Text For Citation: 01 Item/Group: 003B Hazard:

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience. The employer did not follow RAGAGEP, such as but not limited to National Board Inspection Code (NBIC) Part 2- Inspection (2015), API Standard 653 (2009), Tank Inspection, Repair, Alteration, and Reconstruction, Sections 6 and 12, API Standard 510 (2009), Pressure Vessel Code: In-service Inspection, Rating, Repair, and Alteration, Sections 5 and 6. and API 570 (2016), Piping Inspection Code: In-service Inspection, Rating, Testing, Repair, and Alteration of Piping Systems, Sections 5 and 6 when pressure vessels and piping inspections were conducted that did not follow RAGAGEP. This condition exposed employees to the hazard(s) of ethylene oxide explosion and fire, overpressure, struck by ruptured vessel parts, toxic release, inhalation. The pressure vessel and tanks inspection and tests frequency that did not follow RAGAGEP include at least the following: (a) Reactor R-200 and all associated piping and instrumentation, the employer failed to conduct on-stream inspections, external inspection, thickness inspection, corrosion under insulation (CUI) inspection (i.e. nondestructive examinations, corrosion allowance, and thickness measurements) in accordance with a written inspection procedure/plan NBIC Part 2 (2015), API 510 (2006) Section 5 and 6 and API 570 Section 5 and 6 (2016); (b) Reactor R-600 and all associated piping and instrumentation; the employer failed to conduct internal, on-stream inspections, external inspection, thickness inspection, corrosion under insulation (CUI) inspection (i.e. nondestructive examinations, corrosion allowance, and thickness measurements) in accordance with a written inspection procedure/plan NBIC Part 2 (2015), API 510 (2006) Section 5 and 6 and API 570 Section 5 and 6 (2016); (c) Reactor R-700 and all associated piping and instrumentation; the employer failed to conduct internal, on-stream inspections, external inspection, thickness inspection, corrosion under insulation (CUI) inspection (i.e. nondestructive examinations, corrosion allowance, and thickness measurements) in accordance with a written inspection procedure/plan NBIC Part 2 (2015), API 510 (2006) Section 5 and 6 and API 570 Section 5 and 6 (2016); (d) Ethylene oxide storage tank T-100; the employer failed to conduct external and internal inspections an in accordance with a written inspection procedure/plan NBIC Part 2 (2015), API 653 (2006) Section 6 and 12; (e) Ethylene oxide storage tank T-101; the employer failed to conduct external and internal inspections an in accordance with a written inspection procedure/plan NBIC Part 2 (2015), API 653 (2006) Section 6 and 12; (f) Benko Steam Hot Box Model S24 (hotbox) and all piping and instrumentation; the employer failed to conduct on-stream inspections, external inspection, thickness inspection, corrosion under insulation (CUI) inspection (i.e. nondestructive examinations, corrosion allowance, and thickness measurements) in accordance with a written inspection procedure/plan NBIC Part 2 (2015), API 510 (2006) Section 5 and 6 and API 570 Section 5 and 6 (2016). On or about October 16, 2020 and times prior thereto this condition exposed employees to the hazard(s) of explosion/fire, overpressure, struck by ruptured vessel parts, toxic release, inhalation, to the above process equipment containing ethylene oxide and isobutyryl alcohol.