Text For Citation: 01 Item/Group: 003 Hazard: CHEMNEP

29 CFR 1910.119(d): The employer did not develop a written compilation of proces s safety information on hazardous chemicals in the process, the technology of the process , and the equipment in the process before conducting the process hazard analysis : The employer does not complete a compilation of written process safety informa tion before conducting the process hazard analysis. a) This violation occurred o n or about November 18, 2010, and at times prior thereto and at subsequent times in the Butadiene Recovery Area of Lion Copolymer, LLC - Baton Rouge, when proce ss safety information (PSI) for the come-alongs required to operate critical val ves in piping systems of the BD Recovery process were not included in the PSI us ed to conduct the PHA revalidation of 2005. The come-alongs are critical equipme nt in the BD Recovery process, without which several hard to operate valves cann ot be opened or closed, thus control of the process can be compromised. Use of c ome-alongs to operate valves was reported by BD Recovery Area Leadermen and Flex Operators as a requirement for executing their duties in making adjustments while operating the process (to isolate equipment, start and stop flows, redirect process streams, put equipment into service, and remove equipment from service). b) Design temperature and pressure for vessel 27 -V-61 are missing from P&ID E-80-3-113 (LION 0003429). c) Design temperature for vessel 26-V-24 is missing from P&ID E-80-3-138 (LION 0003431). d) Design temper ature for vessel 26-V-25 is missing from P&ID E-80-3-138 (LION 0003431). e) Capa city for pump 26-P-12A is missing from P&ID E-80-3-138 (LION 0003431). f) Capaci ty, design pressure, design temperature, and material for vessel 26-V-31 are mis sing from P&ID E-80-3-142 (LION 0003434). g) Design temperature and pressure for vessel 27-V-65 are missing from P&ID E-80 -3-156 (LION 0003442). h) Capacity, size, and type, for pump 26-P-48 are missing from P&ID E-80-3-158 (LION 0003444). i) Capacity, size, type, material, and hor sepower/rpm rating for pump 26-P-16 are missing from P&ID E-80-3-159 (LION 00034 45). j) Design temperature and pressure for vessel 26-V-98 are missing from P&ID E-80-3-168 (LION 0003448). k) Design temperature for vessel 26-V-22 is missing from P&ID E-80-3-174 (LION 0003450). l) Design temperature for vessel 26-V-23 is missing from P&ID E-80-3-174 (LION 0003450). m) Capacity for pump 26-P-13 is mi ssing from P&ID E-80-3-174 (LION 0003450). n) Design temperature for vessel 26-V-26 is missing from P&ID E-80-3-175 (LION 0 003451). o) Design temperature for vessel 26-V-27 is missing from P&ID E-80-3-17 5 (LION 0003451). Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including describing the steps it is taking to ensure that process safety information pertaining to equipment in the process i s thoroughly compiled prior to conducting the PHA.