Text For Citation: 01 Item/Group: 003 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: At the Ethylene Oxide plant, the employer had not verified that all P&ID's were up to date and accurate for use by Harcros Chemical employee(s) and contractors for the process hazard analysis, line breaks, equipment/piping replacement/repairs, and etc., the following was noted: (a) triple check valves were observed after FE 301-06 on the ethylene oxide line during the walk around, but not drawn on the p&ids (b) during the walk around the ethylene oxide line split into 2 directions at PRV 301; one direction the 2 inch pipe had a reducer that reduced pipe to 1 inch that led to the PRV 301, the other direction the 2 inch line had a reducer that reduced the pipe to 1 inch that led toward the ethylene oxide intermediate tank T-301; neither line was drawn on the p&id. (c) pump selector switch HS 313 was drawn on the p&id, but not observed during the walk around. (d) two pressure gages were observed on opposite sides of a normally open gate valve that was located on the ethylene oxide line between the feed pump P-301A and the cooler E-301 was not drawn on the p&id. (e) pressure gage 314 and two other gate valves drawn on the p&id was not observed during the walk around. (f) a pressure gage was observed on the ethylene oxide line after a gate valve prior to pipe slope to the reactors (g) triple check valves were observed during the walk around prior to on/off flow control valve (XV 201-20) leading to reactor R-202 (h) no gate valve was observed during the walk around on the ethylene oxide line leading to reactor R-205, reactor R-204, and the scrubber tank T-302 (i) a two inch to one inch reducer was observed on the ethylene oxide pipe line before the on/off flow control valve (XV 301-21) leading to reactor R-204 was not drawn on the p&id (j) a nitrogen line was observed connected to the ethylene oxide pipe line that was exiting from the ethylene oxide cooler (E-301), but not drawn on the p&id (k) on/off control valve (XV 303-4) was drawn on the p&id, but was not observed on the propylene oxide pipe line during the walk around (l) after the blue lever ball valve on the propylene oxide line, a propylene oxide pipe line leading to a truck tanker intersected the propylene oxide pipe line to the intermediate tank (T-303), was not drawn on the p&id (m) a ball valve was observed on the propylene oxide pipe line after the piping intersection to the truck tanker; this ball valve was not drawn on the p&id (n) a pressure gage and two gate valves were not observed during the walk around after propylene oxide feed pump (P-303A), but drawn on the p&id (o) a pipe reducer labeled two inch to one inch was observed during the walk around to be 1 inch to 2 inches after propylene oxide feed pump (P-303A), but not drawn on the p&id (p) two pressure gages and a needle valve were observed between the propylene oxide feed pump (P-303A) and the propylene oxide cooler (E-303), but not drawn on the p&id (q) a two inch to 1 inch reducer was observed during the walk around between the propylene oxide feed pump (P-303A) and on/off control valve (XV 303-21) leading to reactor R-204, but not drawn on the p&id (r) two flanges were observed during the walk around after the unlabeled on/off control valve leading to reactor R-205, but not drawn on the p&id (s) a 3/4 inch gate valve on the 3" 316SS pipe line was not observed during the walk around, but drawn on the p&id (t) a gate valve between FE 204-7 and TW204-6 on 3" 316SS pipe line was observed during the walk around, but not drawn on the p&id (u) a 3/4" pipe line with a 3/4" gate valve were observed connecting two hose connection pipe lines prior to their 3/4" gate valves during the walk around of the reactor exchanger (E-204A), bottom section (v) a 3/4" gate valve and pipe line were observed during the walk around attached to the reactor exchanger (E-204A), but not drawn on the p&id (w) pressure indicator/transmitter number 204 had moved to a new location on ethylene oxide transfer system pipe line 2"316SS, the pressure indicator/transmitter #204 was observed before the triple check valves prior to the propylene oxide transfer section piping intersection (x) after flow valve 204-1 on pipe line 2"316SS leading to the ethylene oxide reactor (R-204) the following was observed during the walk around, but not drawn on the p&id: triple check valves, pipe and flange, gate valve, pipe and flange (y) pressure indicators 210 and 215 were not observed during the walk around, but were drawn on the p&id (z) on drawing D156PD04A the majority of the pipe lines were not labeled to identify their size and material of contruction (aa) a 6 inch to 4 inch reducer was observed during the walk around before pump P-204A, but not drawn on the p&id (bb) a 3 inch to 2 inch reducer was observed during the walk around after pump P-204A, but not drawn on the p&id (cc) ethylene / propylene oxide vent transfer line 2"316SS SCH 40 Process to the ethylene oxide water jet scrubber tank (T-302) had a flange, check valve, and gate valve observed during the walk around, but not drawn on the p&id (dd) propylene oxide vent line 2"316SS SCH 40 Process to the ethylene oxide water jet scrubber tank (T-302) had a flange, check valve, and gate valve observed during the walk around, but not drawn on the p&id (ee) no triple check valves or a gate valve were observed during the walk around of the ethylene oxide feed line 2"316 SS Process to the ethylene oxide reactor (R-202), but were drawn on the p&id (D156PD03) (ff) no pressure indicator or transmitter were observed after the flow transmitter (202-1) during the walk around of the ethylene oxide feed line 2"316 SS Process to the ethylene oxide reactor (R-202), but were drawn on the p&id (D156PD03) (gg) during the walk around an approximate 8 inch braided hose and flange were connected to the ethylene oxide feed line 2"316 SS Process to the ethylene oxide reactor (R-202) after the flow valve (FV 202-1), this was not drawn on the p&id (hh) a pressure transmitter was observed during the walk around on the propylene oxide feed line 2"316 SS Process to the ethylene oxide reactor (R-202), but not drawn on the p&id (ii) a pressure gage was observed between the propylene oxide feed pump (P-303A) and reactor (R-204), reactor (R-205), and scrubber tank (T-302), but not drawn on the p&id Employee(s) were exposed to release of extremely flammable vapors to atmosphere that historically result in fire / explosion hazards leading to injury and death to persons in the workplace.