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

29 CFR 1910. 1910.119 (d)(3)(i)(B) Information pertaining to the equipment in the process shall include piping and instrument diagrams (P&ID's). A) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the piping and instrument diagrams were inaccurate or incomplete such as but not limited to: UOSH Document Request No. 10 asked for the P&ID drawings for all PSM Covered Units including legends. For the Amine Unit, the employer provided universal Legend Sheet #1 (BWO UOSH-010B09-0001). The symbols for ball and globe valves on this legend does not match the symbols used on the four Amine Unit Drawings: i.Drawing No. 27, (BWO UOSH-010B09-0002) ii.Drawing No. 28, (BWO UOSH-010B09-0003) iii.Drawing No. 29, (BWO UOSH-010B09-0004) iv.Drawing No. 30, (BWO UOSH-010B09-0005) B) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the piping and instrument diagrams were inaccurate or incomplete such as but not limited to: UOSH Document Request No. 10 asked for the P&ID drawings for all PSM Covered Units including legends. For the Sulfur recovery Unit, the employer provided universal Legend Sheet #1 (BWO UOSH-010B10-0001). This universal legend sheet does not show the symbol for piping segments used on Drawing No. 22, (BWO UOSH-010B10-0007). As explained by Big West Oil process engineer, the symbol of a circle with an alphabetic character in it was an "arbitrary" symbol used by the consultant Ford, Bacon and Davis in lieu of Big West Oil's symbol for piping. The employer should have submitted the legend assembled by Ford, Bacon and Davis (FBD) at the time that the SR Unit was designed in 1992. This SRU legend (BWO UOSH-127B-0124) was included with pipe traveler material submitted. C) On or about July 7, 2010, and OSHA engineer observed an amine drain line connected to a 1" nozzle for pressure gage PI 5590 on exchanger E-1390 in the Amine Unit that was not symbolically represented on Drawing No. 30, (BWO UOSH-010B09-0005). This amine drain line included two isolation valves and a backflow preventer. Big West Oil process engineer who is responsible for the Amine Unit verbally indicated to OSHA that his recent P&ID surveys had found the same errors. D) On or about July 7, 2010, OSHA engineer observed three, 1-in inch isolation valves on an amine drain line connected to the bottom of Liquid Gage LG-5590 on exchanger E-1390 in the Amine Unit that was not symbolically represented on Drawing No. 30, (BWO UOSH- 010B09-0005). The three valves were located downstream of LG-5590 and upstream of the connection to 3/8 inch stainless steel amine drain tubing . Big West Oil process engineer who is responsible for the Amine Unit verbally indicated to OSHA that his recent P&ID surveys had found the same errors. E) On or about July 7, 2010, OSHA engineer did not observe 2 one inch nozzles connected to level transmitter LT-5590 in the head of exchanger E-1390 in the Amine Unit as issymbolically represented on Drawing No. 30, (BWO UOSH-010B09-0005). Big West Oil process engineer who is responsible for the Amine Unit verbally indicated to OSHA that his recent P&ID surveys had found the same errors. F) On or about July 7, 2010, OSHA engineer observed a chain operated isolation valve on the 8 inch sour gas line feeding Amine Absorber T-1310 that was not symbolically represented on Drawing No. 28, (BWO UOSH-010B09-0003). The chain extends to grade. This is a serious omission as it may be crucial to know the presence of the chain operator at grade during an emergency operation. Big West Oil process engineer who is responsible for the Amine Unit verbally indicated to OSHA that his recent P&ID surveys had found the same errors. G) On or about July 7, 2010, OSHA engineer observed a drain line with isolation valve and plug connected to the 8 inch sour gas line feeding Amine Absorber T-1310 that was not symbolically represented on Drawing No. 28, (BWO UOSH-010B09-0003). Flying J process engineer who is responsible for the Amine Unit verbally indicated to OSHA that his recent P&ID surveys had found the same errors. H) On or about July 9, 2010, OSHA engineer observed a drain line with isolation valve and plug connected to the 8 inch sour gas line feeding Amine Absorber T-1310 that was not symbolically represented on Drawing No. 28, (BWO UOSH-010B09-0003). I) On or about July 9, 2010, OSHA engineer observed a nozzle in the shell of exchanger E- 1104 that was not symbolically represented on Drawing No. 21, (BWO UOSH-010B10- 0006). J) On or about July 9, 2010, OSHA engineer observed a nozzle in the shell of exchanger E- 1103 that was not symbolically represented on Drawing No. 21, (BWO UOSH-010B10- 0006). K) On or about July 9, 2010, OSHA engineer did not find Temperature Element TE-1820 in Temperature Well TW-1820 on Exchanger E-1103 as symbolically represented on Drawing No. 21, (BWO UOSH-010B10-0006). The temperature well had been abandoned. TE-1820 had been moved to the 6 inch diameter piping exiting E-1103 for V-1104. L) On or about July 9, 2010, OSHA engineer observed a valved drain line on Specialty Item No. 51 that was not symbolically represented on Drawing No. 18, (BWO UOSH-010B10- 0004). M) On or about July 9, 2010, OSHA engineer could not find Flow Element FE-1504 in the location symbolically represented on Drawing No. 18, (BWO UOSH-010B10-0004). Big West Oil process engineer who is responsible for the Sulfur Recovery Unit indicated that the flow turbine had been moved. N) On or about July 9, 2010, OSHA engineer observed two solenoid-actuated valves (BV- 1506 and BV-1512) that vent fuel gas to the atmosphere through a common 3/8 inch diameterstainless steel pipe. These valves relieve pressure in the line between two Maxxon safety valves when they have tripped. Drawing No. 18, (BWO UOSH-010B10-0004) symbolically misrepresents that each valve is vented separately. O) On or about July 9, 2010, OSHA engineer observed two solenoid-actuated valves (BV- 1506 and BV-1512) that vent fuel gas to the atmosphere through a common 3/8 inch diameter stainless steel tubing. These valves relieve pressure in the line between two Maxxon safety valves when they have tripped. Drawing No. 18, (BWO UOSH-010B10-0004) symbolically misrepresents that each valve is vented to atmosphere separately. In addition, the common vent-to-atmosphere tubing is fitted with a ball valve which also is not symbolically represented on the drawing. P) On or about July 9, 2010, OSHA engineer could not find a strainer in the location symbolically represented on Drawing No. 18, (BWO UOSH-010B10-0004). The strainer is symbolically located just downstream of safety valve BV-1513. Q) On or about July 9, 2010, OSHA engineer could not find a pressure gage (PI-1537) in the location symbolically represented on Drawing No. 18, (BWO UOSH-010B10-0004). The pressure gage is symbolically located downstream of safety valve BV-1513. R) On or about July 9, 2010, OSHA engineer could not find a pressure gage (PI-1539) and corresponding isolation valve in the location symbolically represented on Drawing No. 18, (BWO UOSH-010B10-0004). The pressure gage and isolation valve symbolically "T" into the 1 inch diameter plant fuel gas line just upstream of burner B-1101. S) On or about August 12, 2010, OSHA engineer could not find pressure safety valve PSV- 5510 which protects vessel T-1310 in the location symbolically represented on Drawing No. 28, (BWO UOSH-010B09-0003) by matching the valve tag information with the P&ID information. The aluminum tag on the valve body is marked RV-510 instead of PSV-5510.