Examples of equipment cited for violations of the PSM MI requirements that OSHA found during NEP inspections include:
- A broken gate valve caused a level gauge to not work properly, which rendered visual verification of liquid level for the vessel ineffective. This deficiency went uncorrected.
- The installation of an engineered clamp failed to correct a deficient piece of process piping, which was a 90-degree elbow that was outside acceptable limits. The employer continued to use the leaking 90-degree elbow as part of a piping circuit that conveyed waste hydrogen sulfide gas.
- Hydrogen sulfide monitors were not inspected and tested on a regular basis to correct deficiencies in alarms that were outside acceptable limits due to bad sensors, loose wiring, or monitors that needed to be replaced. Work orders were not managed by a tracking system to ensure that deficiencies were fixed in a timely manner. Some work orders marked “fix today” or “ASAP” were not fixed for a week or longer.
- Six relief systems in an alkylation unit were incorrectly sized and were not corrected in a timely manner when the deficiencies were reported. No Management of Change (MOC) was performed to justify the decision to delay replacing the deficient systems.
- Grounding cables were removed from equipment, such as a heat exchanger and pump motors, but were not replaced.
- Excessive vibration was observed on motors with visible movement of structural steel decking and supports. Also, two 1” pipes and one 4” pipe containing flammable liquid were not adequately supported
Source: Osha.gov
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