Document q8boDk1JqQ0KdMDOOVg9QQjG

interoffice Communication To From Date R. D* Gamblin - Lake Charles A1 Zulka, Ed Romero, Walter Jenkins July 17, 1974 Subject Inspection of Walking and Working Surfaces - VCM Plant Lake Charles As requested by Mr. Vernon, a detailed inspection was made on June 26, 1974. The recommendations are listed on the attachments as follows; Attachment A -- Priority I items Attachment B -- Priority II and III items Attachment C -- General Recommendations The items were given the following suggested priorities: I -- Items involving serious hazards which should be given immediate attention. II -- Moderate hazards which require a short'-term program for correction (12 months). Ill -- Deficiencies or minor violations of Standards that may be corrected under a long-term program. The cooperation of your staff in making this inspection is appreciated and if we can be of further assistance, phase let us know. A1 Zulka Ed Romero Walter Jenkins WDJ;rt CC: Leon Vernon - Saddle Brook R. E. Lehmkuhl - Lake Charles C. H. Klunick - Houston Earl Gremillion - Lake Charles 4.- CCR 000016615 Attachment A Priority I Items VCM Plant - Lake Charles 1. T 202 Platform on West Side - Add handrail on east side. 2. C-500 Top Platform - Add handrail on side next to outlet pipe. 3. C-202 A. Install safety screen where ladder is adjacent to end of platform (3 required). Fifth level - replace corroded grating on north side. 4. Furnaces - North End A. Install handrails on top and intermediate platforms where sides are open. B. Install self closing gate on second ladder down from top (top ladder is 24n from entrance to second ladder). 5. H 303A Rope off entrance to area where grating lias been removed for maintenance. 6. C 101 Install vertical bar in opening between ladder cage and railing. 7. Light Ends Column Add screens between ladder cage and handrail on 3rd and 5th levels. CCR 00,0016616 Attachment B Priority II and III Items VCM Plant - Lake Charles C 102 II - Relocate conduit behind ladder rungs from 1st level to ground level. (2f//?4ll - Replace chain with safety bar at platform levels 1, 2, 3, 4, OHJtucl***. 6, 7, 8, 9, and 10. Safety bars also needed at top and 5th levels where there are no chains. 4///?: Remove foot obstruction behind the ladder at 6th level platform. Install safety' screen or vertical bars from ladder cage to handrails on the 6th level (distance is 3` from the rung to the handrail). T 202 II - Platform on south side has missing toe plate vnder the head of ' drum. -^Replace chain with safety bar. . II - On the west side platform install handrail on the side of -- /^V^he drum. Also replace chain with safety bar. ^Ji^7|^eP^ace chain with safety bar on top of drum. C 202 XI - On 1st, 4th, and 6th level platforms install safety screen or ,ocy-y^vertical bars from cage to the handrail (3* from ladder rungs ' to handrail). Note: Priority I items included screen require ments at 2nd, 3rd, and 5th levels. fa*** Replace chains with safety bar on platform levels 1, 2, 3, 4, 5, and 6, jrfifTfTt - Replace grating on east side of 6th level. II - There are no chains at ladder entrance at top level platform. -<2///74 instail safety bar. />///7^II - Revise insulation behind two rungs at top leve? - foot obstruction. -R---e---a--c--t-o---r-s-----3---0--1--,-----3--0--2-----a--n--d-----3--0--3-- \t 1st Level II - Replace missing toe plate_north of R 302. | II - Remove short sections of grating and replace with long sections. Weld or J-bolt sections down. I II - Toe plate wired together north of R 301 - Replace with bolts. 9!>M 2nd Level II - Floor hole between H308 andH 309 with rotten wood covering half the hole. Repair the floor hole with a metal cover. II - Repair jfloor hole east of R 301. II - Abound H 211 the eratine is beginning to corrode and duf* lome floor holes need to be repaired. 00001*>*>17 OCR Attachment B Page 2 t inf</-?<{ 2nd Level (Cont.) IX - Install safety bar on ladder at east side of H 303C. - All grating on west end of platform should be secured. S 208, H 202A and H 202B CA/^II - Grating is saddle clipped and wired. 11 ! J-bolted, It should be welded or vf) a ` p - Chain missing on platform on east side of H 202A and H 202B. Replace with safety bar. I - No chains on short ladder on entranceway. Install safety bar. /w?