Text For Citation: 01 Item/Group: 001 Hazard:

29 CFR 1910.119(d)(3)(i)(B): The employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the equipment in the process including piping and instrument diagrams (P&ID's): At a facility located at N2467 Vaughan Road, Waupaca, WI 54981; the employer did not compile process safety information pertaining to the equipment in the process, specifically, P&IDs. The employer's P&IDs for the sulfur dioxide system, which included liquid withdrawal and sand core processing, did not accurately represent the system. a) For the liquid withdrawal portion of the system at the outdoor Sulfur Dioxide One Ton Supply Cylinder; the P&ID did not adequately represent the E-Pro Auto Valve Closure connections or the nitrogen tubing connection. b) For the liquid withdrawal portion of the system in the Core Chem Room; the P&ID did not adequately represent a pressure sensor, two shut-off valves (including type or identifier), the attached "E-Pro Electric Valve Closure System", or the sulfur dioxide expansion chamber and its appurtenances. c) For the liquid withdrawal portion of the system in the Core Room above the core machines; the P&IDs did not adequately represent piping connections to the "Large Gas Box Machine" and "Small Gas Box Machine", a valve that had been dead ended (upstream of the L20 connection), or any of the valves servicing each of the three core machines (including type or identifier). d) For the sand core processing portion of the system in the Core Room; the P&IDs did not adequately present each of the core machines' condensers, accumulators, their connections/ appurtenances, and did not represent any piping, valves, controllers, or other equipment leading to the SO2 application point at the core boxes.