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Violation Detail
Standard Cited: 19100119 J04 II Process safety management of highly hazardous chemicals.
This violation item has been deleted.
Inspection Nr: 1312089.015
Citation: 01002
Citation Type: Serious
Abatement Status:
Initial Penalty: $12,934.00
Current Penalty: $0.00
Issuance Date: 10/02/2018
Nr Instances: 2
Nr Exposed: 6
Abatement Date: 11/20/2018
Gravity: 10
Report ID: 0626700
Contest Date: 10/09/2018
Final Order: 04/04/2019
Related Event Code (REC):
Emphasis:
| Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
|---|---|---|---|---|---|---|
| Penalty | F: Formal Settlement | 04/04/2019 | $0.00 | 11/20/2018 | Serious | |
| Penalty | C: Contested | 10/12/2018 | $12,934.00 | 11/20/2018 | Serious | |
| Penalty | Z: Issued | 10/02/2018 | $12,934.00 | 11/20/2018 | Serious |
Text For Citation: 01 Item/Group: 002 Hazard:
29 CFR 1910.119(j)(4)(ii): Inspection and testing procedures did not follow recognized and generally accepted good engineering practices (RAGAGEP). Instance a) On or about April 19, 2018 in the HF Alkylation at Valero Refinery located in Texas City, Texas, the employer did not follow its chosen RAGAGEP when it failed to perform a Fitness for Service assessment on the Main Fractionator piping (10"-PF1003-BCA) to determine if the piping could continue service or whether it needed to be replaced after inspections revealed that 090NE and 080NE CML's would reach their alert thicknesses by 2017. API 570 (2016), Section 7.7 requires employers to evaluate pressure containing parts (e.g. piping) for continued service or removal that are found to be degraded (e.g. corroded and/or thinning piping). Additionally, API 574 (2016), Section 12.1.5 indicates that a remaining life assessment (e.g., Fitness-for-service evaluation) is needed when alert thicknesses have been reached. Instance b) On or about April 19, 2018 in the HF Alkylation Unit at Valero Refinery located in Texas City, Texas, the employer did not follow its chosen RAGAGEP (API 570 and 574) when it failed to establish more than one CML which would have allowed for appropriate monitoring in the form of additional thickness measurements on the Main Fractionator 120 feet vertical straight run piping (10" -PF1003-BCA). The upstream and downstream piping to piping section, 10 "-PF1003-BCA were replaced in 1995 due to corrosion. API 570 (2016), Section 5.6.2 requires that piping systems shall be monitored at appropriately placed CMLs and also states that piping circuits subject to higher corrosion rates or localized corrosion (e.g., piping section 10" -PF1003-BCA) will normally have more CMLs and be monitored more frequently. API 574 (2016) Section 7.4 indicates if an inspection of an area of piping indicates damage is occurring, the piping upstream and downstream of this area, along with associated equipment, should also be inspected.