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

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting: On or about February 17, 2015, the employer's 2014 process hazard analysis was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in the process. The employer's 1993, 1998, 2004, 2009 and 2014 process hazard analysis did not address facility siting as follows: a) The 1993 facility siting process hazard analysis and all subsequent process hazard analyses (1998, 2005, 2009, and 2014) have not included a blast study; thus allowing employees to occupy potentially inadequately protected (i.e., not adequately protected by separation or building construction) structures. This exposes employees to explosion, fire, toxic material, or high pressure hazards resulting from the release of highly hazardous chemicals from process equipment. Buildings that are located in unacceptable areas of the blast zone include the Administrative building (Plant Office), Service Building (Instrumentation and Electronics), and Control Room/Building, and Truck loading/unloading building. b) Responses to potential problem reports included in the 1993 process hazard analysis are no long being implemented. c) The 2004 process hazard analysis which included the addition of the E/P Treater, GWG Chiller and GWG Cryo Plant was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in the risk of additional process equipment and flammable materials. d) 2012 and 2014 process hazard analysis for the truck/loading was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in having tanker trucks (containing flammable materials) traffic adjacent to the Cryo Unit vessels and occupied buildings. e) Motor vehicle usage inside the plant. f) Failed to carry out building siting evaluations for existing buildings intended for occupancy in accordance with Section 6, Section 7, and Section 8 of API 752 as part of their process hazard analysis.