Text For Citation: 01 Item/Group: 001A Hazard:

29 CFR 1910.119(f)(1)(i)(B): The employer did not develop and implement written operating procedures that provided clear instructions for conducting activities during normal operations in PSM covered processes: Suncor Energy Inc, at 5801 Brighton Boulevard, Commerce City, CO: On and preceding 3/13/12, Suncor Energy Inc did not develop and implement written operating procedures that provided clear instructions for conducting activities during normal operations in PSM covered processes. Tank T-400, which contained approximately 1.4 million pounds of liquefied petroleum gas (LPG), was located in Unit 41. Outside operators, as part of their daily duty, performed a "water draw". A "water draw" removed water that collected at the bottom of T-400 and directed the water and residual LPG down pipeline 506 to a knockout drum and flare. Suncor Energy Inc did not develop and implement written operating procedures for performing a "water draw". Suncor Energy Inc, at 5801 Brighton Boulevard, Commerce City, CO: On and preceding 3/13/12, Suncor Energy Inc did not develop and implement written operating procedures that provided clear instructions for conducting activities during normal operations in PSM covered processes. Tank T-400, which contained approximately 1.4 million pounds of liquefied petroleum gas, was located in Unit 41. A single temperature indicator was T-400's element in the Critical Alarm System. Operators utilized the exterior water deluge system to cool T-400 when interior temperature approached T-400's safe operating limit for temperature (115F). Suncor Energy Inc did not develop and implement written operating procedures for utilizing the exterior water deluge system to cool T-400 during normal operations.