Text For Citation: 01 Item/Group: 014 Hazard:

29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process: a) Establishment - PEEB Process The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2014 TCPA compliance audit including changing valve notification on the programmable logic controller to flow/not flow Violation occurred on or about 8/4/15. b) Establishment - PEEB Process The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for installing a pressure transducer on TK-153 with low pressure alarm (completed 12/31/13) Violation occurred on or about 8/4/15. c) Establishment - PEEB Process The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for installing a pressure gauge in the nitrogen line upstream of NIT-RV-1 (completed 3/2014) Violation occurred on or about 8/4/15. d) Establishment - PEEB Process The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for installing a blank flange in the sample line off autoclave A1. Violation occurred on or about 8/4/15. e) Establishment - PEEB Process The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for providing PLC logic to close the steam supply valve on high autoclave pressure (completed 12/2013) Violation occurred on or about 8/4/15. f) Establishment - PEEB Process The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for adding instructions to operating procedures to explicitly instruct operator not to start the agitator if temperature is at setpoint (completed 11/2013) Violation occurred on or about 8/4/15. g) Establishment - PEEB Process The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for installing separate actuated valves and lines, one for the process vent to atmosphere separate from vacuum line (completed 12/2013) Violation occurred on or about 8/4/15. h) Establishment - PEEB Process The employer did not follow management of change (MOC) procedures when implementing recommendations from the 2013 Process Hazard Analysis (PHA) for installing a cap or plug in bleed valve line after usage (completed 12/1/2013) Violation occurred on or about 8/4/15. i) Establishment - PEEB Process The employer did not follow management of change (MOC) procedures for installation of a Programmable Logic Controller (PLC) for the covered process in 2013. Violation occurred on or about 8/4/15. j) Establishment - PEEB Process The employer did not follow management of change (MOC) procedures when process piping was converted to stainless steel in 2012. Violation occurred on or about 8/4/15. k) Establishment - PEEB Process The employer did not follow management of change (MOC) procedures when recalculating MAWP for WT-100. Violation occurred on or about 8/4/2015.