Text For Citation: 01 Item/Group: 009 Hazard:

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation: This violation was documented on or about May 10, 2012, when it was observed that the employer had not adequately sized the pressure relief valves of the following pressure vessels within Areas 1, 2, 3 of the Vinyl Chloride Monomer Unit and the Tank Farm: Area 1 a) Direct Chlorination Reactor A/PSV R7101A-A was not sized according to API 520 worst case scenario; Exposure to External Fire-Wetted Vessel. This scenario requires the PRV to be sized with a J orifice verses a D orifice that the valve is currently fitted per Bertrand Engineering Report dated July 19, 1999. b) Exchanger on the Direct Chlorination Reactor R7101A/PSV E7101-A-C and A-A: As according to API 520 this relief valve is undersized for its service and could not relieve under the loss of cooling water per Bertrand Engineering Report dated July 19, 1999. c) Recovery Column T7103/PSV-T7103A-B: According to API 520 the calculations for this relief valve is undersized for loss of cooling water scenario per the Bertrand Engineers, Inc. 12/1999. d) Old Steam Stripper T7401/PSV-T7401-B and A: According to API 520 this relief valve is undersized for the blocked outlet scenario per the Bertrand Engineers, Inc. dated July 22,1999. According to the relief calculations both valves together could sufficiently relieve if both relief valves were car-sealed open but one valve was car-sealed closed. e) New Steam Stripper T7402/PSV-T7402-1 and PSV-T7402-2: According to API 520 as per the Bertrand Engineers, Inc. 6/1999 relief calculations show these relief valves are undersized for the control valve failure scenario per the Bertrand Engineers Report dated June 16, 1999. f) Ethylene Stripper Bottoms Cooler E7314A/PSV-E7314A: The fire scenario calculations according to API 520 show the present relief valve is undersized per the CDI Engineering Report dated January 8, 2005. g) Stripper Feed Interchanger E7313/PSV-E7313-B: The fire scenario calculations according to API 520 show the relief device is undersized per the CDI Engineering Report dated November 14, 2004. Tank Farm h) Chlorine Expansion Bottle V7621/PSV-V7621-1: The pressure relief calculations were incomplete due to insufficient information. The engineers report says the PSV is undersized due to the fire scenario according to API 520.