Text For Citation: 01 Item/Group: 007A Hazard:

29 CFR 1910.119(e)(1): The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. The employer failed to identify and control process hazards where "safeguards" were identified and claimed as controlling identified hazards in the 2007 and 2013 PHAs that did not exist, were ineffective or were non-compliant: a. For the 2007 PHA, regarding Node 12 involving ethanol vapors from the Rectifier Column C-4201 being condensed in Reflux Condenser E-4201; the employer claimed Safeguard 12.5 MI program and SOP for an identified hazard associated with tube failure in the condenser. The employer does not have a mechanical integrity program that addresses tube components for tube and shell heat exchangers. Additionally the employers standard operating procedures are not compliant for this equipment. b. For the 2007 PHA, regarding Node 12 involving ethanol vapors from the Rectifier Column C-4201 being condensed in Reflux Condenser E-4201; the employer claimed Safeguard 12.2 SOP and Operator Training for failed valve closure on the cooling water supply to the condenser. The employers standard operating procedures are not compliant for this equipment and do not address this situation. c. For the 2007 PHA, regarding Node 13 involving ethanol vapors condensing in the Reflux Vent Condenser E-4203; the employer claimed Safeguard 13.17 MI Tube Program to control hazards associated with tube failure in the condenser. The employer does not have a mechanical integrity program that addresses tube components for tube and shell heat exchangers. d. For the 2007 PHA, regarding Node 17 involving pumping rectifier bottoms containing ethanol to the Stripper Column C-4202; the employer claimed Safeguard 17.2 SOP and Operator Training and the identical Safeguards 17.3 and 17.4 MI Program for hazards caused by valve closure and valve failure. The employer does not have a compliant mechanical integrity program for valves. The employer does not have compliant standard operating procedures for this equipment and the procedures do not address this situation. e. For the 2007 PHA, regarding the Node 24.7 Deviation Misdirected Flow hazard caused by tube failure in a tube and shell heat exchanger; the employer claimed Safeguard 24.9 MI Program when a mechanical integrity program to address tube failure does not exist. Additionally the identical Node 25.7 and 33.7 Deviation Misdirected Flow also claim the identical administrative control for a mechanical integrity program to address tube failure. f. For the 2007 PHA, regarding Node 26.7 Deviation Misdirected Flow caused by valve failure open or misalignment; the employer claimed Safeguard 26.7 SOP and Operator Training to control this hazard. The employer does not have compliant standard operating procedures for this equipment and procedures do not address this situation.