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

29 CFR 1910.119(d)(3)(ii): Process Safety Information. The employer shall document that equipment complies with recognized and generally accepted good engineering practices: The employer did not document, compile and maintain information regarding recognized and generally accepted good engineering practices (RAGAGEP) compliance for the following process equipment, including but not limited to: a. Chlorination department: The 4R reactor did not meet RAGAGEP, in that the U-1 data sheet was missing. b. Phosphites department: 133T tank did not meet RAGAGEP, in that the U-1 data sheet is missing. c. Chlorination department: 2R reactor did not meet RAGAGEP, in that the vessel U-1 data sheet was missing. d. Phosphites department: 38R receiver did not meet RAGAGEP, in that the vessel U-1 data sheet was missing. e. Chlorination department: 45R receiver did not meet RAGAGEP, in that the vessel U-1 data sheet was missing. f. Phosphites department: E-105 (the 35R primary condenser) did not meet RAGAGEP in that the vessel U-1 data sheet was missing. g. Phosphites department: E-373 (the 72R condenser) did not meet RAGAGEP, in that the vessel U-1 data sheet was missing. h. Phosphites department: E-375 (the 72R alcohol preheater) did not meet RAGAGEP in that the vessel U-1 data sheet was missing. i. Chlorination department: 58R receiver did not meet RAGAGEP in that the vessel U-1 data sheet was missing. j. Phosphites department: The 36R reactor did not meet RAGAGEP, in that relief system design and design basis selected for the reactor resulted in incorrect sizing of the pressure relief valve. The worst case scenario basis used for this design was prompt firefighting. The fire scenario was used for the other reactors in building 27. The use of the prompt firefighting scenario resulted in relief device sizing that is approximately 60% of the fire sizing calculation; thus the relief valve was undersized. Additionally, a rupture disk was installed that exceeded the designated pressure set point for this relief system design. k. Phosphites department: The 133T phosphorous trichloride (PCl3) storage tank did not meet RAGAGEP, in that the relief device (pressure relief valve) was not designed to vent to a safe location. In the event of actuation, the relief device would vent to an aqueous scrubber that has not been evaluated and documented to safely contain a designated worst case basis scenario for this device. Phosphorous trichloride properties include water reactivity with a highly exothermic, rapidly expanding evolution of acidic gas. l. Chlorination department: The 200T Bromine storage tank did not meet RAGAGEP, in that the relief device (pressure relief valve) was not designed to vent to a safe location. In the event of actuation, the relief device would vent to a caustic scrubber that had not been evaluated and documented to safely contain a designated worst case scenario for this device. Bromine interacting with 25% sodium hydroxide solution would result in a highly exothermic reaction event. m. Process piping, including but not limited to the following phosphites and chlorination department processes, did not meet RAGAGEP, in that an inappropriate design code (ASME 31.1) was compiled in PSI as design code for process piping: Chlorination 20 reactor process, Chlorination 18R/19R reactor process, Chlorination 49R reactor process, Chlorination 45R reactor and 1P acid absorber system process, 34R reactor process, 35R reactor process and 44R reactor process. n. Phosphites department: The 32R reactor did not meet RAGAGEP, in that a rupture disk was installed that exceeded the designated pressure set point for the relief design.