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Inspection
Priority Item
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Yes,
No, N/A
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Possible
Violations
[1910.119...]
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Comments
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1
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Does
the PSI include definable criteria (acceptable limits) for
continued service/removal from service criteria for rotating
equipment (pumps, compressors and turbines)?
Compliance
Guidance: To determine if the PSI includes information on
definable criteria (acceptable limits) for continued
service/removal from service criteria for rotating equipment,
evaluate the employer's mechanical integrity program procedures,
manufacturers' recommendations, and other pertinent PSI for
rotating equipment.
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(d)
(d)(3)(ii)
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2
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Does
the employer operate the selected rotating equipment (pumps,
compressors and turbines) beyond its acceptable limits for
continued service?
Compliance
Guidance: 1) Request that the employer provide a list of the
product pump(s), compressor(s) and turbines which are located in
or feed directly into and out of the Selected Unit(s); 2) from the
list of product pump(s), compressor(s) or turbines, randomly
select the inspection and testing records for a total of five of
the product pumps, compressors and turbines (e.g., 3 pumps, 1
compressor and 1 turbine) in the Selected Unit(s); 3) Interview
board operators and review operating data to determine if the
selected rotating equipment has been operated outside its
acceptable limits.
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(j)(2)
(j)(5)
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3
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For
the six pressure vessels selected to be evaluated per X.E.3.aa.,
does the employer have each of these pressure vessel's form U-1
manufacturer's data report (PSI)?
Compliance
Guidance: "Form U-1 Manufacturer's Data Report For Pressure
Vessels' is required by provisions of the ASME Code Rules, Section
VIII, Division 1 (Code) for pressure vessels.
The
manufacturer"s records (e.g. U-1 Data Report), nameplates and
stamping serves a safety management and hazard control function
and is part of the quality control system for construction of a
Code vessel. The Code records assure employers that they are using
pressure vessels that have been constructed to a nationally
recognized consensus standard/good engineering practice. Without
the quality control system required by the Code through its
specifications for nameplates, records, and stamping, employers
cannot determine if they have pressure vessels which have been
constructed to a recognized standard, and they cannot assure that
their vessels are safe to operate.
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(d)
(d)(3)(ii)&(iii)
(j)6)(i)&
(ii), (i)(2)(i)
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4
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For
the six pressure vessels selected to be evaluated per X.E.3.aa.,
if any of these vessels have been repaired, or altered, does the
employer have each of the repaired pressure vessel's R-1 (Report
of Welded Repair) or R-2 (Report of Alteration) form(s) or their
equivalent documentation (PSI)?
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(d)(3)(ii)
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5
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Does
the PSI include information regarding:
-
gaskets, e.g. composition rating,
pressure
rating, etc.;
- fasteners - size,
grade and torque
requirements;
and
- bolt tightening sequencing for
flanges,
blind
flanges and slip blinds?
Compliance
Guidance: Randomly select from different locations in the Selected
Unit(s)the following equipment which are being used to contain
HHCs:
1) 5 gaskets;
2) 5 fasteners used either for
pressure vessels components (e.g. bolted head to shell
connections), pressure piping to piping, or pressure vessel to
piping connections;
and
3) 2 flanges, 2 blind flanges,
and 2 slip flanges and determine if there is a mechanical
integrity program procedure and/or specific procedures which
specifies torque requirements and bolt tightening sequencing for
these selected flanges.
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(d)(1)
(d)(3)(i)(A)
(d)(3)(i)(F)
(d)(3)(ii)
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6
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Does
the PSI include corrosivity data with respect to chemicals in
process and their interaction with the materials of construction
for the equipment in the process?
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(d)(1)(v)
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7
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Does
the PHA and emergency planning and response procedures address
hazards from an adjacent facility (e.g. nearby unit, facility
owned or controlled by a different employer) such as:
-
overpressures from explosions
- toxic
or flammable vapor clouds and fire
-
contamination of utilities
- Improper
feedstocks
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(e)(1);
(n)
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8
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For
employers that keep operating procedures on computer databases,
are there written procedures available for operators that may need
them in a timely manner, e.g. during emergency operations which
may have been initiated by an electrical or computer malfunction -
resulting in no access to the computer based procedures?
