Text For Citation: 01 Item/Group: 001 Hazard:

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process. On or about 11/24/2015, the employer's piping and instrument diagrams for the outdoor formaldehyde unloading/storage unit and the Resin Building Kettle 19 unit were not accurate and did not represent equipment that was existing and was part of the process when: a) Multiple pieces of equipment on the system, such as but not limited to; valves, strainers, flexible connections, temperature/pressure gages, and temperature/pressure sensors, were not tagged, marked or labeled with information to identify equipment on the system that was represented on the company's P&ID drawings. b) Approximately 21 instances occurred where equipment on the PSM covered systems were not documented on the company's P&ID, such as but not limited to; valves, goose necked vapor release lines, temperature sensors, temporary temperature and pressure devices, flexible lines, antifoam/dry additives equipment, piping lines between Kettle 19 and Condenser 19, a line blind, and a temporary valve. c) Approximately 10 instances occurred where equipment documented on the company's P&ID were not installed on the PSM covered systems, such as but not limited to; pressure gages, valves, a dead-end pipe section and a section of piping from the truck loading area drawn to a non-existent planned storage tank. d) Approximately 3 instances occurred where equipment on the PSM covered systems were not drawn in the correct location on the company's P&ID, such as but not limited to; a line to the sewer from Scale Tank #5 drawn as blanked and disconnected when it was actually connected on the system; finished molten resin tanks (T14, T27, T28, T52) were drawn in the wrong locations; and a drawn 4-way cross section of 4" pipe was actually a 4" Tee section with a 3/4" perpendicular line downstream from the Tee. e) Approximately 7 instances occurred where equipment on the P&ID was identified with the wrong symbol for the part or the symbol was not designated on P&ID legend, such as but not limited to; strainers, valves, lines entering a building from outdoor unloading system, and lines leaving receiver tank 19 didn't designate the adjoining P&ID sheet.