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

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP): a) Ethylene Oxide Continuous Plant, Croda-Atlas Point. - On or about November 25, 2018, due to the infiltration of EO into the EO control building, employees who remained in the EO control room to conduct emergency operations were exposed to toxic and explosion/fire hazards when the employer did not document that it complied with its chosen RAGAGEP, API 752, Management of Hazards Associated with Location of Process Plant Permanent Buildings, Sections 7.6.2, 8.4.1 and 8.4.2. The EO control building was not designated by the employer as a shelter-in-place and did not include equipment/building features that would have protected the control building, control equipment, and its employees from the infiltration of EO vapors such as: " sensors in the air intakes to alert the occupants of the ingress of hazardous materials, " means to automatically limit air ingress from HVAC systems in the event of a sensor alarm; " appropriately sealed windows and doors " equipment for operators who must remain in the control room, such as a breathing air manifold system with supplied air masks, or SCBAs, and, " equipment to facilitate an escape, if warranted, such as 5- or 10-minute escape packs that would provide enough clean air to allow the operators to evacuate to a safe location. b) Ethylene Oxide Continuous Plant, Croda-Atlas Point. - On or about November 25, 2018, the employer failed to document it complied with its chosen RAGAGEP, ASME B31.3 (2016), Process Piping, Section 335.2.2, Bolting Torque when it assembled piping flanges in ethylene oxide service that were not torqued to their proper design loading including the flange bolts on the 1½ inch vent line of the Purification Column Steam Reboiler E-430 in Area 400 that was involved in the ethylene oxide release. In addition, approximately 85 other flanges were found post-incident to be under torqued in Areas 400 and 1400 of the EO plant. c) Ethylene Oxide Continuous Plant, Croda-Atlas Point. - On or about November 25, 2018, the employer failed to document it complied with its chosen recognized and RAGAGEP, ASME B31.3 (2016), Process Piping, Section 308.4  Gaskets, when it assembled a piping flange with a gasket that was not suitable for the process conditions, i.e. the gasket material was not compatible for ethylene oxide service. This piping flange and gasket were part of the 1½ inch vent line of the Purification Column Steam Reboiler E-430 in Area 400 that was involved in the release of ethylene oxide. e) Ethylene Oxide Continuous Plant, Croda-Atlas Point.- On or about November 25, 2018, the employer did not document that it complied with RAGAGEP such as: " NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection Sections 7.1.10.3, 7.5.2, 9.2.1, and 9.2.2 for fixed water spray systems (deluge system); " NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection Sections 4.6.4.1 and 4,6.2 for diesel firewater pumps and jockey pump; " API 2510 [as referenced in employers chosen RAGAGEP, the Ethylene Oxide Product Stewardship Manual Third Edition (ACC)] Section 10.3.1.5 requires 4 hour firewater supply; and, " NFPA 22, Standard for Water Tanks for Private Fire Protection Section 4.1.1 for firewater tank; when the existing firewater system was not adequately sized and designed to meet the additional firewater demands (e.g. simultaneous operation of deluge system and fire monitors, and other non-firewater users) for mitigating an ethylene oxide release at the ECO[EP1] Plant. This contributed to the firewater supply being undersized for a high firewater demand case involving flow from multiple users. These conditions contributed to employee exposure to the toxic, fire, and explosion hazards posed by ethylene oxide.