract Services Division for Implementation, C< Contractors do not always III.E.3 A nrogran is already In place. follow UCC safety 1 health (3) procedures: Medical surveil lance is questionable. Maintenance Shops Department Head "any cases of hygersensitivlt IV.A.l to amines were not reoorted and logged per UCC guidelines Dne hypersensitivity case for *82 has been reported. Hedlcal Director 10. Those De~t. Head HOP'S and 1V.E. 1 proposal will be developed for plant management's HSIEA Manager quarterly reports reviewed consideration and subsequent implementation thru the line did not Include health;Items. * irganlzation. "i - .` . ' t . i ;----- ' 3rd qtr 63 2nd qtr 83 Complete Complete 1st qtr 83 i 1" \ * if r PERSONNEL SAFETY ",--------------1-------------- n-J--------------------- l. NO. `5 A: 1 DEFICIENCY JSBdIT REFERENCE POINT 1 The nu-cer of vari I.A, Page 1 ances to Plant Safety Prsced-res aopears to &e excessive. The related procedures need to ie reviewed with in oajecttw to res-jee the exceptions. 2 Sr? Lepart.-ental Safety Kama Is con tain outdated Plant Safety Procedures. (Repeat) I.B.1, Page 1 3 A Plan* Evacuation Procedure could not he located. (Repeat) I.B.2, Page 1 TEXAS CIUTYT PLANT . PERSONNEL SAFETY A HEALTH AUDIT ACTION PLAN ACTION REQUIRED RESPONSIBILITY COMPLETION CATE The Texas City Plant stresses getting exceptions when deviating from Plant Procedures. The Plant Procedures review fora was revised to cover review of exceptions for possible inclusion. Exception review form was revised to orovide specific paragraph for which exception is required. Review has been tightened and requests returned for clarification where required. Safety Director Plant Procedures should net be in unit safety manuals. This was affirmed in the November Plant Procedures Cosirr.ittee meeting. Plant Pro cedures are to only be kept in Plant Procedures Manuals. A letter was sent to the Department Heads pointing this out. The plant "Unit Safety and Health Review* program will Include this as an inspection item. Safety Director This procedure was In existence and Issued at the time of the audit. The primary problem is that the procedure is contained in the Emergency Infor- ation Manual, which has an extremely limited distribution due to confidential material. A special effort will be made in 1983 to publicize the existence of this procedure. ' Safety Director IHial 12/32 Continuing Iritlal 12/S2 Continuing 3 Q *82 047991 >. t 047992 ,- * '*: ' '.V* PER SOr-'iEL 'SAFETY r.o. DEFICIENCY MIY REFERENCE POINT The following proce dures need to be issued end Implemented 4 --Cranes Near Power Lines (Repeat) I.B.5. Page 2 S --Scaffolds I.B.S, Page 2 s -Off-Site Transpor I.B.S, Page 2 tation of Personnel 7 --Work from Elevated I.B.S. Page 2 Surfaces ACTION REQUIRED responsibility COMPLETION CATE 4 This procedure has received APM endorsement and will be sent to the Plant Manager for final approval. A variance to SH-112 has been written and it being routed for approval. A training program is being developed for this procedure by the Maintenance Department. Safety Director A Maintenance 1 Materials Management Procedure is being developed for this subject. Shop Maintenance Department Head This procedure has been approved by the Plant Procedures Committee and will be sent to the APH's for endorsement In the first quarter. Safety Dtrector The first draft of this procedure was introduced In the January Plant Procedures Coomittee meeting. This procedure will be the most difficult one in the audit to implement. Even the Safety and Fire Protection Department is uncertain if 1t>can meet the letter of the UCC procedure. Safety Director 1st Qtr '83 2nd qtr '83 2nd Qtr <83 1st Qtr '84 j t 047993 * PE-.SCCTEL safety TEXAS CITY PLANT 1982 PERSONNEL SAFETY 1 HEALTH AUDIT ACTION PLAN BUSINESS Icarbide] COfWDENTlAL K3. DEFICIENCY JEOIT REFERENCE PD 1 Ilf 8 The Plant Vaoor Cloud I.B.S, Page 2 Procedure does not cover oxygen enriched clouds (SH-105). 9 Tne MsstecTag I.B.5, Page 2 Procedure is not com pletely deer on whst/wnen craft personnel locks ere required. 