Text For Citation: 01 Item/Group: 022 Hazard:

29 CFR 1910.119(j)(2): Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment: a. As of December 21, 2015, the employer did not establish and implement specific written mechanical integrity procedures for inspecting, testing, and maintaining the ongoing integrity of all relief system components, vent systems and devices, including but not limited to the following: Inspection and testing of over-pressure protection systems and components (e.g. pressure safety valves, rupture disks, Durabla/DFT check valves, Protectoseal pressure/vacuum conservation vents, piping associated with relief devices and structural support members) for covered process vessels; including the types of tests performed on existing equipment; criteria for replacement and repair, inspection and testing schedule and the appropriate designated methodologies for the inspection/test. b. As of December 21, 2015, the employer did not establish and implement specific written mechanical integrity procedures for inspecting, testing, and maintaining the ongoing integrity of piping systems and valves, including but not limited to the following: inspection and testing criteria, inspection and testing schedules, inspection criteria for corrosion under insulation, thickness measurement strategy, quality assurance criteria for inspecting and examining welds, welders performance qualifications, and criteria for resolving anomalous inspection data related to thickness growth. c. As of December 21, 2015, the employer did not establish and implement specific written mechanical integrity procedures for inspecting, testing, and maintaining the ongoing integrity of process vessels, including but not limited to the following: inspection and testing criteria, inspection criteria for corrosion under insulation, thickness measurement strategy, quality assurance criteria for inspecting and examining welds, welders performance qualifications, and criteria for resolving anomalous inspection data related to thickness growth. d. As of December 21, 2015, the employers written Inventory Control System (SOP #16002) dated August 7, 2012, was not adequate, in that the MP2 software, the old computerized maintenance management system, had not been updated with the TabWare software currently being used. e. As of December 21, 2015, the employer did not establish and implement specific written mechanical integrity procedures for quality assurance to assure that equipment, maintenance materials, and spare parts were suitable for the process application for which they would be used; did not assure that new equipment as it was fabricated was suitable for the process application for which it was used; and did not assure appropriate checks and inspections were performed to ensure equipment was installed properly and consistent with design specifications and the manufacturer's instructions.