Text For Citation: 01 Item/Group: 005 Hazard:

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment. (a) The employer did not establish and implement written procedures for maintaining the mechanical integrity of the process for Haverhill in-house maintenance employees and contracted maintenance employees to follow for performing routine job tasks that were not classified as preventive or predictive maintenance, such as but not limited to replacement of Teflon expansion joints made by Ethylene that failed and fabrication of pipe spools of Teflon lined pipe that were out of alignment. (b) The employer did not implement written procedures for maintaining the mechanical integrity of the process as found in API Recommended Practice 574 and the employer's Mechanical Integrity Program for inspection of expansion joints (HAV-MI-PRO-0507) in that; 1. Expansion joints were not regularly inspected; 2. Expansion joints that were insulated did not have all of the insulation removed for inspection and were not inspected unless visible leaks were detected through the insulation; 3. Expansion joint safety shields were not used for personnel protection. (c) The employer did not establish and implement written procedures for maintaining the mechanical integrity of Teflon lined piping in the Phenol and BPA units, as they did not perform non-destructive testing on lined piping, and did not follow the manufacturer's recommendations for flange bolt torquing, retorquing, hydrotesting, annual retorquing and pressure testing of Restoflex PTFE Lined Piping Products. (d) The employer's vibration analysis program HAV-MI-PRO-0509 did not contain written procedures for performance of vibration analysis on rotating equipment in the Phenol processing unit and the logistics unit. (e) The employer's HAV-PSM-PRO-008, Predictive/Preventive Maintenance Procedure PPM #101did not contain written procedures for performing daily inspections of pumps in areas of the facility such as the logistics unit and the phenol processing unit. (f) The employer did not establish and implement written procedures for performing internal inspections on pumps located in the Phenol processing unit and the logistics unit (HAV-PSM-PRO-008, Predictive/Preventive Maintenance Procedure PPM #101). (g) The employer did not establish and implement written procedures for conducting external pumps inspections in the Phenol processing unit and the logistics unit. (h) The employer did not establish and implement written procedures for increasing or decreasing inspection intervals of process equipment, such as but not limited to piping, pressure vessels, pumps, and pressure relief valves. (i) Procedures that provide clear instructions for safely conducting activities associated with draining the Primary Reactors including Reactor R-109, in that the existing procedures (SJP G-26-a, SJP R-101-b) did not address the special hazards of leaking expansion joints in the reactor dump lines and the need for safety shields surrounding the expansion joints in the event they did leak or fail and the corresponding precautions necessary to prevent employee exposure to hot process chemicals, such as phenol, BPA, acetone and hydrochloric acid. (j) The employer did not establish and implement written procedures for the installation and maintenance of expansion joint covers used for personnel protection. (k) The employer did not establish and implement written procedures for contractors who were hired to patch the glass linings of reactor vessels. In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification. This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.