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(f)(2)
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9
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Does
the PSI for the Selected Unit(s) include an evaluation of the
consequence of deviations related to:
-
abnormal process conditions, e.g. high
temperature
or pressures, pH, too
much/little
catalyst, crude heater trip,
etc.
-
mechanical failure, e.g. pump or
compressor
trip, exchanger tube failure,
relief
valve needing to be taken out-
of-service,
failure of critical instru-
mentation,
etc.
- utility failure, e.g.
electrical, inert gas
system,
instrument air, cooling water,
etc.
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(d)(2)(i)(E)
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10
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Does
the employer's mechanical integrity program procedure include
instructions on how to determine corrosion rates?
If
so, was the subject procedure used for determining the corrosion
rates in the 6 pressure vessels randomly selected as per Section
X.E.3.aa?
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(j)(2);(d)(3)(ii)
(j)(4)(ii);(d)(3)(ii)
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11
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Are
there written procedures for controlling situations where safety
mechanisms (operational controls, interlocks, etc.) might be
overridden?
Compliance
Guidance: Request policies and/or procedures for overriding or
by-passing equipment at the facility.
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(f)(1);(j)(2);
(d)(2)(i)(E);
(f)(1)(ii)(A);(e)(1)
)(e)(3)(iii);
(e)(3)(iv)(;)(l)(1)
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12
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If
operators and or instrument technicians override or by-pass
equipment in the Selected Unit(s), is it done per an established
procedure?
Compliance
Guidance: Interview process operators and instrument technicians
to determine if equipment related to the Selected Unit(s) is
by-passed or overridden.
If operators or instrument
technicians do override or by-pass equipment, request the
equipment by-pass procedure used by the employer.
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(f)(1)
(j)(2)
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13
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Are
designated safe havens located in areas which may be subject to
the ingress of toxic materials?
Compliance
Guidance: Consider factors such as: the location of fresh air
intakes for the safe haven; the location of the safe haven in
relation to any over pressure hazards; how the design of the safe
haven prevents the ingress of toxic materials, e.g., adequate
separation distance, positive pressure ventilation; whether the
safe haven includes SCBAs and if so are they properly maintained
and is there an adequate number of SCBAs for the number of
employees intended to occupy the safe haven when needed; etc.
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(d)(3)(ii);(e)(1);
(e)(3)(i);(e)(3)(iii);
(e)(3)(iv);
(e)(3)(v);
n;
1910.38(a) and
1910.120(q)
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14
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Are
there adequate detailed procedures developed and implemented for
occupying safe havens during emergencies?
Compliance
Guidance: 1) Request the employer's emergency action plan and
emergency response plan to determine if it contains procedures for
occupying safe havens in or near covered processes during
emergencies; and 2) Interview operators to determine if they have
occupied a safe haven during an emergency and if they have been
trained in emergency procedures with respect to evacuating to and
occupying a safe haven structure during an emergency
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(n),
1910.38(a),
1910.120(q)
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15
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Are
the assembly areas for employees including contractors located out
of harms way?
Does the written emergency action plan or
emergency response plan specify the location of assembly areas for
workers?
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(n),1910.38(a),
1910.120(q)
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#
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Inspection
Priority Item
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Yes,
No, N/A
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Possible
Violations
[1910.119....]
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Comments
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1
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Does
the process safety information (PSI) for the equipment in the
Selected Unit(s) include its electrical
classification?
Compliance
Guidance: Randomly identify 15 pieces of electrical equipment in
the Selected Unit(s). Request PSI for the identified equipment
which indicates its electrical classification.
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(d)(3)(i)(C)
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2
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Is
there electrical equipment in the Selected Unit which does not
meet the requirements of its electrical
classification?
