Text For Citation: 01 Item/Group: 003 Hazard: EXPLOSION

29 CFR 1910.119(d)(3)(i)(B). The employer did not compile process safety information which included accurate piping and instrument diagrams (P&IDs): (a)Suncor Energy (U.S.A.), Inc., 5801 Brighton Blvd., Commerce City, Colorado: On or about October 2, 2008, and at times prior thereto, P&ID DR-13-PI-030 incorrectly illustrates the pressure relief flow from RV829 (relieving D-77) as from "FROM D-77 RV-516" when RV-516 does not exist. This does not appear to present a serious hazard for employees. (b)On or about October 8, 2008, and at times prior thereto, P&ID DR-13-PI-010 illustrates the two 8-inch and two 6-inch isolation valves in the piping between the tube side outlet of X-338 and inlet of D-77 as being "LO" which means the valves are supposed to be "locked open." On October 8, 2008, and at prior times thereto, these valves were not locked open as illustrated on the P&ID. Employees are exposed to hazards related to fires and explosions due to the potential for overpressurization of pressure vessels containing hydrocarbons such as X-338 due to these valves not being locked open as indicated on the P&ID. (c)On or about November 4, 2008, and at times prior thereto, P&ID DR-13-PI-020 illustrates that the 4-inch isolation valve on the outlet of X-16 shell side is "LO" which means the valve is supposed to be "locked open." On November 4, 2008, and at prior times thereto, this valve was not locked open as illustrated on the P&ID. Employees are exposed to hazards related to fires and explosions due to the potential for overpressurization of pressure vessel X-16 due to these valves not being locked open as indicated on the P&ID. (d)On or about November 4, 2008, and at times prior thereto, P&ID DR-13-PI-020 illustrates numerous isolation valves as not being locked open when such valves are locked open. On November 4, 2008, and at times prior thereto, the following isolation valves were observed as being locked open when the P&ID illustrates otherwise: on the inlet piping to X-327 shell side, outlet piping of X-328 shell side, inlet and outlet piping of X-339 shell side, outlet piping of X-165 shell side, outlet piping of X-8 tube side, inlet and outlet piping of X-7 tube side, and inlet and outlet of X-16 tube side. In the event of an emergency, employees are subject to hazards related to fire and explosion due to misinformation about the actuation potential of isolation valves. (e)On or about September 25, 2008, and at times prior thereto, P&ID DR-13-PI-020 wrongly identifies the outlet piping for crude from X-30 tube side as a Cooling Water Return pipe (WH) instead of as a crude oil pipe (HC). Employees are exposed to hazards related to fires and explosions due to the potential for employees to misidentify the fluid in the piping. (f)On or about September 25, 2008, and at times prior thereto, P&ID DR-13-PI-020 wrongly identifies the inlet piping for crude into X-30 tube side as 8- inch diameter instead of 6-inch diameter. Employees are potentially exposed to hazards related tofires and explosions due to the potential for employees to misidentify a piping circuit. (g)On or about December 12, 2008, and at times prior thereto, P&ID DR-13-PI-090 wrongly identifies the speed control inputs for P-188 and P-652 as "LP" instead of "LY". LP is not listed in the legend shown on DR-00-LG-040. There is no readily apparent employee hazard associated with this instance. One feasible means of abatement would be for the Employer to ensure that its P&IDs in the process safety information are accurate and updated. Abatement Note: Abatement certification is required for this item (see enclosed "Sample Abatement-Certification Letter").