Text For Citation: 01 Item/Group: 020 Hazard:

29 CFR 1910.119(j)(2):Written procedures. The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment. a. On or about and prior to April 8, 2021, the employer's written procedures for rupture disk inspection failed to address the training requirements, and failed to address qualifications and credentials of the individuals and organizations authorized by the employer to inspect, test, and repair relief devices in covered processes; including rupture disks in pressure relief systems, such as but not limited to the rupture disk for the kettle 3 reactor vessel. b. On or about and prior to April 8, 2021, the employer's written procedures for rupture disk inspection failed to address rupture disk burst sensors, failed to address verification of rupture disk set point with relief system design basis, did not include detailed instruction for relief vent piping visual inspection, failed to address criteria for failure/acceptance and did not include detailed instruction for rupture disk and holder component assembly, inspection and cleaning in pressure relief systems of covered processes, such as, but not limited to rupture disk inspections for the kettle 3 reactor vessel. c. On or about and prior to April 8, 2021, the employer's mechanical integrity program procedures for pressure relief devices failed to address inspection, replacement and repair of "OPW vents" in pressure relief systems for equipment in the covered process, such as but not limited to Scale Tank 7. d. On or about and prior to April 8, 2021, the employer's mechanical integrity program procedures for process vessels failed to address the repair, installation and alteration of covered process equipment; such as but not limited to gasket repair for manway leaks, the installation of new process pressure vessels and alteration of pressure vessels, such as but not limited to the kettle 3 reactor vessel alteration, the installation of the K3 Bubble Cap Column, the installation of the K3 Total Condenser and the associated manway repair for the kettle 3 reactor vessel. On April 8, 2021, the kettle 3 reactor vessel manway cover to manway flange gasket failed and released vapor into the kettle 3/kettle 4 room. This catastrophic failure resulted in the explosion event that resulted in a fatality and multiple disabling injuries. e. On or about and prior to April 8, 2021, the employer's mechanical integrity program for process vessels failed to address qualifications and credentials of the individuals and organizations performing testing/inspection; and the written program failed to address the development of specific inspection plans for process vessels in the covered process; to include the kettle 3 reactor vessel testing, inspection and inspection planning. f. On or about and prior to April 8, 2021, the employer's mechanical integrity program written procedures for process piping did not include the development of specific inspection plans for piping in Resin Plant covered processes.