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

29 CFR 1910.119(d)(3)(i)(B): Information pertaining to the equipment in the process did not include accurate piping and instrument diagrams (P&ID's): a) On or about May 14, 2012 and times prior, the employer's piping and instrument diagrams (P&ID's) were not accurate and did not reflect equipment that was existing in the actual process including, but not limited to, the following: 1. P&ID FS-105A showed a valve upstream of PSV 511A where there was no actual valve in the process. 2. P&ID FS-105A did not show two (2) drain valves and two (2) flanges on the waste gas stream line which are in place in the actual process. 3. P&ID FS-106 showed two (2) 4 inch valves on an inlet line and discharge line to S-101 in the "locked open" position where these were operational valves and were not locked open in the actual process. 4. P&ID FS-106 did not show a second ball valve and piping connected to a 3/4 inch gate valve on the NGL discharge line upstream of FE-615 that was in place in the actual process. 5. P&ID FS-106A showed a PSV 639 when the PSV was labeled as PSV 646 in the actual process. 6. P&ID FS-110 showed F-102 with a discharge line going from PSV 1039 venting to atmosphere where the actual process had the discharge line going from PSV 1039 to a "rich amine line" and not to atmosphere. 7. The symbol for pressure safety valve in the P&ID legend did not accurately reflect the symbol for PSV used throughouth all the P&IDs. The symbol for a regular angle valve was used in many cases as the symbol for a PSV. Abatement Note: Abatement certification and documentation is required for this item (see enclosed "Certification of Corrective Action Worksheet").