Text For Citation: 01 Item/Group: 002B Hazard:

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment. a. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio: On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for pressure vessel inspections. Procedures used by the company did not establish a set of specific actions and strategies detailing the scope, extent, methods and timing of specific inspection activities in order to determine the condition of a pressure vessel based on defined/expected damage. Actions and strategies that were not addressed in the inadequate procedure include at least; identification of the next inspection date for each inspection type; the specification of the inspection and NDE techniques to be used; and the specification of the extent and locations of inspection and NDE that was used. Pressure vessels inspected using inadequate written procedures include but are not limited to Kettle K-4001, Kettle K-4002, Kettle K-4003 and Kettle K-4020. b. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio: On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for piping inspections. The procedures used by the company did not establish a set of specific actions and strategies detailing the scope, extent, methods and timing of specific inspection activities in order to determine the condition of piping based on defined/expected damage. Actions and strategies that were not addressed in the inadequate procedure include at least; identification of the next inspection date for each inspection type; NDE techniques and methods to be used; and the specification of the extent and locations of inspection and NDE that was used. Piping inspected using inadequate written procedures include but are not limited to the formaldehyde piping loop. c. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio: On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for rotating equipment inspections. The procedure used by the company did not establish a set of specific actions and strategies detailing the scope, extent, methods and timing of specific inspection activities in order to determine the condition of rotating equipment based on defined/expected damage. Actions and strategies that were not addressed in the inadequate procedure include at least; identification of the next inspection date for each inspection type; NDE techniques and methods to be used; and the specification of the extent and locations of inspection and NDE that was used. Rotating equipment inspected using inadequate written procedures include but are not limited to the kettle agitator powertrain and kettle coolant water/steam/oil pumps for kettles AG-4001, AG-4002, AG-4003, and AG-4020. d. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio: On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for bolted connections. Procedures need to specify many variables such as but not limited to torque values on threaded connectors, connector materials, torqueing patterns, torqueing equipment, temperature variables, and flange and seal inspections. Bolted connections include but are not limited to the formalin lines, kettle agitator equipment, and cooling water/oil/steam lines to kettles AG-4001, AG-4002, AG-4003, and AG-4020. e. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio: On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for evaluating corrosion under insulation on process piping, piping components, and vessels. Procedures need to specify many variables such as but not limited to specific actions and strategies detailing the scope, extent, methods and timing of specific inspection activities in order to determine the condition of piping, piping components, and vessels, NDE techniques and methods to be used, and the specification of the extent and locations of inspection and NDE that was used based on defined/expected damage. Corrosion under insulation inspection procedures would apply to piping, piping components, and vessels such as but not limited to cooling water/oil/steam lines to kettles AG-4001, AG-4002, AG-4003, and AG-4020 as well as the kettles themselves. f. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio: On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for installing pressure relief disks on the relief vents for the process kettles. Procedures need to specify many variables such as but not limited to specific actions and strategies detailing relief system disassembly, inspection, installation, and reassembly of the pressure relief system to kettles AG-4001, AG-4002, AG-4003, and AG-4020. g. Sumitomo Backlite North America dba Durez Corporation located in Kenton, Ohio: On or about August 8, 2018 the employer failed to develop adequate written mechanical integrity procedures for lubrication of rotating equipment. Procedures need to specify many variables such as but not limited to specific actions and strategies detailing the scope, extent, methods and timing of specific lubrication activities in order to ensure timely lubrication of process equipment, techniques and methods to be used, specification of locations of lubrication, and the proper types of lubrication to use. Lubrication procedures would apply to rotating equipment such as but not limited to oil/steam/water cooling pumps and agitator drive components for kettles AG-4001, AG-4002, AG-4003, and AG-4020. Abatement Note: One feasible and acceptable means of abatement would be for the employer to develop and implement an inspection plan per API Standard 510 (Pressure Vessel Inspection Code: In-service Inspection, Rating, Repair, and Alteration), API 570 (Piping Inspection Code: In-service Inspection, Rating, Repair, and Alteration of Piping Systems), API 572 Inspection Practices for Pressure Vessels, API 574 Inspection Practices for Piping System Components, API 676 (Positive Displacement Rotary Pumps), API 576 (Inspection of Pressure Relieving Devices), Center for Chemical Process Safety: Guidelines for Mechanical Integrity Systems, and equipment manufacturer's maintenance and inspection recommendations for each pressure vessel , piping circuit , and piece of rotating equipment at the facility.