Text For Citation: 01 Item/Group: 002 Hazard: REFINERY

SAVE: 29 CFR 1910.119(d)(3)(i)(B): The employer did not complete a compilation o f written process safety information before conducting any process hazard analys is required by the standard, including accurate Piping and Instrument Diagrams. The employer does not maintain P&IDs so that they accurately reflect the equipme nt of the process. A.This violation was observed on or about March 1, 2010 when it was noted that P&ID 18-E-54-3000 did not show relief valve 18-RV-02 on the Re actor Product Condenser (18-EX-02) and that P&ID 19-E-54-1000 did not show relie f valve 19-RV-05 on the South Drum (19-PV-01A). The list of relief valves provid ed by the employer indicates that there are relief valves on both of these vesse ls. Field inspections verified that the Reactor Product Condenser, and South Dru m do indeed have relief valves. The P&IDs were field verified by the employer on 03/17/2009. B.This viol ation was observed on or about March 3, 2010 in the Platformer Unit when it was noted that PSV 1912 appears on P&ID 19-E-54-4000 although it has been removed fr om service. Inaccurate information that is relied upon could expose employees to fire and explosion hazards. Pursuant to 29 C. F. R. 1903.19, within ten (10) ca lendar days of the date of this citation, the employer must submit documentation that it is in compliance with the standard, including describing the steps it i s taking to ensure process safety information is available for all refinery equi pment. One method of abatement among others is to have someone walk down the uni t piping and verify what is there and add what is missing.