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

29 CFR 1910.119(d)(3)(ii): The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices (RAGAGEP): a) Sunoco, Inc. Marcus Hook Refinery , 10-4 FCCU - The employer did not document compliance with API Recommended Practice 612 Petroleum, Petrochemical and Natural Gas Industries-Steam Turbines- Special Purpose Applications, Section 12.2, as evidenced by the lack of a digital turbine governor on the Elliott 2EPG7 Steam turbine. Condition noted on or about March 10, 2009. b) Sunoco, Inc. Marcus Hook Refinery , 10-4 FCCU - The employer did not document compliance with API Recommended Practice 617 Axial and Centrifugal Compressors and Expander-compressors for Petroleum, Chemical and Gas Industry Services, Section 3.4; Gas Machinery Research Council Southwest Research Institute, "Application Guideline For Centrifugal Compressor Surge Control Systems", Section 3.3.9; and ASME B19.3b Safety Standard for Compressors for Process Industries, as evidenced by the lack of effective and process integrated surge control on the Clark 4114 centrifugal compressor. Condition noted on or about March 10, 2009. c) Sunoco, Inc. Marcus Hook Refinery , 10-4 FCCU - The employer did not document compliance with API Recommended Practice 553 Refinery Control Valves, Section 5, as evidenced by the ineffective operation and inaccessible location of the 10-4 Wet Gas Compressor Discharge valve at the Exchangers. Condition noted on or about January 29, 2009. d) Sunoco, Inc. Marcus Hook Refinery , 10-4 FCCU - The employer did not document compliance with API Recommended Practice 553 Refinery Control Valves, Section 5, as evidenced by the ineffective operation and inaccessible location of the 10-4 Wet Gas Compressor By-Pass valve. Condition noted on or about March 10, 2009. e) Sunoco, Inc. Marcus Hook Refinery , 10-4 FCCU - The employer did not document compliance with API Recommended Practice 553 Refinery Control Valves, Section 5, as evidenced by the lack of platform or ladder at the manual by-pass valve and TC-537 control valve. Condition noted on or about March 10, 2009. f) Sunoco Inc. Marcus Hook Refinery, 15-2 & 15-2B Alkylation Unit - The employer did not document compliance with RAGAGEP. The employer's stated RAGAGEP was Sunoco Portable Buildings & Alternative Enclosures Procedure, Document No. PSM-122. This procedure referred to API 753 as a source standard. A portable tool trailer, owned by J.J. White Incorporated, was placed within an area of the 15-2 & 15-2B alkylation unit which had potential exposure to a maximum over pressurization of 5 or more pounds per square inch (psi) during a vapor cloud explosion. The trailer was occupied by an employee of J.J. White Inc. The trailer was not evaluated for occupancy or prevented from being occupied during its time atthis location. Condition noted on or about January 16, 2009. g) Sunoco Inc. Marcus Hook Refinery, The employer did not document compliance with RAGAGEP. The employer's stated RAGAGEP was API Recommended Practice 752 - "Management of Hazards Associated with Location of Process Plant Buildings". The following buildings were located in areas which had potential exposure to vapor cloud explosion. The buildings listed were not depopulated or structurally modified to withstand the anticipated pressures. Some buildings of such concern are, but are not limited to the following: g.1) Sunoco Inc. Marcus Hook Refinery, 10-4 FCCU - The employer did not document compliance with RAGAGEP. The employer's stated RAGAGEP was API Recommended Practice 752 - "Management of Hazards Associated with Location of Process Plant Buildings". The 10-4 Control Building was located in an area which had potential exposure to a maximum over pressurization of between 1 and 3 pounds per square inch (psi) during a vapor cloud explosion. The control building is an un- reinforced masonry bearing wall structure. API evaluates damage to such a structure, from partial collapse of walls to total destruction at the referenced pressures. The control building was not depopulated or structurally modified to withstand the anticipated pressure. Condition noted on or about January 22, 2009. g.2) Sunoco Inc. Marcus Hook Refinery, 15-1 Plant - The employer did not document compliance with RAGAGEP. The employer's stated RAGAGEP was API Recommended Practice 752 - "Management of Hazards Associated with Location of Process Plant Buildings". The 15-1 Control Building was located in an area which had