13 The six-month follow I.B.S,'Page 2 up' cn LEL and 0? raster RM scheduling Is Ineffective. Accounted 11 ties for folIcwtuo should be clarlfled/asslgned. ACTION REQUIRED RESPONSIBILITY COMPLETION DATE This topic had not even been considered Id development of our current procedure. It will be Incorporated as part of the 1983 update. An Interim article will be provided in the Super visors' Safety Newsletter to notify the plant population. The Plant Procedures subcorrnlttee currently working on this procedure has been notified of the deficiency. This correction will be Incor porated In the revised procedure. Plant Procedures Coanlttee Shift Dept. Head 4th Q *63 Plant Procedures Committee Production Dept. Head 3rd Q *83 Department Heads have been notified of this Item. Approximately 6SS of the deficiencies have been corrected. The Personnel Safety Clerk is responsible for follow-up. Operators will be reminded of this requirement In their annual mandatory safety training. Safety Director \ 3rd Q *83 e oC * UCC 04 7994 I i*. l" - PERSONNEL SAFETY f' TEXAS CITT PLANT ^ 1982 PERSONNEL SAFETY t HEALTH AUDIT ACTION PLAN | BUSINESS fTM!y CONFIDENTIAL 1 DEFICIENCY 9 mn REFERENCE POINT n :z ) i i i t 13 i i: 14 l_ 1 1 1 1 r. !i';r-ersu* eyo baths throu;'.out i^a plant are not in accordance with the Safety and Health Technology Standjrds. II.A., Page 3 I:-;.- C*i;art^ntil Accii:'.i Prevention Cc-ritt;es (DAPC's) are inactive and sc- i^jrtrents don't have ccnittees. II.A., Page 3 Excessive variances. III.A.l, Page 4 Many of the defici encies Identified In the l-w'T audit have not been corrected. I1I.A.1, Page 4 ACTION REQUIRED RESPONSIBILITY COMPLETION DATE No wholesale replacement Is planned at this time. Increased emphasis will be placed on beeping drains open. In lieu of any major repairs to the existing eye baths, they will be replaced with UCC aporoved units. A survey will be conducted to determine the number of these units. Safety Director Continuing Increased erphasii will 6e given to the DAPC's in 1933. The Managers* group will make a pre-. sentation to the department heads indicating the thrust in this program in 1983. Managers Department 4th C *S3 See Item No. 1. These items are highlighted in the responses to this audit. Special emphasis Is being given to assure these are corrected in a timely manner. t' 1 Safety 01rector -- Continuing , ... . T . . , ucc 047995 PEFSQMi^, Urctf hit wit 1982 PERSOWtEL SAFETY 1 HEALTH AUDIT ACTIW PUW *:***no. f DEFICIENCY *------------ JEDBTT REFERENCE POINT ACTION REQUIRED RESPONSIBILITY COMPLETION DATE IS 16 17 V The safety Trilair.a Record! Program fjjf* Is not editable a,a to information being incomplete. As the projran will be the official record, care rust ti ti^en lj iiscre all training is properly entered. (Repeat) Field Katntenance Engineers have mini mal Involvement In Safety Training. Contractors do not always follow UCC safety and health procedures 1. Scaffolds and Ladders [JI.D.l.(t>), PageS The audit showed that' the record system is accurate. The major problem is a lack of faith in the system by first line supervisors. An attempt will be made to allow Maintenance and Operations to input directly to allow problems to be corrected immediately in the field rather than awaiting feedback. Safety Direu^*- 4 th Q '83 III.0.2.d.(2), Page 8 III.0.(3).1. The Maintenance Department has listed this as one of their safety action items. The FME's will .receive the mandatory safety training plus the annual hazards review for the production units for which they are responsible. Tech Services Maint. Dept. Head 4th Q '83 Then does not appear to be a major problem at the present time with the maintenance contractors. However, the new UCC scaffold procedure will be provided to these contractors. This group will he regularly monitored by the Contract Maintenance Services Division for compliance. i Maint. Shop Dept. Head 2nd Q '83 Continuing * f. i > PERSW-L SAFETY r ------------------- y*-*J~-* f M). DEFICIENCY AUDIT . "MP TFXAS CITY PLANT 1902 PERSONNEL SAFETY & HEALTH AUDIT ACTION PLAN ft r. ACTION REQUIRED business CAflBlOeJ1 CONFIDENTIAL tO O) oS \ RESPONSIBILITY COMPLETION DATE 18 Many ns?.-standard scaffolds were In use throughout the plant. IS Hazards Uork Pe-rtt* au used on non-hazardous jobs which r.i/ dilute the effectiveness of the program. 23 Repeat audit Itees from 1980 audit. IV.D. Page 10 IV.0.. Page 10 f i IV.F.2." These scaffolds were checked and found to belong to the site construction contractor (Bechtel). A copy of the UCC scaffold procedure will be provided to the contractor. The Texas City Plant uses a "Work Authorization Fora" for nest non*hazardous work. This will be Ve-orphasized. Ue will lightly emphasize not using the HHP for non-hazardous work. If we . exist err, we prefer it to be in this direction. UCC Construction Site Manager Safety Director See Iten 14. 1th Q *83 2nd Q *83 , 1