Text For Citation: 01 Item/Group: 008B Hazard:

29 CFR 1910.119(l)(2): Management of change procedures shall assure that the following considerations are addressed prior to any change: 29 CFR 1910.119(l)(2)(ii): Impact of change on safety and health; On or about March 5, 2024, the management of change (MOC) procedures, MOC Change Validation Tool - v*.02 for CESS Venting, dated March 5, 2024 failed to address the impact on safety and health for the disconnection of the CESS Storage Vent line from the A/C Tower 1 discharge location that disrupted the pathway for the CESS Storage Area overpressure relief system. The CESS Storage Area relief system is designed to vent overpressure events from the 10 ASME code pressure vessels from the storage area into the A/C Tower 1 discharge location. This management of change procedure also failed to address the safety and health impact for disconnecting a separator tank from the vent line and connecting the separator tank discharge to a flexible that is placed into an IBC tote during the unloading of electrolyte from tankers. Each separator tank is the pathway for the discharge of pressure-relieving devices for two storage tanks. The MOC procedure failed to address the overpressure event hazards for the altered pathway for the CESS Storage Area venting into the disconnected (and capped) vent line that could lead to catastrophic failure and the overpressure event hazards of venting storage tank and separator tank contents into an IBC tote during unloading which would lead to an immediate release of electrolyte into an employee occupied area. Due to these conditions for which the MOC does not address overpressure event hazards, employees are exposed to fire, explosion and contact hazards.