Document MnZrxXxeedJNYvdoEJ8LEqBM

A B D 0 0 1 15148 ABERDEEN PSM AUDIT WORKSHEETS FOR FIELD VERIFICATION COMPLIANCE AUDIT GUIDELINES SECTION 4.3 PROCESS SAFETY INFORMATION 29 CFR 1910.119(d) 7. Are updated P&IDs available? a) Are official hard-copies or reliable electronic copies of P&IDs readily available for employees? Spot Check Items Yes No Comments X b) Field check one P&ID from each covered process area by walking the P&ID with the help of a process engineer and an electrical / instrumentation engineer. When a major error or several minor errors are found on the P&ID, the check of that drawing will be considered to be complete and that drawing will be assumed to be inaccurate. Spot Check Items Yes No Comments OM-0914-PID-D RX-500 X 5 minor and one major error found NM-090112-PID-D Recovered VCM Condenser X 5 minor errors. EX-101 shown on dwg. but was not found in the field (major error). OM-090109-PID-D Recovery Compressors & Vacuum Pumps X 5 minor errors VS-090101-PID-D VCM Tank Car Unloading X VS-090104-PID-D VCM Yard Equipment X 2 minor & 1 major error found April 18, 1995 58 )V ABERDEEN PSM AUDIT Audit item v) Corrosivity data; COMPLIA NCE AUDIT GUIDELINES SECTION 4.3 PROCESS SA FETY INFORMATION 29 CFR 1910.119(d) Yes No Comments X Technical references." Initial s DCS vi) Thermal and chemical stability data; and X Technical references. DCS vii) Hazardous effects of inadvertent mixing of different materials that could foreseeably occur. 4. Are updated process flow diagrams or block flow diagrams available? 5. Does the plant have documents that describe: a) Covered process; bl process chemistry: cl maximum intended inventories: and d) troubleshooting information. 6a. Does the plant have a compilation of safe upper and lower limits for process parameters? X X X X X No mixing matrix was found for any of the covered chemicals. DCS X Draft PFD's exist for all units. These were not readily DCS available to employees.. X This information was not found. DCS DCS DCS DCS DCS A B D 0 0 1 15157 April 17, 1995 19 ABERDEEN PSM AUDIT Audit item COMPUA NCE AU DIT GUIDELINES SECTION 4.3 PROCESS SA FETYIN FORMATION 29 CFR 1910.119(d) Yes No Comments 6b. Does the compilation of safe upper and lower limits include a description of the consequences of deviation? 7. Are updated P&IDs available (also refer to field verification)? 8a. Does the plant have electrical classification for different areas? 8b. Does the electrical classification follow NFPA standard or comparable industry standard? 8c. Is the electrical classification indicated on a plot plan? 9a. Is there technical basis for all relief valves (including design information and design basis that follow consensus industry standards and/or considerations made related to fire rating, downstream pressure, reactivity and flow capacity)? 9b. Are proper materials of construction used for relief valves? X X X X X X Six P&ID's were checked. Four were considered not accurate or up to date. This was well laid out and identified. - X Not all relief valves were done(interview comment.) Fourteen relief valves were spot checked. Two were not found (EX-101) For D-500 (PVC Reactor), the calculations were not found, though they are likely to be on file somewhere in the plant. This appears to be the case for the relief valves that were spot checked. Initial $ DCS DCS & CJL CJL CJL CJL DCS DCS A B D 0 0 1 15158 April 17, 1995 l). K. 20 ABERDEEN PSM AUDIT Audit item COMPLIANCE AUDIT GUIDELINES SECTION 4.3 PROCESS SAFETY INFORMATION 29 CFR 1910.119(d) Yes No Comments 9c. Are relief valves properly designed and installed (this audit item will be verified in field)? 9d. Is there technical basis for design of relief headers? 9e. Are flow calculations available for relief headers! X X 10. Is there technical basis for the design of the ventilation system for all control buildings and process buildings and enclosures (such as design information and design basis that follow consensus industry standards)7 11. Are material and energy balance calculations available for all covered processes built after 5/26/92? 12. Are descriptions of safety systems available for na X Several RVs were considered improperly installed due to lengthy inlet lines, inlet line smaller than the inlet nozzle, and an unlocked block valve upstream of the RV inlet. Refer to the field checks for RV identification. Two were spot checked and the technical basis was not found.. Two were spot checked. The flow calculations were available. X Four buildings were checked( sub102, sub 7, sub 4, and the new control room.) No technical basis was found for any building. Initial s DCS DCS DCS DCS DCS A B D 0 0 1 15159 April 17, 1995 D.R - 21 A B D 0 0 1 15160 ABERDEEN PSM AUDIT Audit item COMPLIA NCE AUDIT GUIDELINES SECTION 4.3 PROCESS SA FETY INFORMATION 29 CFR 1910.119(d) Yes No Comments a) Fire and gas detection (monitor locations, upper and lower monitor detection limits, detectable gases, etc.); b) Active fire systems (fire water systems, deluge systems, dry chemical, and mobile or hand-held extinguisher, etc.); c) Passive fire systems (fire walls, dikes, fire protection insulation etc.); d) interlocks