Text For Citation: 01 Item/Group: 005 Hazard:

29 CFR 1910.119(d)(3)(i):Information pertaining to the equipment in the process did not include: 29 CFR 1910.119(d)(3)(i)(D):Relief system design and design basis; On or about April 8, 2021, the employer failed to document relief system design and design basis for the following Resin Plant covered process equipment: a. the Kettle 3 Total Condenser, did not have any relief system design or design basis for the condenser. b. For the Kettle 4 reactor vessel; the employer failed to document all likely relief scenarios such as the Chemical Reaction relief scenario described in API Standard 521, Table 1, Item 12 and Section 4.4.11 the possibility of a 2-phase flow relieving event due to the frothing nature (aka "foaming") of the normal reaction carried on in the kettle 4 reactor vessel, failed to document the safe discharge of the kettle 4 reactor vessel pressure relief vent piping into the Catch Tank and failed to document evaluation that vent piping could withstand the forces associated with pressure relief discharge events. c. For the Kettle 5 reactor vessel; the employer failed to document all likely relief scenarios such as the Chemical Reaction relief scenario described in API Standard 521, Table 1, Item 12 and Section 4.4.11 the possibility of a 2-phase flow relieving event due to the frothing nature (aka "foaming") of the normal reaction carried on in the kettle 5 reactor vessel, failed to document the safe discharge of the kettle 5 reactor vessel pressure relief vent piping into the Catch Tank and failed to document evaluation that vent piping could withstand the forces associated with pressure relief discharge events. d. For the Kettle 8 reactor vessel; the employer failed to document all likely relief scenarios such as the Chemical Reaction relief scenario described in API Standard 521, Table 1, Item 12 and Section 4.4.11 the possibility of a 2-phase flow relieving event due to the frothing nature (aka "foaming") of the normal reaction carried on in the kettle 8 reactor vessel, failed to document the safe discharge of the kettle 8 reactor vessel pressure relief vent piping into the Catch Tank and failed to document evaluation that vent piping could withstand the forces associated with pressure relief discharge events. e. For the K3 Bubble Cap Column; the employer did not have any relief system design or design basis for the Bubble Cap Column. f. For the Kettle 3 reactor vessel; the employer failed to document all likely relief scenarios for the pressure relief system, such as the Chemical Reaction relief scenario described in API Standard 521, Table 1, Item 12 and Section 4.4.11 the possibility of a 2-phase flow relieving event due to the frothing nature (aka "foaming") of the normal reaction carried on in the kettle 3 reactor vessel (K3); failed to document all likely relief scenarios for the pressure relief system, such as the Reactor relief scenario described in API Standard 521, Table 1, Item 16B and section 4.4.11 the consideration of for "failure of agitation, or stirring" which occurred during the events involved with the fatal incident on April 8, 2021 when the K3 agitator was not mixing as required by the normal batch operation procedures; failed to document the actual burst pressure rating of the K3 reactor vessel rupture disk; failed to document the impact of the installation of the interconnected Total Condenser on the K3 reactor vessel relief system; failed to document the impact of the installation of the interconnected Bubble Cap Column on the K3 reactor vessel relief system; and failed to document an evaluation of the reaction forces and their impact on the K3 rupture disk and discharge piping. g. On or about and prior to April 8, 2021, the employer the employer did not have any relief system design or design basis for the Catch Tank CT-8. Employees working on and in the vicinity of equipment containing highly hazardous chemicals are exposed to fire, explosion and contact hazards.