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

29 CFR 1910.119(f)(1): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and addressing at least steps for each operating phase, safe operating limits, safety and health considerations, and safety systems and their functions as outlined by this paragraph: On or about February 10, 2019, the revised startup procedure, DU2 Startup from Cold Circulation, was implemented but did not contain clear instructions or steps for safely conducting the startup of DU2. The revised startup procedure did not provide clear instructions or address safety or health procedures, such as, but not limited to: sending light hydrocarbons from the upper column of DU2 to the debutanizer; the necessary steps to place the tube side section of the vent exchanger T4330 back into service; or take into consideration the potential exposures to fire, explosion or toxic chemicals generated during the startup operations..