Text For Citation: 01 Item/Group: 027 Hazard:

29 CFR 1910.119(f)(1)(i)(B): The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements: Normal operations: a. In the chlorination department 1C building #17, 1C-21, 20 Reactor Operating Procedures (# 32 reactor) did not match the practice utilized by plant operators. In the phosphites plant building #27, the employer failed to develop and implement specific written procedures for normal operations, for the following processes: b. For the 34R reactor process, there were no normal operation procedures. c. For the 35R reactor process, there were no normal operation procedures. d. For the 72R reactor process, there were no normal operation procedures. e. For the 36R reactor process, there were no normal operation procedures for the production of the DNPP intermediary. f. For PHOS SOPM 408, 9228 Production in 36R (PCL3 PROCESS), the procedure did not reflect the current practice regarding the removed 224T tank as the PCl3 charging supply. Main Street is used for PCl3 charging of the 36R reactor. g. PHOS SOPM 303, 44R Doverphos DP10 Production the procedure did not reflect the current practice regarding the removed from service 238T tank as a phenol source and the removed from service 261T tank as the PCl3 charging supply. Main Street is used for PCl3 charging. In the Chlorination department 1P building #6, the employer failed to develop and implement specific written procedures for normal operations. h. For 1P-03E, #40 Reactor Operating Procedure lacked specificity for proper temperature to begin chlorine line bleed down and charge completion.