Compliance
Guidance: Request that the employer provide an electrical
classification drawing(s) for the Selected Unit(s).
During
the walkaround inspection of the Selected Unit(s) observe the 15
pieces of electrical equipment (e.g. lighting, electric pumps,
instrumentation, etc.) which were identified in Question 5
(above), using the employer's electrical classification drawing,
RAGAGEP for example NFPA 70 - National Electric Code, the
employers engineering standards/codes for the installation of
electrical equipment, etc., determine if the electrical equipment
is approved for its location.
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(d)(3)(ii),(j)(5)
1910.307
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3
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Are
there controls in-place for safety systems in the Selected Unit(s)
to assure valves which must remain in the open, closed, or other
position are in the specified position to ensure these safety
systems are operational, (e.g., block valve for a deluge system is
car-sealed in the open position to assure flow when the safety
system is challenged; an identified safety-critical instrument is
prevented from being rendered inoperable by closing a valve; a
safety interlock is prevented from being inadvertently taken out
of service when a valve is locked in the open position; a reaction
shortstop or kill system cannot function because of a closed
valve, etc.)?
Compliance
Guidance: Request a list of safety systems in the Selected
Unit(s). Using the list of safety systems and the employer's
associated P&IDs determine if any of these systems could be
rendered inoperable if a valve was in an incorrect position during
operations. If this situation exists, determine if adequate
controls (e.g. car seals, chains and locks, operating procedures,
etc.) are in place to assure the valves are in the correct
positions during all phases of operations.
During
walkaround(s) of the Selected Unit(s) determine if the valves
which could potentially render the safety systems inoperable have
been adequately controlled, e.g. an operating procedure addresses
the specific situation, a PHA has identified, evaluated and
controlled the situation, car-seals when required are in place,
etc.
Examples of safety systems include but are not
limited to: emergency relief systems including relief devices,
disposal systems and flares; automatic depressurization valves;
remote isolation capabilities (aka emergency isolation valves;
safety-instrumented-systems (SIS) including emergency shutdown
systems, and safety interlock systems; emergency reaction
shortstop or kill systems; fire detection and protection systems,
deluge systems; fixed combustible gas and fire detection system;
safety critical alarms and instrumentation; uninterruptible power
supply; dikes; etc.
Where employees could render a
safety system non-functional (e.g., by closing or opening a
valve), the employer must address this human factor in its PHA.
Human factors must be addressed in the PHA regardless of whether
an employee's action is a matter of omission or commission and its
action has potential to result in a safety system becoming
non-functional during operations.
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(f)(1,
(d)(3)(ii),
(e)(1),(e)(3)(iii),
(e)(3)(vi)
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4
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Are
the inspection and testing procedures for the employer's safety
systems and emergency shutdown systems listed in 119(d),
119(f)(1), and (j)(1) audited to assure they are adequate and
implemented?
Compliance
Guidance: A statistically significant number inspection and
testing procedures for safety system(s) and emergency shutdown
system(s) must be audited to assure the validity of the audit and
that an appropriate confidence level in the audit has been
attained.
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(o)(1)
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5
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Based
on the geographic location of the covered process, does the
employer's emergency response and planning address external forces
which might impact the site, e.g. hurricanes, tornados,
earthquakes, cold weather, snow/ice, flooding, lightening,
releases from nearby plants, crash of an airplane from a nearby
airport, fire, etc.
Compliance
Guidance: Request the employer's emergency action plan
(1910.38(a)), and its emergency response plan (1910.120(q)(1) and
(2)) to determine if the employer has addressed potential
emergency situations which can be initiated by external forces.
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(n)-includes
1910.38
&
1910.120(q);(f)(1)
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6
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Does
the PHA of the Selected Unit(s) address the loss of utilities and
what affects the loss of utilities may have at specific locations
in the process?
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(e)(1),
(e)(3)(i),
(iii), and (iv)
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