Text For Citation: 01 Item/Group: 009 Hazard:

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers' recommendations and good engineering practices (REGAGAP), and more frequently if determined to be necessary by prior operating experience. (a) The employer did not ensure annual visual inspections of the Safety Instrumented Systems for phenol 2 and 3 were performed on a periodic basis according to ANSI/ISA 84 section 16.3.2 which states that SIS systems must periodically visually inspected to ensure there are no unauthorized modifications and observable deterioration to system components. (HAV-PH2-PRO-025) (b) The employer did not ensure the inspection frequencies for pumps located in the phenol processing area and the logistics department were based on CCPS Guidelines for Mechanical Integrity Systems 2006 ed. which states on page 172 that pumps are required to have vibration analysis performed weekly to quarterly, rotational checks performed weekly to monthly, analysis of gear box and bearing lubricant performed monthly to semi-annually. (c) The employer did not conduct internal inspections of vessel 3301-E, a crude acetone column located in the Phenol 2 unit that is approximately 200 feet tall, with 97 thickness management locations (TML) for testing on the vessel and 32 of the testing points were past due for inspection every 10 years according to API 510. (Haverhill document HAV-MI-PRO-0591 states that ultrasonic inspections shall be made either internal or external.) (d) The employer did not conduct internal inspections of vessel 3307-E, a phenol finishing column located in the Phenol 2 unit, that is approximately 62 feet tall and is lined with stainless steel cladding, with 71 TML testing locations on the vessel and 34 of the testing points were past due for inspection every 10 years according to API 510. (e) The employer did not conduct internal inspections of vessel 3307-E, a hydrocarbon removal column located in the Phenol 2 unit, that is approximately 134 feet tall and is lined with stainless steel cladding, with 127 TML testing locations on the vessel and 17 of the testing points were past due for inspection every 10 years according to API 510. (f) The employer did not conduct internal inspections of vessel 3301-D, a phenol resin bed located in the Phenol 2 unit and is approximately 18 feet tall, unclad, with 21 TML testing locations on the vessel and 1 of the testing points on the shell was past due for inspection every 10 years according to API 510. (g) The employer did not ensure that approximately 1000 piping inspections, for piping segments and inspection points containing the Class I flammable chemicals acetone, cumene hydrogen peroxide and cumene, were conducted at intervals according to API 570 and Haverhill Mechanical Integrity piping procedures. 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.