for process safety systems (description of interlock system, listing of failure modes, logic diagram and/or loop diagram); and e) Alarms (pressure, temperature, level and flow control systems and alarms)? Safety systems at a specific site vary. Other safety systems may include: Scrubbers; Emergency generators or UPS\ Flares; and X X X na X na X No technical description of the fire water system was found, though there is likely one in the plant files. X No technical basis was found for the VCM sphere containment dike. Initial s DCS DCS DCS DCS DCS DCS DCS DCS April 17, 1995 22 > / ABERDEEN PSM AUDIT Others: Audit item COMPLIANCE AU DIT GUIDELINES SECTION 4.3 PROCESS SAFETY IN FORMATION 29 CFR 1910.119(d) Yes No Comments None were noted. Initial s DCS 13a. Are equipment sheets and/or design files available for all equipment: i) U-1 sheets or equivalent forpressure vessels; X The equipment files were not complete. CJL ii) Specification data sheets for storage tanks; iii) Pump specification sheets; X Only a few specification sheets were found for tanks. X The files were not complete. Spec sheets were missing. CJL CJL iv) Compressor specification sheets; X CJL v) Piping specification sheets (line specification referenced on P&ID); vi) Relief valve data sheets (with sizing calculations); X This item was complete on P&ID's, but it was not done on inspection ISO's and in the line drawing data base. CJL X Of the fourteen spot checked, two were missing and four had incomplete calculations. DCS vii) Ventilation systems calculation sheets; X None were found, including the set for the new control CJL room. viii) Emergency shutdown systems; X The difference between "quality critical" and "safety CJL critical" systems needs to be noted in the files. A B D 0 0 1 15161 April 17, 1995 D.R- 23 ABERDEEN PSM AUDIT Audit item COMPLIA NCE AU DIT GUIDELINES SECTION 4.3 PROCESS SA FETYIN FORMATION 29 CFR 1910.119(d) Yes No Comments ix) Control and/or monitoring systems specifications (Instrument data sheets); and x) Other appropriate equipment types? 13b. Do the equipment sheets or design files of equipment include appropriate references to codes and standards used? 14. Is there documentation that covered equipment complies with generally accepted good engineering practices? X na X 15. For existing equipment designed under codes and standards no longer in use, is there documentation of tests, inspections, operating history, engineering analyses, etc. that show that the equipment is fit for duty? X Same comment as above. X Most PVs, some tanks, some pumps, and all piping make this reference. This information is missing for some tanks. The inspection frequency on instrument inspection frequencies may not match the manufacturer's recommendations. This information is missing for some tanks. Initial s CJL CJL CJL CJL A B D 0 0 1 15162 April 17, 1995 24 ABERDEEN PSM AUDIT WORKSHEETS FOR FIELD VERIFICATION (continued) COMPLIANCE AUDIT GUIDELINES SECTION 4.3 PROCESS SAFETY INFORMATION 29 CFR 1910.119(d) 8d. Do all equipment meet established electrical.c assifica ion? Spot Check Items Yes No Comments X 9c. Are relief valves properly designed and installed? Spot Check Items Yes No PSV-EX337, EX-338, FI008, & FL009 X Comments The length of the inlet piping to these relief appear to exceed recommended guidelines. PSV-FL008, & FL009 X The inlet piping to these relief valves appears to be smaller than the inlet flange on the relief valve,. PSV-EX338 X The block under this relief valve was not locked in the open position. A B D 0 0 1 15149 April 18, 1995 59 ABERDEEN PSM AUDIT WORKSHEETS FOR FIELD VERIFICATION (continued) 16.^ Spot Check Items VCM Storage Sphere_____________ COMPLIANCE AUDIT GUIDELINES SECTION 4.3 PROCESS SAFETY INFORMATION 29 CFR 1910.119(d) Yes No Comments Unable to determine as their was no technical basis or calculations for this dike. A B D 0 0 1 15150 April 18, 1995 60 w O- ABERDEEN PSM AUDIT WORKSHEETS FOR GROUP A INTERVIEW (Continued) A B D 0 0 1 15151 COMPLIANCE AUDIT GUIDELINES SECTION 4.3 PROCESS SAFETY INFORMATION 29 CFR 1910.119(d) 18. Do employees indicate that they have access to the required process safety information? MSDS sheets and other chemical information? Equipment design information? P&ID's? Employee Name (Optional) Yes No Comments X MSDS's X P&ID's X Vendor manuals X In general, the group felt they had access to this information but did not know they had access to all PSM information. Mechanic He commented that the MSDS system was not adequate and they were hard to find. 19. Do emDiovees indicate that all process safetv information is keDt current and communicated to all who need to know? How are changes communicated? Employee Name (Optional) Yes No Comments All X The group was unanimous is saying this was not done. The consensus was that this information is not kept current. ft PnPkoirfj April 18, 1995 Hull 65 ABERDEEN PSM AUDIT WORKSHEETS FOR GROUP B INTERVIEW COMPLIANCE AUDIT GUIDELINES SECTION 4.3 PROCESS SAFETY INFORMATION 29 CFR 1910.119(d) 4. Are updated process flow diagrams or block flow diagrams available? Employee Name (Optional) Yes No Comments Consensus X These are being developed, but are not available. 5. Does the plant have updated manuals that describe the covered process. Drocess chemistrv. maximum intended inventories, and troubleshooting information? Is the technical basis for design of equi pment available? Chemistry X This is available but not considered accurate or up to date. Max Inventories X Troubleshooting X Tech basis The interviewees felt some was available but not for all equipment. A B D 0 0 1 15152 April 18 1995 Ru^ pri 11 71 ABERDEEN PSM AUDIT A B D 0 0 1 15153 COMPLIANCE AUDIT GUIDELINES SECTION 4.3 PROCESS SAFETY INFORMATION 29 CFR 1910.119(d) Suggested Questions Yes No Comments for Implementation Status 1. Are process safety information complete and up-to-date (before conducting process hazard analyses)? X Not all required information was complete at the start of the PHA. 2. Are all employees provided reasonable access to all process safety information? X 3a. Is there chemical information for all covered chemicals (such as material safety data sheets and hazardous effects of inadvertent mixing of different chemicals)? X MSDS are available. Other information is available in the operating procedures and in technical data books. There is no mixing matrix; however, the plant does not believe one is needed. Is there information pertaining to the technology of the process: 4. Updated process flow diagrams or block flow diagrams? X PFDs are in the process of being made. 5 nrocess descriotion. Drocess chemistrv. maximum intended inventories, and troubleshootina information? This information is in operating procedures and employees offices. It may not be complete. 6. Safe upper and lower limits for process parameters and consequences of deviation (how were these information obtained)? X X In the operating procedures. Is there information pertaining to the equipment in the process: Initials DCS DCS DCS DCS DCS DCS April 18, 1995 j>$^ 5Wi^ TeaST\ QmM ISA StU ' "&0 3"A> 87 ABERDEEN PSM AUDIT COMPLIANC E AUDIT GUIDELINES SECTION 4.3 PROCESS SAFE*fY INFORMATION 29 CFR 1910.119(d) Suggested Questions Yes No Comments for Implementation Status 7. Updated P&IDs (how often are P&IDs being updated)? X P&IDs are redlined as needed and redrawn every 2-3 months. 8. Electrical classification for different areas (does it follow NFPA standard or comparable industry standard and is it indicated on a plot plan)? X This is shown on a plot plan and was reviewed by Randy Denton. 9. Design and technical basis for relief valves and/or relief headers? X These are kept in the "PSM" office. Not all are done, for example the New Module. 10. Technical basis for design of ventilation system (for all control buildings and process buildings and enclosures)? X 11. Material and energy balances for all covered processes built after 5/26/92? na 12. Description of safety systems (such as scrubbers, dikes, firewater systems, emergency generators or UPS, control systems and flares, etc.)? X Most of these are in the operating procedures and fire systems information is dept in the safety department. 13a. Equipment sheets and/or design files for all equipment? These are in the "PSM" office and Mechanical records. Not all are available. 13b. Do the equipment sheets or design files of equipment include appropriate references to codes and standards used? Some do, but some may be missing. Initials CJL CJL DCS DCS DCS DCS CJL CJL April 18, 1995 ps/'i s y- 88 ABERDEEN PSM AUDIT COMPLIANCE AUDIT GUIDELINES SECTION 4.3 p ROCESS SAFETY INFORMATION 29 CFR 1910.119(d) Suggested Questions Yes No Comments for Implementation Status 14. Is there documentation that covered equipment complies with generally accepted good engineering practices? X X Check in the equipment files and in Don Whattley's office. (Whattley is the resident inspector) 15. For existing equipment designed under codes and standards no longer in use, is there documentation of tests, inspections, operating history, engineering analyses, etc. that show that the equipment is fit for duty? X X Same as above. Initials CJL CJL A B D 0 0 1 15155 April 18, 1995 PS/'I S.T. 89 ABDOOl 15156 ABERDEEN PSM AUDIT Audit item COMPLIA NCE AUDIT GUIDELINES SCT\Otl$J) PROCESS SA FETY INFORMATION 29 CFR 1910.119(d) Yes No Comments 1. Is process safety information complete and upto-date before a process hazard analysis is conducted? 2. Are all employees provided reasonable access to all PSM documents (e.gare official hard copies or electronic copies ofP&IDs and operating procedures available at all times in the control room or principle workplace for operator)7 3a. Is there chemical information for all covered chemicals? 3b. Does the compilation of chemicals information include all the information required by law? i) Toxicity information; X X X X Interview comments indicate that some information was not complete at the start of the PHA. Also, the comments indicated that this did not hinder the PHA. MSDS ii) Permissible exposure limits (when available); X MSDS iii) Physical data; X MSDS and technical data references. iv) Reactivity data; X Technical references. Initial s DCS DCS DCS DCS DCS DCS DCS DCS April 17, 1995 IWeuJ 18