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

29 CFR 1910.119(j)(4)(ii):Inspection and testing procedures did not follow recognized and generally accepted good engineering practices. a. On or about and prior to April 8, 2021, inspection and testing procedures failed to follow recognized and generally accepted good engineering practices (RAGAGEP) for the kettle 3 reactor vessel internal inspections. Internal inspections were performed without equipment specific inspection plans, without previous inspection thickness measurements use for corrosion rates and without the determination inspection frequency from vessel remaining life based calculations according to RAGAGEP, such as but not limited to, American Petroleum Institute (API) 510 (2014) Pressure Vessel Code: In-service Inspection, Rating, Repair and Alteration, Section 5, Inspection, Examination, and Pressure Testing Practices. b. On or about and prior to April 8, 2021, inspection and testing procedures did not follow RAGAGEP for the pressure relief system for reactor vessel 3, in that the rupture disk inspection was not documented. The work order for the scheduled mechanical integrity inspection was recorded on the employer's work order number PM021601 and was closed on January 5, 2021. The employer failed to document the person who performed the inspection, failed to document the date of the inspection, failed to document any identifying information for the rupture disk and failed to document the result of the inspection. The pressure relief device inspection was not documented according to, and failed to follow RAGAGEP, such as but not limited to, American Petroleum Institute (API) 510 (2014) Pressure Vessel Code: In-service Inspection, Rating, Repair and Alteration, Section 7.8, Reports and Records. c. On or about and prior to April 8, 2021, inspection and testing procedures did not follow RAGAGEP when the employer failed to document the inspection and testing related to the installation of pressure vessels; such as the kettle 3 reactor vessel system Bubble Cap Column. The employer failed to document any testing or inspections for the installation of process equipment into the covered process and failed to follow RAGAGEP, such as but not limited to, American Petroleum Institute (API) 510 (2014) Pressure Vessel Code: In-service Inspection, Rating, Repair and Alteration, Section 6.2.1, Vessel Installations. d. On or about and prior to April 8, 2021, inspection and testing procedures did not follow RAGAGEP when the employer failed to document the inspection and testing related to the installation of pressure vessels; such as the kettle 3 reactor vessel system K3 Total Condenser. The employer failed to document any testing or inspections for the installation of process equipment into the covered process and failed to follow RAGAGEP, such as but not limited to, American Petroleum Institute (API) 510 (2014) Pressure Vessel Code: In-service Inspection, Rating, Repair and Alteration, Section 6.2.1, Vessel Installations . e. On or about and prior to April 8, 2021, inspection and testing procedures for process piping in high temperature kettle systems did not follow RAGAGEP. Process piping inspections were performed without detailed inspection plans, without providing piping records and previous inspection information to the inspector and without the performance of remaining life calculations according to RAGAGEP, such as but not limited to, API 570 (2016) Piping Inspection Code: In-service Inspection, Rating, Repair, and Alteration of Piping Systems, section 5 Inspection, Examination, and Pressure Testing Practices, section 6, Interval/Frequency and Extent of Inspection and section 4.3. Owner/User Organization - Responsibilities. f. On or about and prior to April 8, 2021, inspection and testing procedures did not follow RAGAGEP when the employer failed to inspect, test, maintain and repair process piping for the new Total Condenser installation according to RAGAGEP. The employer failed to document any testing or inspections for the installation of process piping related to the new Total Condenser installation and failed to follow RAGAGEP, such as but not limited to, API 570 (2016) Piping Inspection Code: In-service Inspection, Rating, Repair, and Alteration of Piping Systems, section 6.2.1, Inspection During Installation and Service Changes - Piping Installation.