Text For Citation: 01 Item/Group: 037 Hazard:

29 CFR 1910.119(i)(2)(iii): The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process: for new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup; and modified facilities meet the requirements contained in management of change, paragraph (l): The employer did not resolve hazard analysis findings and recommendations for the pre-startup safety review (PSSR) associated with installation of the new PCL3 supply piping circuit for building #27 (aka Main Street) and connection to 44R, 51R, and 36R reactors: a. Recommendation 8 involved valve inspection to determine valve predictive maintenance replacement for the feed line into Main Street. b. Recommendation 10 involved preventive maintenance for feed pumps regarding bearing wear indication and was not resolved. c. Recommendation 16 involved preventive maintenance for feed pumps regarding vibrational analysis and was not resolved. d. Recommendation 26 involved verifying pump preventive maintenance and was not resolved. e. Recommendation 15 involved operating procedures for PCl3 pump operation, operating procedures were not noted in the Dover PSSR checklist, were not noted in the Dover PSSR checklist actions to be completed section and these procedures are not included in the phosphites control room operating procedures binder. f. For the 247T tank/72R reactor conversion project, a process hazard analysis was not performed prior to start-up in 2005. Process safety information was compiled, a management of change was initiated but a hazard analysis was not performed prior to the introduction of PCl3 into this new process.