potential exposure to a maximum over pressurization of between 3 and 5 pounds per square inch (psi) during a vapor cloud explosion. The control building is an un- reinforced masonry bearing wall structure. API evaluates damage to such a structure at total destruction at the referenced pressures. The control building was not depopulated or structurally modified to withstand the anticipated pressure. Condition noted on or about January 22, 2009. g.3) Sunoco Inc. Marcus Hook Refinery, 15-2 Plant - The employer did not document compliance with RAGAGEP. The employer's stated RAGAGEP was API Recommended Practice 752 - "Management of Hazards Associated with Location of Process Plant Buildings". The 15-2 Control Building was located in an area which had potential exposure to a maximum over pressurization of between 3 and 5 pounds per square inch (psi) during a vapor cloud explosion. The control building is an un- reinforced masonry bearing wall structure. API evaluates damage to such a structure at total destruction at the referenced pressures. The control building was not depopulated or structurally modified to withstand the anticipated pressure. Condition noted on or about January 22, 2009. g.4) Sunoco Inc. Marcus Hook Refinery, 12-3 Plant - The employer did not document compliance with RAGAGEP. The employer's stated RAGAGEP was API Recommended Practice 752 - "Management of Hazards Associated with Location ofProcess Plant Buildings". The 12-3 Control Building was located in an area which had potential exposure to a maximum over pressurization of between 1 and 3 pounds per square inch (psi) during a vapor cloud explosion. The control building is an un- reinforced masonry bearing wall structure. API evaluates damage to such a structure, from partial collapse of walls to total destruction at the referenced pressures. The control building was not depopulated or structurally modified to withstand the anticipated pressure. Condition noted on or about January 22, 2009. g.5) Sunoco Inc. Marcus Hook Refinery, 17-1 Plant - The employer did not document compliance with RAGAGEP. The employer's stated RAGAGEP was API Recommended Practice 752 - "Management of Hazards Associated with Location of Process Plant Buildings". The 17-1 Control Building was located in an area which had potential exposure to a maximum over pressurization of between 3 and 6.3 pounds per square inch (psi) during a vapor cloud explosion. The control building is an un-reinforced masonry bearing wall structure. API evaluates damage to such a structure at total destruction at the referenced pressures. The control building was not depopulated or structurally modified to withstand the anticipated pressure. Condition noted on or about January 22, 2009. g.6) Sunoco Inc. Marcus Hook Refinery, Ethylene Complex - The employer did not document compliance with RAGAGEP. The employer's stated RAGAGEP was API Recommended Practice 752 - "Management of Hazards Associated with Location of Process Plant Buildings". The Ethylene Complex Control Building was located in an area which had potential exposure to a maximum over pressurization of between 1 and 3 pounds per square inch (psi) during a vapor cloud explosion. The control building is an un-reinforced masonry bearing wall structure. API evaluates damage to such a structure, from partial collapse of walls to total destruction at the referenced pressures. The control building was not depopulated or structurally modified to withstand the anticipated pressure. Condition noted on or about January 22, 2009. g.7) Sunoco Inc. Marcus Hook Refinery, Mechanical Center - The employer did not document compliance with RAGAGEP. The employer's stated RAGAGEP was API Recommended Practice 752 - "Management of Hazards Associated with Location of Process Plant Buildings". Mechanical Center was located in an area which had potential exposure to an over pressurization of approximately 1 pound per square inch (psi) during a vapor cloud explosion. The building is a single story brick building with high bay areas to accommodate the internal bridge cranes. The first portion of the exterior walls is un-reinforced brick and the remaining portion of approximately 20 feet in height is glass. The Mechanical Center building was not depopulated or structurally modified to withstand the anticipated pressure. Condition noted on or about January 22, 2009. g.8) Sunoco Inc. Marcus Hook Refinery, LSGU - The employer did not document compliance with RAGAGEP. The employer's stated