Text For Citation: 01 Item/Group: 007 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. On or about February 17, 2015, the employer did not develop or implement written procedures to maintain the ongoing integrity of the process equipment. The employer's mechanical integrity program does not contain written procedures and/or procedures have not been developed or implemented procedures for the following: a) The employer has UT past inspection data from 1993-2000 performed by contractors which indicates that some pressure vessels have or are soon to be at their retirement date. The employer has not effectively implemented its mechanical integrity program by not establishing procedures to resolve or reconcile historical UT data measurements for pressure vessels which indicated significant corrosion. 1993 Owensby & Kritikos Inspection Report: V-202 TML point Inspection Date Corrosion 5 1/93 Shell 32% metal loss V-110 TML point Inspection Date Corrosion 1-12 1/93 Shell 14-27% metal loss F-313 TML point Inspection Date Corrosion 1-12 1/93 Shell 15-19% metal loss Flange/knuckle/dish 15-24% metal loss V-203 TML point Inspection Date Corrosion 10, 11, 12 1/93 Shell 15-43% metal loss Longview Inspection 1995 Inspection Report: V-101 TML point Inspection Date Corrosion 17, 18 3/93 Shell 29% metal loss Hi-Tech Testing 1997 Inspection Report: V-120 TML point Inspection Date Corrosion 4 9/97 Shell 40% metal loss CB-271S TML point Inspection Date Corrosion 4 9/97 Shell 40% metal loss b) Riveted pressure vessels: There is no written procedure in the Mechanical Integrity program addressing the proper inspection of riveted vessels under vacuum. Two riveted vessels are currently in use: King Inlet Gas Scrubber V-103 and Cole Inlet Gas Scrubber V-102 c) Buried vessels and piping: There is no written procedure in the Mechanical Integrity program addressing the proper inspection of buried vessels and underground piping. Portions of the piping for the main flare header to the knockout drum is underground. d) Visual or UT inspections with limited access: There is no written procedure in the Mechanical Integrity program addressing procedures to be followed when limited access creates barriers for visual and UT inspections of pressure vessels and piping, such as, but not limited to the following process equipment: T-830: Visual inspection limited due to height and the presence of insulation V-810: Visual inspection limited due to presence of insulation D1-A and D1-B: Visual inspection limited due to presence of insulation 3?G-3056 A-D: Visual inspection limited due to height. UT exam limited to the high temperature of the line 6?G-3057 A-D: Visual inspection limited due to height and the presence of insulation. 3?G-3058 A-D: Visual inspection limited due to the presence of insulation 3? G-3060-A-D and 6? GH 4-C10: Visual inspection limited due to height and accessibility. 3? G-3070-A-B Visual limited due to height 3? G-3083-A-B: Visual limited due to height and accessibility e) Deadleg piping: There is no written procedure in the Mechanical Integrity program addressing the inspection, testing, or removal of deadleg piping. Deadleg piping was identified on the following process equipment: 3? G-3060-A-D and 6? GH 4-C10 piping circuit deadleg 3? G-3070-A-B deadleg-Bottom of 2? control loop 6? G-3057-A-D: deadleg piping-Header to first stage suction 6? G-3142-A-B startup by pass f) Implementation of inspection recommendations: There is no written procedure in the Mechanical Integrity program addressing the implementation, timing and execution of the inspection and testing recommendations. There were recommendations which had not been addressed including but not limited to the following process equipment: V-10, V-30, V-31, V-120, V-215, V-231, T-5, T-6, T-360 8?-G-161-A-A, 8?-G-185-A-A, 10?-G-039-A-B, 10?-G-180-A-B, 12?-G-190-A-B, 14?-G-181-A-B, 14?-G-188-A-B, 20?-G-183-A-A 3? G-3070-A-B, 8? RP-557-A-B, 8? RP-549-A-B g) Corrosion under insulation: There is no written procedure in the Mechanical Integrity program addressing the implementation and timing of inspection and testing recommendations for corrosion under insulation (CUI). There were recommendations for inspection for corrosion under insulation for piping and vessels such as, but not limited to: 6? G-3055 A-D; 6? LV-552-A-A; V-810, T-830; V-20 inlet 6? RP-275-AA; V-20 outlet 6? RP-552-AA; h) Internal inspection audit: The employer has not conducted an audit of its internal inspection program to determine if it is meeting the requirements of the inspection code. Consensus standards such as, but limited to API 570, require that each owner/user organization conduct and audit periodically to determine if the inspections are meeting the requirements of this inspection code. i) There is no written procedure in the Mechanical Integrity program addressing the inspection and testing of stainless steel vessels and piping; T-830, T-4 j) Anomalous data and establishing corrosion rates: There is no written procedure in the Mechanical Integrity program addressing the inspection and testing of anomalous data and establishing corrosion rates. The following pressure vessels had insufficient UT testing, anomalous data; or undetermined corrosion rates. Cryo Area 3? G-3056 A-D: 2 out of 3 UT data point are larger than nominal, hence a corrosion rate cannot be fully established. Cryo Area 4? G-3085 A-D: TML/ UT data point 5-6 are larger than nominal, a hence corrosion rate cannot be fully established. 3? G-3060A-D: corrosion rates not established for TMLs 1, 2, 5, 11, 12, 15, 19, 21-26 V-810: 6 out of 6 UT data point (TMLs 1-4) are larger than nominal, hence corrosion rate cannot be fully established. F-880: 14 out of 16 UT data point are larger than nominal (no corrosion rate established for TMLs 1-4), hence corrosion rate cannot be fully established. T-830: 4 out of 6 UT data point are larger than nominal (no corrosion rate established TMLs 1-4), hence corrosion rate cannot be fully established. There were an inadequate number of TMLs (6 TMLs on shell) for a 72 foot tower. No TMLs/UT data for manways, nozzles, head and bottom. T-1270: No TMLs/UT data for head V-520: Insufficient TMLs/UT for head, shell and nozzles V-522 Insufficient TMLs/UT for head, shell and nozzles V-524 Insufficient TMLs/UT for head, shell and nozzles V-213, V-30 and V-31 corrosion rates cannot be established Anomalous data and no corrosion rate established for many measurements: V-20, V-215, V-231, V-30, V-630, E-520 and T-130, T-340, T-350, T-360 Anomalous data and no corrosion rate established for many measurements 4? RP 548 A-B C-1 Startup bypass; V-20 inlet 6? RP-275-AA; V-20 outlet RP-552-A-A; 6? G-3011-A-D; 4? NG-444-A-B; 4? NG-448-A-B; 4? NG-452-A-B; 4? NG-451-A-B k) There is no written procedure in the Mechanical Integrity program addressing inspection of car seals for pressure relief valves and intervening valves.