Documents requested from OSHA Inspection of Kansas City, KS
- EPA Reportable Release Forms/Form 'R' 23
- Operator Log Book (Operator Log/System Log)
- PSM Committee Meeting Minutes (PSM Team Minutes) and responses made to resolve issues.
- Mechanical Integrity audits for past two years and actions taken in response to audit.
{Removed from list as duplicate of 32}
- Minutes of PSM Consultations with hourly employee for past two years and responses to
consultation.
- Written PSM Program (all 13 elements)
- List of employee safety concerns/responses
- Access to PSM file cabinet
- PSM Compliance Status Reports/memos/letters/or interplant documents from 1992 (and
responses)
- Any action plans for compliance with PSM standard from 1992
- Safety Committee and/or supervisor safety audits (checklists/forms) and responses to the
audits
- Operating procedures for Emergency Shutdown/operations (?) for both systems/Start-ups
following and emergency shutdown
- Line breaking procedures for both systems and employee training records
- Lockout/tagout procedures for all equipment in both systems (machine specific procedures
and general program) and employee training records
- Confined Space entry procedures and employee training records (and program)
- Site control for contractors/maintenance personnel
- Hazwoper (HAZMAT) procedures/programs/training programs and records/agreements with
outside responders/medical exams for responders/physician opinions/incident critiques/list
of responses for last two years
- PPE Programs (1910.132) written evaluations and inspections; 1910.134 respiratory
programs and employee training records
- HazCom program/training records
- Emergency Action Plans
- Meeting notes of meeting which occurred approximately last Thursday (4-24-97) with
Luicille White, John Lewis, Paul Williams, and Robbie Robison)
- Emergency Alarm/signal procedures/programs/test records
- Annual certification of operating procedures
- PSM Operating procedures (including emergency shutdown); training records (and means to
assure OJT and classroom training was effective)
- Training programs for operators for new and old systems
- Contractor injury and illness logs
- List of outside contractors used for the past two years and what jobs they performed
- Contractor training and information programs; and training records
- Contractor safety and health program evaluation criteria/procedures/program - name of
person(s) performing these evaluations
- Written mechanical integrity program procedures. ie. For compressors/pumps/calibration
of alarms/level indicators/controls;cut-off’s/pipes/valves/pressure
reliefs/vents/cut
off switches/interlocks/etc.
- Testing procedures for mechanical equipment/Inspection procedures for mechanical
equipment
- Documentation of inspection/tests performed on process equipment and frequency performed
- Training documentation for personnel who perform process equipment inspection and
testing.
- Accident Investigation Reports
- Route cause analysis training program and training documentation
- Resolution of incident investigation finding and recommendations as (?)
- Incident dated 07-17-97
- Incident dated 02-27-97
- Incident dated 02-13-97
- Incident dated 09-15-96
- Incident dated 02-04-97
- Compliance Audits (need reference documents used to compile findings)
- Resolution of recommendations made in the Preston Refrigeration Report of 01-24-97
LIST # 2
(I) Pre-Start Up Safety Review
- Documents generated during Pre-start up safety review for new sausage line in 1996
including the following:
- Checklist demonstrating that installed equipment in accordance with design
specifications. A construction inspection report or punch list from engineer-of-record
would suffice
- Documents to show that SOP’s, maintenance and emergency procedures were in place,
prior to charging system with ammonia.
- Provide PHA for new ammonia system put on line in 1996
- Was training performed for operators in engine room prior to start-up? Any documents to
show this.
- Refrigeration Inspection by Dual Temp.
(d) Process Safety Information
- Information pertaining to hazard such as toxicity, PEL, reactivity, corrosivity. MSDS
has some of this info.
- P&ID’s for old and new machine room. These diagrams should include "state
points" of process such as design pressure and temperature in different components of
system.
- Maximum intended inventory of ammonia. Charge into system (pounds of ammonia).
- Provide specifications used to purchase ammonia. What is grade or quality of ammonia? Do
you specify issue of "contaminants" picked up during transport.
- Safe operating limits (high and low) for temperatures, pressures, flow rates of ammonia
and critical auxiliary system such as evaporative condensers. Ammonia levels in Receiver?
- Simplified block flow diagrams
- Plan view of plant showing electrical classification of each area per NEC/NFPA
- Ammonia relief system design and design basis. Include design and manifold that connects
discharge from each relief valve.
- Basis of design for ventilation system in machine room.
- For old and new system design what were applicable:
- building codes?
- mechanical codes?
- industry standards of recommended practice
- Descriptive of safety systems including equipment to prevent:
- thermal expansion from trapped liquid
- liquid deceleration (hydraulic shock or hammer)
- vapor-propelled liquid (hydraulic shock or hammer)
- Description of safety interlock
- Description of detection system
- Description of suppression systems such as water fogs, mists, etc.
- Provide design/specification sheets for pressure vessels, shop drawings of pressure
vessels would be sufficient.
- Provide any documentation that system meets good engineering practice as established by
IIAR, ASHREA, etc.
(e) Process Hazard Analysis
- Audit indicates PHA’s were performed without adequate PSI. Have these audits been
redone?
- Is there a PHA for new 1996 ammonia system.
- Did PHA’s address hazards by work category? Different for maintenance workers o
pumps, reliefs than packing operators?
- Did PHA’s consider previous incidents. Could not find PHA analysis. Did you
consider incidents reported in industry literature such as lift trucks hitting piping,
etc.
- Did PHA’s consider interrelationship of detection system and ventilation
engineering controls?
- What factors were considered for siting of machine room and machine room offices in the
event of a leak?
- What human factors were considered for machine room controls, alarms, access. (Primatech
has this now)
(I) Management of Change
Was MOC done for evaporative condenser tube bundle replacement two years ago?
Document request - 04/30/97
- Copy of all PSM committee minutes
- Turn around reports or major repair and inspections
- For contractors repairing/replacing insulation:
- inspection reports on piping condition
- training
- names of workers repairing insulation
- Work orders for pipe replacement since January 1996 and design criteria for piping and
insulation.
- MOC for condenser changed out two years ago that failed this week.
- Pages 307-395 from operator logs
- Operator walk around mechanical integrity audits for last two months
- Corporate guidelines for all SOP’s
- Mechanical integrity documents including:
- design specification sheets
- maintenance records and procedures
- inspection and test procedures and records
- Pressure vessels and tanks:
- 35 pound accumulator
- 75 pound receiver
- Transfer tank
- - Heat exchanger
- Piping spools - corporate T&I or pipe submitted
- Hot Gas Return lines
- Hi Temp liquid lines
- Hot gas lines
- Relief valve headers
- Instruments:
- Level indicators for accumulators
- Evap xcy (?) switch for isolation
- Emergency stop button
- Compressor low pressure cut out
- Compressor high pressure and temperature cut out
- High 25 pound accumulator cut out (04/30/97) ie Stop
- Relief device histories:
- # 1, # 2, # 8 FES compressors
- # 3 High side dump
- # 35, # 75 pound receivers (REC HI-A; REC Lo-A)
- Intercooler ICIA
- Oil Accum OCA-12-94
- Transfer tank TTA
- # 3 Accumulator (OP 5:1-94)
- # 3 low side dump LD3A
- Valves
- Valves on following lines:
- hot gas
- hot gas return
- hi temp liquid lines
- pump out valves all old valves
- S4A RS
- Ammonia shut off valves (isolation valves)
- Transfer tank valves
- Pumps
- Ammonia pumps
- Compressors # 1, # 2, # 8
- SOP's for new system
- MOC for change of egress
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