RAGAGEP was API Recommended Practice 752 - "Management of Hazards Associated with Location of Process Plant Buildings". The Control Room/Operator Shelter LSG was located in anarea which had potential exposure to a maximum over pressurization greater than 1 pound per square inch (psi) during a vapor cloud explosion. The building is a single story self-framing interlocking steel panel structure for general purpose exterior use. API evaluates damage to such a structure between 1.5 and 2.5 psi. The building was constructed in 2004 to 2005 and no engineering evaluation of its adequacy for the area in which it was placed was performed, and no special stipulations for blast resistant construction is reflected in the construction documents. Condition noted on or about January 22, 2009. g.9) Sunoco Inc. Marcus Hook Refinery, 10-4 FCCU - The employer did not document compliance with RAGAGEP. The employer's stated RAGAGEP was API Recommended Practice 752 - "Management of Hazards Associated with Location of Process Plant Buildings". The Zone 24 shop (10-4 Maintenance Building) was located in an area which had potential exposure to a maximum over pressurization of greater than 1 pounds per square inch (psi) during a vapor cloud explosion. The Maintenance Building is an un-reinforced brick bearing wall structure. API evaluates damage to such a structure, as partial collapse of walls at 1 psi. The maintenance building was not depopulated or structurally modified to withstand the anticipated pressure. Condition noted on or about April 16, 2009. h) Sunoco Inc. Marcus Hook Refinery - The employer did not document compliance with RAGAGEP. The employer's stated RAGAGEP was API Recommended Practice 752 - "Management of Hazards Associated with Location of Process Plant Buildings". Buildings such as but not limited to the Mechanical Center, Lube Service Center, E & I Shop, and Control Room H-5 were identified as occupied and having potential exposure to Ethylene Oxide (EO) or Hydrogen Sulfide (H2S) from units containing these materials. The employer did not evaluate or identify that mitigation systems or emergency response was in place or appropriate. Condition noted on or about January 22, 2009. i) 10-4 Plant: Sunoco, Inc. (MH) did not ensure that relief valves were sized, selected, and installed in accordance with API-520: Sizing, Selection, and Installation of Pressure-relieving Devices in Refineries, and API-521: Pressure-relieving and Depressuring Systems. These relief valves included but were not limited to: 1) RV-102 associated with E-94A/B (shell sides) 2) RV-159 associated with E-9A (shell side) 3) RV-160 associated with E-9B (shell side) 4) RV-156 associated with E-10 (shell side) 5) RV-109 associated with E-12A/C (shell side) 6) RV-110 associated with E-12B/D (shell side)7) SV-0025 associated with T-4 The above listed relief valves were still in place and part of the active process as of 3/11/2009. j) 10-4 Plant: Sunoco did not implement effective administrative controls to ensure that upstream and downstream intervening (block) valves, in line with relief devices, remained in the open position. These relief devices had upstream and/or downstream block valves which did not meet the ASME Boiler & Pressure Vessel Code, Section VIII, Division 1 requirements in that those block valves did not have mechanical locking elements present. The affected relief devices included, but were not limited to: 1) SV-23A, SV-23B, SV-23C, SV-23D (V-12) 2) SV-23E, SV-23G, SV-23H, SV-23J (V-12) 3) RV-101, RV-102 (E-94) 4) SV-20C, RV 153 (E-15A) 5) SV-20B, RV-154 (E-15B) 6) SV-20A, RV-155 (E-15C) 7) SV-157 (E-8) 8) RV-131 (V-113) The above listed block valves were observed not to have mechanical locking elements as of 2/12/2009. k) Sunoco, Inc. Marcus Hook Refinery - The employer did not document compliance with API Standard 521, Pressure-Relieving and Depressuring Systems, as evident by the fact that the design of the 17-2 UDEX Fraid Stack was not designed to prevent or safely accommodate liquid overfill. Condition noted on or about 4/21/2009. Abatement Note OSHA does not accept occupancy criteria evaluations (see API 752, Section 2.5.2) as the basis for an employer's determination that adequate protection has been provided for employees in occupied structures which employer's have identified as being potentially subject to explosions, fire, ingress of toxic materials or high energy releases. NOTE: DOCUMENTATION OF ABATEMENT OF THESE CONDITIONS IS REQUIRED