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

29 CFR 1910.119(e)(3): The process hazard analysis shall address: 29 CFR 1910.119(e)(3)(iii): Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.); a. For the 2007 PHA, Node 4.1 Deviation of No Flow due to Cause E-4103 Plugged does not address the existing engineering controls or any potential for additional engineering control additions for the potential overpressure hazard associated with this deviation. b. For the 2007 PHA, Node 7.14 Deviation High Concentration of Ethanol in Bottoms Stillage due to Cause Rectifier Valve closed does not address the existing engineering controls for parameter indication, DCS alarms and the overpressure protection for the Beer Column. c. For the 2007 PHA, Node 9.1 Deviation No Flow First Effect Evaporator E-4501 Cause Pump Failure, Node 9.21 Deviation Increase in Number of Phases Cause PC-4102 Overheating and Flashing and Node 9.24 Deviation No Level Cause C-4101 Too Hot Consequence Starve Pump Potential Pump Damage do not address potential engineering and administrative controls to prevent pump failure and minimize the risk for pumps as an ignition source, such as but not limited to an effective mechanical integrity program. d. For the 2007 PHA Node 9, the identical Safeguards 9.15 and 9.17 DCS Alarms and Interlocks lack specificity. These PHA safeguards do not address the actual engineering and administrative controls used to control the identified hazard. e. For the 2007 PHA Node 12, Safeguard 12.1 Instrumentation and DCS Alarms on E-4201 lacks specificity. The PHA safeguard does not address which actual instrument and DCS alarm employees would rely on to the lack of cooling water or the lack of ethanol vapor flow into the Reflux Condenser E-4201. f. For the 2007 PHA Node 14, the identical Safeguards 14.1 and 14.3 Instrumentation and DCS Alarms on Column, FIC-42159, UIC-42117, the identical Safeguards 14.4 and 14.5 Instrumentation and DCS Alarms on Column, 14.6-14.8, 14.13 and 14.17 Column Instrumentation and DCS Alarms C-4101 and C-4201 and 14.9 Column Instrumentation and Alarms lack specificity. The PHA safeguard does not address which actual instruments, controls, DCS Beer Column alarms and DCS Rectifier Column alarms are intended to address and control the identified Rectifier Column C-4201 overpressure hazards. In addition, FIC-42159 is a control that is not in existence. The 2013 PHA lacks specificity for engineering and administrative controls claimed by the PHA to control identified hazards. The following listed ?Existing Safeguards? in the 2013 PHA revalidation lack specificity: g. for the ?Beer Column? page, there are three identical controls ?interlock with control system to prevent column flooding? and the control ?alarm/operator intervention ? Evap system? listed without specificity to the exact engineering and administrative control claimed. h. for the ?Rectifier Column? page, there are two identical controls ?interlock with control system to prevent column flooding? and two identical controls ?interlock with operator alarms? listed without specificity to the exact engineering and administrative control claimed. i. for the ?Stripper Column? page, there are two identical controls ?interlock with control system to prevent column flooding,? the control ?operator intervention,? the control ?operator alarms? and the control ?interlock with operator alarms? listed without specificity to the exact engineering and administrative control claimed. j. for the Mole Sieves page that addresses the VS-4301 and VS-4302, the mole sieve beds, the control ?PSVs, alarms, operator intervention? and ?routine inspection, alarms and operator intervention? are listed controls lacking specificity to the exact engineering and administrative control claimed. k. for the Mole Sieves page that addresses the regeration process equipment, the control ?secondary containment, alarm, operator intervention,? the control ?system design, fire protection system, PSVs? and the control Routine inspections, alarms and operator intervention, secondary containment? are listed control lacking specificity to the exact engineering and administrative control claimed. l. for the 1st Effect Evaporator page, there are two identical controls ?pressure indicator, operator intervention? and the control ?Routine inspections, alarms, and operator intervention, secondary containment? listed without specificity to the exact engineering and administrative control claimed.