Text For Citation: 01 Item/Group: 002A Hazard:

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions: a) On or about May 14, 2012 and times prior, recommendations from a PHA revalidation which was completed in 2009, were not addressed and resolved in a timely manner. All recommendations contained in the HAZOP Final Report had a target completion date of 10/31/2009, however, many of these had not been completed. The majority of these recommendations were to replace or modify pressure safety valves and were based on a relief valve study conducted at the facility. The employer also had a document entitled "Ladder Creek 2008 PHA Revalidation Action Items" which contained additional items to be addressed from the PHA revalidation. Many of the entries were left blank and did not contain any indication of completion date or any documentation of a resolution for the items. Abatement Note: Abatement certification and documentation is required for this item (see enclosed "Certification of Corrective Action Worksheet").