Document zzMn1j3qLQLVmb5Mdzk4BG2Qn

) P. E. Brubaker -4 - August 23, 1976 CONCERNS/RECOMMENDATIONS A. Procedures 1. Concern The Dept. 19 operating personnel were not aware that any work was going on in the ammonia area. A ction CED will enforce the plant rules m*)q ~~ JS 7 r c. ~~1 S ft, f u-'tK Y~ 4 tcj Responsibility: CED/E. D. Moore Timing: Immediately A ction CED will assign additional supervision to the off sites project^/ /C j~D - r?,,1? ; P. -A Kesponsibility: Timing: CED ---------Immediately - r w! 2. Concern Should Construction/CED work around tanks which contain hazardous inventories such as ammonia. Action Write a procedure specific for the ammonia tank rehabilitation that will minimize contact in this area. c://o/l 6/ Responsibility: Timing: J. L. Rasmussen September 15, 1976 A ction A plant policy should be considered for work on hazardous inventory tanks. Responsibility: Timing: SHAC October 1, 1976 3. Concern The present permit system may not allow control by the department affected when CED is doing a lot of off site pipe work. A ction 13464 Investigate present permit system to incorporate CED involvement in new construction. Ce-.-' >Responsibility: Timing: SHAC October 1, 1976 LAM014684 P. E. Brubaker -5- August 23, 1976 CONCERNS/RECOMMENDATIONS (cont. ) 4. Concern - The ammonia storage tanks are located in the north storage area and do not have a specific geographical area that is considered the ammonia storage area. Action - Define ammonia storage area geographically and inform all personnel. (oj Responsibility: J. L>. Rasmussen Timing: W. H. Triplett E. D. Moore September 1, 1976 B. Mechanical Design 1. Concern The broken swage nipple did not meet the current Monsanto specification of no threaded connections against hazardous inventories. The action plan to backweld the swage nipples is a compromise in fluenced by constraints of existing construction, stress relieving, etc. There is concern that backwelding may not be the best solution. Action All nozzles on the tank need to be investigated to ensure that the mechanical design of the installation is satisfactorv. ______ _______\ Responsibility: Timing: J. Trafton September 1,1976 A ction Alternate designs, including one submitted by Badger will be evaluated to determine the best available corrective action. (Gr-ff-'U -----------------?/V n ij Responsibility: Timing: J. Trafton September 1, 1976 2. Concern During the process of isolating the ammonia tanks, it was found that one of the tank outlet valves which is located under the skirt of the tank did not have an extension handle. SC 13465 LAM014685 P. E. Brubaker -6- August 23, 1976 CONCERNS/RECOMMENDATIONS (cont.) Action Install extension handle and check the workability of all others.--?----------j--.-- / (jcn~79-sUjLe^L/ 73/7 L Responsibility: Timing: W. M. Recknor September 3, 1976 3. Concern During the investigation, it was thought that some of the ammonia valves into and out of the ammonia tanks leak through, which makes isolation difficult. Action - Study problem and develop solution v/JF'i i>j u "Responsibility: Lju oL ' , Timing: n W. H. Triplett J. L. Rasmussen September 15, 1976 C. Safety Equipment 1. Concern During the period of the incident, it appeared that the Dept. 19 operators were running out of air paks too frequently. It did not appear that they were lasting 30 minutes as designed. It was later de termined that two types of air paks were being used. One, a Scott Air Pak which discharges air in the mask upon demand and a MSA type furnished by the fire department which lets out air whenever the valve is open. Action A ction Conduct safety meetings to train Dept. 19 operations in the use of both types of masks. f~ SC A" 7~, S S) r _ f v '/ f J bs i- Responsibility: Timing: _ Sco-r1/ <9i* PS>Z. R. T. Hammann October 1, 1976 The investigation team questions the advisability of two types of air paks and also whether other departments need similar training. 13466 '(*>./) 7` ./ Responsibility: Timing: LP&S September 1, 1976 LAM014686 P. E. Brubaker - 7- August 23, 1976 CONCERNS/RECOMMENDATIONS (cont. 2. Concern - There was some concern from the personnel in volved in the incident whether or not there were enough air paks available and whether or not the ability to refill was fast enough. A ction - Review and define nature and extent of air pak problems during the incident. ___ P^/Sctfrtstr "i H-ioX-rS See// P/9/^S P LLsS Responsibility: LP&S T/i/Z/'xs <Zc>~rT/ Timing: September 1, 1976 3. Concern Investigation determined after the incident that the location of the caged safety ladder did not give access to both ends of the ammonia tanks and also the caged ladder did not meet plant standards and was too small for personnel if they had an air pak. Action - Relocate and revise the ladder to meet plant standards. Responsibility: Timing: W. H. Triplett Action Plan - 9/15/76 Execution - 12/15/76 4. Concern Some of the team members questioned whether all block valves could be reached with a vapor proof suit and air pak on. A ction - Check to determine and make recommendations. Responsibility: Timing: W. H. Triplett September 15, 1976 5. Concern An inspection of the area indicated that there may not be enough safety showers in the area of the ammonia tanks. Action - Study and make recommendations on number of safety showers needed. Responsibility: Timing: W.H. Triplett J. E. F ox September 15, 1976 LAM014687 SC 13467 P. E. Brubaker - 8- August 23, 1976 CONCERNS/RECOMMENDATIONS (cont.) D. Safety of People 1. Concern - There was concern that with the large number of CED construction personnel working in the north storage area where the ammonia tanks are located, that all personnel would not be aware of potential hazards in area. Action Action Emphasize existing safeguards and procedures to all workers*_________ ____ _ T ------------- -----------j j - f?3 - &>'pA c-, Z > ? c_ /fo C ec/ur ~ HR e s ponslbili tyl CED"~ T iming: Immediately ' Initiate straight day "permit" operator for closer surveillance by Dept.--LS, / S/i(/7 Responsibility: Mfg. - Dept. 19 Timing: August 25, 1976 2. Concern There was concern noted about the adequacy of the EPP for handling contract personnel and also how the plan covers community impacts such as when to evacuate residential areas, etc. A ction: Review EPP plan fo-r-handling of the above factors. Responsibility: Timing: PMSB Underway E. Relationships 1. Concern - There is a feeling that CED/Construction personnel are not aware of potential safety hazards and act differently than plant personnel. Action - Provide action plan for improving safety awareness of off site construction workers. sc 13468 Responsibility: Timing: CED September 1, 1976 >) ZL o i) LAM014688 P. E. Brubaker -9- August 23, 1976 CONCERNS/RECOMMENDATIONS (cont.) 2. Concern - Because the ammonia storage area will be operated by AN-5 after December 15, 1976, the Dept. 19 operators are not completely knowledge able of the new piping system which in turn caused the isolation procedure during the incident to be slowed down. Action - Train the Dept. 19 operators on the piping of the ammonia tank system. Responsibility: Timing: J. L. Rasmussen October 1, 1976 F. Process Design 1. Concern - Can ammonia be pumped from one storage tank to another without using the present compressor. Action - Design and installation of such a system should be inv e s ti gated. ____________ _ -- S' ) Responsibility: W. H. Triplett A. J. Stroud J. C. Trube Timing: Design - 9/15/76 Cost Study - 10/1/76 bw Enclosure (1) Rasmussen SC 13469 LAM014689