* II - On the table at the handrails, install back plate so material can not fall off and hit someone walking by BL 501, It is 8` higlu T 601 and T 611 No safety bars on ladder entranceway. , , Loading Rack - SE Corner of Plant // 7> ***. ^ II - Provide toe boards^ ^^ S 401 and S 402 ~ Gmail platform at bottom of S 401 on the north side - Secure.. II - Remove wood . caffold on north side of S 402. I///7- H 408 Fin Fan ^///^ III" Replace expanded metal grating or add supports. Furnaces f///?4ll - Weld grating to supports and remove saddle clips. " On east end of furnaces add toe boards, handrails^ and uidrails as required. tf/jfp^TT - Increase hand clearance at top rung on upper ladder. (p/\Jjbf / / 103 Heavy End:, Column - Install safety bars at ladder entrances. T 511 Anhydrous Ammonia ^//^?5"TI - Install handrails on steps to dike. JC 101 Steam Stripper coAAaLU ** Top platform saddle clips loose. '' 7 II - Secure pirating at first level. - T 103 ^ " Grati-ng bent and needs securing on north platform at manway. T 101 Crude EDC Tank Platform II - Grating secured with saddle, clips - Use J-bolts. Ladder rune not in alignment with platform. CCR 000016618 Attachment B Page 3 H 104 ZjlS/ytX11]? South of H 104-railing is substandard (28"), S 102 Lower Light End Column Overhead Accumulator IX - Install toe board inside on west side, II - Saddle clips loose - Install J-bolts. H 106 On both ladders top rung is not in alignment with platf ora. S 103 Lower Heavy Ends Column Reflux Accumulator II - Grating secured with saddle clips. ___ H 109A Upper EDC Condenser 21)17^ fill^Ladder rung not in alignment with platform. 9///^ ** ~ Grating secured with saddle clips, lag Compressor Room f - Grating loose at west ladder crossover. - Grating saddle clipped. II " Install midrail east side wall opening. R 304 Platform i1 ^///74 II - Grating saddle clipped on 1st level. 1J 207A and 207B VCM Condenser Platform fII - Grating bent both sides - Add supports to structure to support foiMX weighted load of bell heads from condensers. OCX - Short pieces of grating should be replaced with long spans. - Install safety bars at ladders. . S 307 - Grating Bent- - Replace. H 303C II - Complete standard railing south above S 309 drum. T 503 - II - Steam pipe running vertically at top section of ladder i/'?$ obstructing clearance of runp;s. 1 T 506 , II - On walkway north of compressor building install standard 7//l/^T railing (part of railing installed on east end). bight Ends Column II - Replace chain with safety bar. II - Improve housekeeping of 1st level. I - Cover floor holes on 2nd and top levels. <25? Add intermediate platform on ladder - exceeds 20 ,/iU^ AJ CCR 000016619 .. Attachment B Page 4 Steam Flash Tanks No. 150 and 250 - Install ladder safety bar. , Platform Over S 207A and 207B, S IPS and S 109 D&UlTX - Secure grating " remove saddle clips. <ff(/?<)-> II - Improve housekeeping. II - Remove top ladder rungs - Cover floor ho.les. - Install handrail on grating top S 109. ^ Ii - Promote ladder safety bars. / ^ ^Structure At T 103A.' T 110 and T 102 (fll - Secure grating. ^///7<f?II - Cover floor holes at H 111, above T 103A and east end T 103A. (^11 Install toe boards on west side of platform at east end of T 103A. 3^ /,/S--/--?----T-I-I* - A(d4d 3sa'~feetynLsgc^r.een at west l-a--d---d--e--r-- to nlatform over T 103A _ S 104A and 104B -5 II " Cover floor holes on top platform. .^Vertical Tanks West of HCl Tank *S/ ff y II ~ Install toe boards on west side of platform IC1 Tank II - Secure grating. Install toe board - west side. 7^ Shell Pit phy\&~--^11 - Install handrails. C 500 Scrubber II - Portable scaffold had uo handrails or toe boards and boards not tied down. Scaffolds should be removed after rse, IL-- Provide intermediate platform or safety climbing device - ladder c is about 35' high. \~ \ Cooling Tower IIj; Extension ladder is not tied off at SE corner of Jcooling tower At*l. area - Enforce procedures. ' - Secure grating in primp area. f A A11 " ^lat^orm above pumps needs *-<-><=> and some clips are loose. - T 70 has wood platform with rotten steps and platform boards. Sly** ^j^i^TL - Replace broken rung on NE ladder - distribution tpy. Tank Farm T 401A. B. and C Illr Install toe boards Cover floor holes. | CCR 000016620 Attachment B Page 5 T^402. 405, 422, 452, and 460 Ladder is substandard - side rails are 14" T 411A, B, and C II - Secure grating on top platform - saddle clips $re corroded or loose. T 461 Sfll'7 j II - Ladder is substandard - replace with vertical ladder. /^f'/^ Vertical Drum Near T 461 IT - Cover holes in floor plates. ?CltQ Toe boards are substandard (2%" high), __Dikes <i// / ? ^ II " Install handrails on all crossover steps. Warehouse V//?f II - Add toe board and midrail on handrail at overhead storage area. CCR 000016621 Attachment C General Items VCM Plant - Lake Charles III- At several locations there are toe boards at the platform entrance to ladders. On future construction they should be omitted. Top ladder rung should be even with platform. Ill- At locations where it is feasible we recommend grating be XJLaa Jibuti secured by welding. II - Prepare a program on storing and using scaffolding equipment 7 III -Walking and working surfaces should be inspected annually. 000i