Document LgROLw0d8VDN5ZdeMz0qNGvx7

Process Safety Audit - November 1994 T. Michael Jones & Associates conducted an audit of our process areas covered by the OSHA Process Safety Standard during the week of November 14, 1994. Fourteen opportunities for irprovement were identified. As of 9/8/95 the status of these opportunities is: IO_f Description Status A9401 Provide a site plan which explains how the plant manages the PSM program. Graphically identify the PSM areas within the facility. Plan drafted and being reviewed for comments. Complete by 10/95 ^ EP9402 Expand SP-2 Employee Participation policy to explain why employee involvement committees exist and document actions taken to closure. Complete, - Policy revised. All involvement groups need ongoing mechanism to document actions taken on PSI related issues. PSI9403 Each identified PSM area must develop all process safety information required by section 1910.119(d) . Nearly complete - each PSM area coordinator has list of few remaining items needed. Complete fcy 11/95. yir* ----- - <0 -- j- PSI9404 Provide an index system for PSI information. Complete - will use "catalogue list of documents" FHA9405 Document that facility siting and human factors are considered when PHA's are completed. Complete for suspension and ammonia. Being addressed in dispersion. To be complete in tank farm by 11/95. PHA9406 Establish tracking system to address PHA findings. Complete - will use Manage PC software. Recommenda tions from Hazops pulled into Manage PC. Need to assign responsibility and update status OP9407 T9408 Insure consequences of deviations in operating conditions are identified in all PSM areas. Verify and document that operators have had input into the training frequency. Need for tank farm and NH3 chillers. Safe upper and lower operating limits and consequences of deviations are part of PS info. Complete fcy 11/95. /r + b ,'rt J'O /Q 5*, 4- 'v- <*--`***-> Complete C9409 Conduct and document annual job evaluations on all contractors that work in a PSM area. System revised to collect and maintain this data. Complete ky 10/95 PSSR9410 Insure pre-staipt"1 T* pmr;h lists become part of the project file. Complete NGC 12781 /*/r IQ # MI9411 M0C9412 EPR9413 TS9414 Description Testing, inspection and documentation is required on piping and components in PSM areas. Review the plant's M3C policy to assure desired results are being achieved. Update ER Plan listing of key personnel and phone numbers. Consider secrecy agreement for contractors who work in sensitive plant areas. Status Complete - tank farm and NH3 done in 1995. Need to do dispersion or suspension in 1996. Complete -- SA-36 revised and reissued. Complete Complete - agreement exists with Ogden. Consider on case by case basis for others.