Text For Citation: 02 Item/Group: 001 Hazard:

29 CFR 1910.119(d)(3): Information pertaining to the equipment in the process. 29 CFR 1910.119(d)(3)(ii):The employer shall document that equipment complies with recognized and generally accepted good engineering practices. The employer does not protect employees from hazards associated with the catastrophic release of hazardous chemicals from the kettle 3 reactor vessel covered process by failing to comply with the OSHA PSM standard for complying with regularly and generally accepted good engineering practices. a. This most recently occurred on April 8, 2021, the employer failed to document that the alteration of an ASME BPVC section VIII pressure vessel, the kettle 3 reactor vessel, was performed in compliance with recognized and generally accepted good engineering practices (RAGAGEP) such as, but not limited to, American Petroleum Institute (API) 510 (2014) Pressure Vessel Code: In-service Inspection, Rating, Repair and Alteration, Section 8.1.1 General - performed in accordance with ASME code; section 8.1.2 Authorization, Section 8.1.3. Approval, 8.1.4 Design, 8.1.7.2, Procedures, Qualifications, and Records, and 5.8 Pressure Testing. The kettle 3 reactor vessel alteration involved the installation of a new manway opening, the installation of nozzle and the alteration of the existing manway. The employer failed to require the alteration to be performed by and fabricated by a pressure vessel repair organization with a certificate of authorization, failed to verify the qualifications of welders and failed to use qualified welders for the alteration. Additionally, the employer failed to have the work authorized and hold points designated by the authorized inspector, failed to have methods of design, welding procedures, nondestructive examination and testing approved by the authorized inspector and failed to have pressure testing performed. The employer failed to document the alteration. 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. b. This most recently occurred on April 8, 2021, the employer failed to document that the kettle 3 reactor vessel, an ASME BPVC section VIII pressure vessel, complied with recognized and generally accepted good engineering practices (RAGAGEP) related to "de-rating" or rerating the vessel, such as, but not limited to, American Petroleum Institute (API) 510 (2014) Pressure Vessel Code: In-service Inspection, Rating, Repair and Alteration, Section 8.2.The employer did not rerate/"de-rate" the vessel according to the code of construction and stated that it had derated the vessel to a non-code vessel, but failed to take actions per the vessel's construction code, the 1959 American Society of Mechanical Engineers Boiler and Pressure Vessel Code section VIII; and the 2019 American Society of Mechanical Engineers Boiler and Pressure Vessel Code section VIII that would have actually "derated" the kettle 3 reactor vessel. In particular, the employer failed to replace the pressure vessel's rupture disk that was set to burst at a pressure greater than 15 psig with a rupture disk with a specified burst pressure rating less than 15 psig. 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.