Document 4vYDwzRJ5GBnY3n2gxo6nVB6x

ABDOO109267 To: Ted Nickerson Interoffice Communication From: ' Date: Subject: Keith Bailey June 23, 1994 Process Safety Management Progress Report VIS1A The following is a summary of progress that has been made toward the compliance of OSHA 29 CFR 1910.119. EMPLOYEE PARTICIPATION:^------- To date, approximately 58 employees of the Aberdeen Plant has been directly involved in the implication of PSM. Both hourly and salary employees have worked together in the planning and execution of the Aberdeen PSM policy. PROCESS SAFETY INFORMATION: Chemical Hazards: Information pertaining to chemical hazards is available in Material Safety Data Sheets. MSDSs for each area of the plant are maintained by the safety department. , Vl , 'fit - i Process Flow Diagrams: Process flow diagrams have been completed for the VCM tank farm. CAD files have been created for most of the diagrams of the Old Module. The remaining areas of the plant have not been assigned. '.vlAc Process Chemistry: Process chemistry for the identified areas are completed except for the mechanisms of hydroquinone. R and D is currently evaluating possible mechanisms. Chemistry information is not necessary for the VCM tank farm, dryers, utilities, and SA module. Water Plant chemistry has not been completed. Maximum Intended Inventory: Safe Upper/Lower Limits: Consequences of Deviation: All of these areas are included in Operating Procedures. ABDOO109268 Material of Construction: Material of construction information are included on P&IDs. All of the equipment for the VCM Tank Farm and Old Module is completed. The majority of equipment in the remaining areas is completed. However, there is still some items that remain to be checked. Updating the equipment specifications for the New Module and SA Module is assigned to BKB. ^(pJr yjujpf l P&IDs: P&IDs are completed for all areas of the plant. A system is also in place for the maintenance of these diagrams. Electrical Classification: Write ups for existing classified areas are being finalized. Currently, information is being gathered to support the reclassification of P-1. Remaining work has been assigned to WCE and TRM. Relief Documentation: Relief Documentation is completed for the VCM Tank Farm and the Old Module. Documentation for the SA Module and New Module is assigned to BKB. The remaining areas have not been assigned. Material and Energy Balances: Material and energy balances are only required for the water plant and the new boiler. The balances have nofe^ been completed on either of these projects. 'r Safety Systems: Safety systems for the vinyl area are maintenance in the DCS. ' PROCESS HAZARD ANALYSIS: PHAs have been completed for the vinyl tank farm and the Old Module. However results have not been communicated, potential hazards have'"'"K^t been addressed, and a sighting study has no be conducted. The PHA process for the New Module, SA^ModuTe, and the catalyst freezeKS is currently being initiated. But process safety information need$ to be completed in these areas before progress can be made. The remaining areas have not been ..signed, \ ABDOO109269 OPERATING PROCEDURES: Operation procedures are completed for the Old Module and the Vinyl Tank Farm. Procedures for the Water Plant are written and awaiting approval. The writing of procedures for the New Module and SA Module will be complete by July 94. The remaining vinyl procedures ^i-s' scheduled to be completed by December '94. Typing and approval are still bottle necks in the ? TRAINING: , JDO is handling this. CONTRACTORS: < i- ll / Amount of progress is uncertain. 4,'jj. f fj' .Vj ` A V > C' /'.J '> PSSR: Procedures for Pre-start up Safety Review is currently in place for all area. MECHANICAL INTEGRITY: Amount of^progress is micertadn^ However responsibility policy is currently^awal'fiYig^Approval. HOT WORK PERMIT: Hot work permit program is in place and used throughout the plant. MOCA: Management of change procedures are currently being used with all process changes in the plant. INCIDENT INVESTIGATION: , 'A Procedures for the conduct of an incident investigation is maintained by all areas of the plant. ^ EMERGENCY PLANNING AND RESPONSE: The plant's emergency response has recently been reviewed and is up to date. AUDIT: DCS is coordinating audits on a company wide basis. ABDOO109270 PROCESS SAFETY MANAGEMENT UPDATE EMPLOYEE PARTICIPATION: VS OM NM SA DY UT BP WP X XXXXXXX NOTES: To date 58 people have been involved in the development and execution of the PSM policy. PROCESS SAFETY INFORMATION: Chemical Hazards Information (MSDS) vs OM NM SA DY UT BP WP X XXXXXXX NOTES: Copies of MSDS are maintained by the Safety department. However, there are copies in plant that are not being maintained. Process Flow Diagrams VS OM NM SA DY UT BP WP X / NS NS NS NOTES: PFDs fi]Les have been created operating parameters remain. for NS NS the 0]Ld Module. NS Only Process Chemistry VS OM NM SA DY UT BP WP NA / / NA NA NA NA NS NOTES: The process chemistry for the Old Module Is completed, except for the mechanisms of hydroquinone. Two possible mechanisms have been proposed. Maximum Intended Inventory VS X NOTES: OM NM SA DY UT BP WP X // NS NS / / This requirement is included with operation procedures. ABDOO109271 Safe Upper/Lower Limits VS X NOTES: OM NM SA DY UT BP WP X / / NS NS / / This requirement is included with operation procedures. Consequences of Deviation VS OM NM X X/ SA / DY NS UT NS BP WP // Process and Instrumentation Diagrams VS OM NM SA DY UT BP WP X XXXXXXX NOTES: Electrical Classification vs OM NM SA DY UT BP WP // / / / / // NOTES:Writes up for existing classified area are being finalized. Unsure on the progress for the SA, DY, UT, and WP areas. Relief Documentation VS X NOTES: OM NM SA DY UT BP WP X / / NS NS NS NS Relief documentation for NM and SA are currently underway. Material and Energy Balances VS . OM NM SA DY UT BP WP NA NA NA NA NA NA NS NS NOTES: Material and energy balances are only ABDOO109272 Safety Systems VS OM NM SA DY UT BP WP X NOTES: X XX PROCESS HAZARD ANALYSIS: VS OM NM SA DY UT BP WP / // / NS NS NS NS NOTES: The hazard analysis is complete for VS and OM. However, results have not been communicated, identified hazards have not been addressed, and a sighting study has not been completed. The hazard analysis for NM and SA is in the preliminary stages. OPERATION PROCEDURES: VS OM NM SA DY UT BP WP X X / / NS NS / / NOTES: Operation procedures for the NM and SA are nearly the write up stage. They all will be written by July #94. Typing and approval still remains to be accomplished. Procedures for WP are awaiting approval. TRAINING: VS OM NM SA DY UT BP WP NOTES: CONTRACTORS: VS OM NM SA DY UT BP WP NOTES: ABDOO109273 PSSR: VS OM NM SA DY UT BP WP X XXXXXXX MECHANICAL INTEGRITY: vs OM NM SA DY UT BP WP NOTES: Policies describing area responsibility has been develop and awaiting approval. HOT WORK PERMIT: VS OM NM SA DY UT BP WP X XXXXXXX NOTES: MANAGEMENT OF CHANGE (MOCA) vs OM NM SA DY UT BP WP X XXXXXXX NOTES: