Document dQ8Q6RO3O814JYe6oKb14w6G5

Improvement Opportunities - Deer Park PVC Plant Page 1 Element Application 1910.119(a) IO# A9501 IMPROVEMENT OPPORTUNITIES 1995 PSM Audit - Deer Park PVC Plant Description Develop an index system that will clearly identify the PSM file contents, location of data and the person(s) responsible for each portion of the PSM effort. DOCUMENTATION: Posted letter dated April 29, 1996, outlines each section of PSM Standard, Responsibility and Location RESPONSIBILITY Cann TARGET DATE COMPLETION Date 04/29/96 Process Safety Information 1910.119(d) PSI9502 Maintain a data base of information pertaining to the chemicals of the process, technology of the process and equipment in the process. To facilitate easy retrieval and utilization of this information, it is recommended that an index system be maintained including methods for updating and maintaining the data current. DOCUMENTATION: Same letter as A9501, references MSD information, Mechanical Integrity information for equipment, and PMA's Cover Process P & ID's. Cann 04/29/96 Process Hazard Analysis 1910.119(e) PHA9503 n --* Ui KJ ----- V-4O ----------------- Provide proper disposition for all items resulting from Hazops regardless of whether or not they have value and are actually implemented. Closure of findings and communication to appropriate people are critical parts of the documentation necessary to complete a process hazard evaluation. DOCUMENTATION: Several meetings were held with groups from different areas of the plant to review sets of open PHA recommendations. Many were closed out at that time and some needed more help. In either event each recommendation was given proper disposition as to whether it needed further review or not. The rest that were not closed were forwarded for approval to: DeSantis 10/01/96 Improvement Opportunities - Deer Park PVC Plant Page 2 ELEMENT IO# Description j Responsibility TARGET Date Completion DATE The Project Group The PMSEC The bi-weekly maintenance meeting. Out of those meetings action items were assigned to individuals with target dates for completion. Ail documentation is provided in the MANAGE-PC database of PRIMATECH software on our computer system. Operating Procedures 1910.119(f) OP9504 Review each operating procedure, as they are being reworked by iCT, to ensure inclusion of each operating phase listed under paragraph 191O.119(f)0)(i). DOCUMENTATION: This was completed in February. Two subject matter experts, one operator and one head operator were assigned to work with ICT to make this happen Payne 02/97 OP9505 Ensure operating procedures include operating limits that outline consequences of process deviation and steps required to correct or avoid deviations. DOCUMENTATION: This was completed in February, using the same two subject matter experts. Payne 02/97 NGC 13280 OP9506 Establish a routine to review and certify annually that operating procedures are current, accurate and reflect existing process technology. DOCUMENTATION: This routine has been in place for sometime. We plan to renew and certify all procedures on a semi-annual basis. Next review is scheduled for mid-June, 1997. Payne 06/01/96 Improvement Opportunities - Deer Park PVC Plant Element 10# DESCRIPTION Page 3 X 1 | Target i COMPLETIO Responsibility Date date Training 1910.119(g) Training 1910.119(g) O *--* Ui K> oo 1-- T9507 Verify completeness of file documentation where Deer Park Plant has "grandfathered" operators involved in operating a process prior to May 26, 1992. Apply this same activity to maintenance craft person. Ability to justify why a person was "grandfathered" will be best management practice. DOCUMENTATION: The Maintenance Department has all the old files pertaining to all their training We also now put in the files any new training they do. All Manufacturing personnel have a "Grandfather" Certificate of Training in their training folder signed by Supervisor. This document was added to the individuals training folder in 1992. Henderson (Maintenance) Payne (Operations) T9508 Training records must include information indicating that each employee involved in operating a PSM process has been trained in each phase listed under paragraph 1910.119(g)(l)(l). Operating limits relating to consequences of deviation and steps to avoid deviations need to be addressed DOCUMENTATION: Training records indicate the operators were training in all tasks tor their areas. This includes operating limits. Payne T9509 Employers must consult with its employees, who are involved in operating the PSM process, to determine the frequency for efresher training. Document this effort. DOCUMENTATION: E-Mail sent to all Shifts December 17, 1997, asking each jmployee this question. Memos are in my E-Mail File. 1 Payne 01/01/96 01/01/96 03/06/97 03/06/97 Improvement Opportunities - Deer Park PVC Plant Element IO# - DESCRIPTION T9510 Recommend converting manual training data management system to electronic data management, system such as TRIM. This system is used at several GEON facilities. DOCUMENTATION: Trim is being used. People positions, and courses are already in the Database. As resources are available, the next step will follow. '" RESPONSIBILITY O'Keefe/Payne Page 4 TARGET | COMPLETION Date ' Date 10/01/96 Contractors 1910.119(h) C9511 Implement a requirement whereby contractors, as an employer, understand and carry out their responsibilities under paragraph 1910.119(h)(2)(v). DOCUMENTATION: Safety Questionnaires are filled out on Contractors prior to working at GEON; This includes review of OSHA 200/Log with final approval by GEON-Safety. Annually, Purchasing sends to GEON contact a "Vendor Appraisal Form" for Contractor performance during the previous year. Heinschel 04/30/96 C9512 Deer Park person(s) should audit contractors (routinely used by the plant) to verify that they are fulfilling their responsibility according to paragraph 1910.119(h)(2)(v). Heinschel DOCUMENTATION: On several occasions through out the year the following vendors have been inspected or visited: Law Valve - Relief Valve Repairs Q Bird Machine - Centrifuge O McNeely Machine - Machine Work t--* Amber Electric - Electrical Contractor OJ tv> oo Force Construction - Capital Construction Projects K> ACS Labs - Baxter Testing NALCO - Water Treating OXY - Utilities 04/30/96 Improvement Opportunities - Deer Park PVC Plant ELEMENT IO# DESCRIPTION Page 5 Target RESPONSIBILITY DATE COMPLETION DATE Mechanical Integrity 1910.1190 % nQ MI9513 MI9514 Recommend plant develop site specific Mechanical Integrity policy to reflect actual actions being executed in complying with this element. Review the document Elements of a Written Technical PSM Analysis (Appendix No. 1) so that ail appropriate equipment/systems are included and non PSM equipment/systems are excluded with reasons for each decision. DOCUMENTATION; Law Engineering and Environmental Services completed the Deer Park Integrity program on April 18, 1997. Procedures include the following: General Guidelines, Pressure Vessels and Reactors, Storage Tanks, Fiberglass Reinforced Plastic Tanks/Vessels, Piping Systems, Eddy Current of Seamless and welded NonFerromagnetic Heat Exchanger, Eddy Current of Seamless Copper and Copper Alloy Tubing, Flux Leakage of Ferromagnetic Heat Exchanger Tubing, Sample Inspection Procedures and Scoustic Emission Testing. Where recommendations have been made to correct deficiencies noted during inspection of PSM elements, timely action to resolve, complete documentation and communication to appropriate people must be achieved, i.e. natural gas pipeline. DOCUMENTATION: Pipeline repairs have been completed. Work orders and Purchase Orders are used to verify completure plus new inspections. Lindstrom Lindstrom 09/01/97 05/08/97 04/30/96 Ui K) MI9515 Establish random audit system whereby relief valve repairs and Lindstrom GO settings are verified at repair shop prior to receiving in plant. DOCUMENTATION: P/M in Champs is established to do this item quarterly. 04/30/96 Improvement Opportunities - Deer Park PVC Plant Element - : ;i Ijfnfcf:rifeikKX'\v \"vi'J< '$?*J:?*';j DESCRIPTION Page 6 Responsibility TARGET date Completion Date Management of Change 1910.119(1) MOC9516 Develop check list type form to ensure, except for "replacement in kind", management of change request address technical basis for change, impact on safety and health, modifications to operating procedures, necessary time period, authorization required, informing and training of affected employees, and updating process safety information and operating procedures or practice. DOCUMENTATION: New MOC Procedure has a checklist. McKinley/ Johnson 11/15/96 NGC 13284 MOC9517 Develop a list of positions who have authority to approve a M.O.C. involving other than "replacement of kind" in a PSM area. DOCUMENTATION: New MOC Procedure has Authorization List. Incident Investigation 1910.119(m) ! > > > 119518 Take action to bring formal closure to action item recommendations noted during incident investigations. DOCUMENTATION: Developed Corrective Action Report: Section J - Safety & Environmental Narratives Section II - Safety Audit Items Section III - Safety Walk Thru Items These are updated and distributed monthly. Compliance Audits 1910.119(0) CA9519 Retain the two most recent audits. Utilizing report findings, develop response, take corrective action and document closure. McKinley DesJardins DesJardins 11/15/96 04/15/96 04/15/96 a: NGC 13285 ab> '5>02) CO o u5 o o> Improvement Opportunities - Deer Park PVC Plant Page 1