Mechanical Integrity - Piping Support Issues Sample Clauses

Mechanical Integrity - Piping Support Issues. The first area of concern relates to piping support issues in oleum piping associated with tanks VT-518 and VT-519, and ammonia piping associated with atmospheric tank VT-520 and Xxxxxx Spheres HST-1 and HST-2, as well as the general failure to address piping equipment deficiencies. In the Facility’s Marine Operations area, EPA inspectors observed that the piping associated with oleum tanks VT-518 and VT-519 was not properly supported in several locations. Specifically, piping was suspended from other pipes with hangers, which were carrying too much load, causing the pipes carrying the load to bend under pressure. In the Facility’s Xxxxxxx Unit around ammonia tank VT-520, EPA inspectors observed piping support brackets rising from ammonia pipes to support other ammonia pipes, wooden block piping supports, cinder block piping supports, and piping with missing insulation jackets. In the piping associated with ammonia-filled Xxxxxx Spheres HST-1 and HST-2, EPA inspectors observed piping lying atop other piping, piping on the ground, piping with missing jackets, piping supporting other pipes with cuts into insulation jackets, and piping with no insulation protective xxxxxxx on the piping where hangers were located. Support issues with the oleum and ammonia piping have existed at the Facility and were known to AdvanSix for some time. According to an AdvanSix 2016 inspection report for oleum tanks VT-518 and VT-519, inspectors observed broken pipe hangers and hangers being used inappropriately in vertical locations. The Facility’s piping inspection report from 2015 for piping associated with tank VT-520 similarly describes “corroded/damaged or missing pipe supports,” and improper wood block supports for pipes. The same conditions were present in 2020 for tank VT-520, with descriptions including “rope supports, “damaged hanger,” “wire hanger,” “loose support,” “needs support,” “pipe resting on ground,” “pipe resting on rock/conduit,” “damaged pipe support,” “corroded supports,” “pipe supporting other pipe,” “piping not in contact with support,” and “pipe supported by wood.” Industry standard API RP 574 sets forth inspection practices for piping systems. With respect to supports it states, “External visual inspections are performed to determine the external condition of
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