Violation Detail
Standard Cited: 19100119 J04 II Process safety management of highly hazardous chemicals.
Inspection Nr: 451379.015
Citation: 01041
Citation Type: Serious
Abatement Status: Abatement Completed
Initial Penalty: $7,000.00
Current Penalty: $7,000.00
Issuance Date: 11/26/2012
Nr Instances: 21
Nr Exposed: 160
Abatement Date: 06/04/2014
Gravity: 10
Report ID: 0522500
Contest Date: 12/12/2012
Final Order: 03/10/2014
Related Event Code (REC):
Emphasis:
| Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
|---|---|---|---|---|---|---|
| Penalty | F: Formal Settlement | 03/13/2014 | $7,000.00 | 06/04/2014 | Serious | |
| Penalty | C: Contested | 12/19/2012 | $7,000.00 | 02/27/2013 | Serious | |
| Penalty | Z: Issued | 11/26/2012 | $7,000.00 | 02/27/2013 | Serious |
Text For Citation: 01 Item/Group: 041 Hazard:
29 CFR 1910.119(j)(4)(ii): Inspection and testing procedures shall follow recognized and generally accepted good engineering practices: Inspection and testing did not follow RAGAGEP for the following process equipment that includes but is not limited to: a. 72R reactor: A September 2011 inspection did not document the certification of the inspector, data was not documented in a manner that would allow consistent location on the vessel for future thickness measurements, corrosion rates were not calculated from the data, and the data was not compared to required thickness or minimum thickness values for this vessel. b. 75R reactor: A September 2011 inspection did not document the certification of the inspector, data was not documented in a manner that would allow consistent location on the vessel for future thickness measurements, corrosion rates were not calculated from the data, thickness measurements were taken for the jacket only (not the vessel shell) and the data was not compared to required thickness or minimum thickness values for this vessel. c. 2R reactor: A January 2010 internal inspection did not document the certification of the inspector. A January 2009 inspection did not include thickness measurements for nozzles. d. 1R reactor: A December 2009 internal inspection did not include spark (holiday) testing of the glass lining for the inner chamber of this vessel. The December 2009 inspection and the previous May 2008 inspection did not provide for an evaluation or testing of the weld from the jacket to the surface of the reactor chamber. e. 4R reactor: A 2002 internal inspection did not document the certification of the inspector, corrosion rates were not calculated from thickness measurement data and the data was not compared to required thickness or minimum thickness values for this vessel. For a May 2008 external inspection, corrosion rates were not calculated from thickness measurement data and the data was not compared to required thickness or minimum thickness values for this vessel. For an August 2010 internal inspection, calculations for required thickness or minimum thickness were not provided with the calculated values and thickness measurement data was not documented in a manner that would allow consistent location on the vessel for future thickness measurements. f. 5R reactor: An August 2010 inspection did not include calculations for required or minimum thickness values and thickness measurements were not taken for nozzles. g. 34R reactor: A January 2011 inspection did not document specific thickness measurements taken for the bottom jacket head on the knuckle radius and on the crown. This data was not documented in a manner that would allow consistent location on the vessel for future thickness measurements and calculations for required thickness or minimum thickness were not provided with the calculated values. h. R-032-01 (20 reactor -chlorination): A May 2008 inspection did not document the calculations for the calculated required or minimum thickness values for the reactor. i. 19R reactor thickness measurements taken during a May 2008 inspection did not include nozzle thickness measurements. Additionally, the inspection record did not document calculated required or minimum thickness values for the reactor for which a reactor inner chamber bottom head thickness measurement taken was below the manufacturer's minimum thickness value. j. 18R reactor for thickness measurements taken during an August 2011 inspection: The data was not documented in a manner that would allow consistent location on the vessel for future thickness measurements, and calculations for the calculated required or minimum thickness values for the reactor were not documented. k. 35R reactor for thickness measurements taken during an October 2010 inspection: The data was not documented in a manner that would allow consistent location on the vessel for future thickness measurements. Additionally for an August 2010 inspection, specific thickness measurements were summarized rather than being comprehensively documented for each thickness measurement location. l. 38R receiver for thickness measurements taken during an August 2010 inspection: The data was not documented in a manner that would allow consistent location on the vessel for future thickness measurements, corrosion rates were not calculated from thickness measurement data, the data was not compared to required thickness or minimum thickness values for this vessel and thickness measurements were not taken for the vessel inner chamber shell. m. 39R reactor for thickness measurements taken during an August 2010 inspection: The data was not documented in a manner that would allow consistent location on the vessel for future thickness measurements, calculations for the calculated required or minimum thickness values for the reactor were not documented, corrosion rates were not calculated from thickness measurement data, the data was not compared to required thickness or minimum thickness values for this vessel and specific thickness measurements were summarized rather than being comprehensively documented for each thickness measurement location. n. 40R reactor for thickness measurements taken during a May 2008 inspection: The data for the inner chamber shell, top and bottom heads was not documented in a manner that would allow consistent locations on the vessel for future thickness measurements and corrosion rates were not calculated with inner chamber thickness measurement data. o. 41R reactor: An August 2011 inspection did not document the calculations for the recalculated required, or minimum thickness values for the reactor. p. 48R reactor: A January 2011 inspection did not include nozzle thickness measurements. q. 51R reactor: A May 2008 internal inspection did not include spark (holiday) testing of the glass lining for the inner chamber of this vessel. The May 2008 inspection and an August 2011 inspection did not provide for the evaluation or testing of the weld from the jacket to the surface of the reactor chamber, or thickness measurement testing for nozzles. r. 52R reactor: An August 2011 inspection report did not include and document calculations for required or minimum thickness values used to reduce the manufacturer's minimum required thickness. Additionally the results section of the report was inaccurate in that it reported all jacket thickness measurements above the manufacturer's tolerances, when three data points for thickness data were below the manufacturer's stated minimum thickness value. s. 58R reactor: An August 2011 inspection did not include thickness measurements for the vessel inner chamber, the nozzles, and the welded connections between the jacket and the exterior reactor surface were not evaluated. Additionally calculations for conservative value minimum thickness were not provided or documented. t. 133T storage tank: An August 2010 inspection did not compare each thickness measurement to previous measurements and required thickness values or minimum thickness values, for the determination of corrosion rates and remaining vessel life. Additionally, data was not documented in a manner that would allow consistent location on the vessel for future thickness measurements. u. For 29 piping inspections in chlorination and one piping inspection performed on the supply line to the 133T storage tank performed September 2011, inspection and testing did not meet RAGAGEP in that the piping inspector was not API 570 certified or otherwise qualified.
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