Text For Citation: 01 Item/Group: 005 Hazard: CHEMICAL

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices: (a)Suncor Energy (U.S.A.), Inc., 5801 Brighton Blvd., Commerce City, Colorado: On or about October 29, 2008, and at times prior thereto, the employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP) in that throughout the refinery, including, but not limited to, the #1 Crude Unit, there were many pressure vessels, such as heat exchangers and strainers, falling under the scope of the ASME Boiler and Pressure Vessel Code Section VIII, Division 1 (BPVC), which were not provided with pressure relief devices. Minimally, but not limited to, the following heat exchangers and strainers, which are pressure vessels in the #1 Crude Unit, were not provided with pressure relief devices: X-338 shell side, X-322 shell side, X-324 shell side, X-323 shell side, X-322 tube side, X-338 tube side, X-16 shell side, X-165 tube side, S-56 and S-57. Employees are potentially exposed to hazards related to fires and explosions caused by overpressurized pressure vessels containing highly hazardous chemicals such as flammable liquids. One feasible means of abatement would be for the employer to design and install pressure relief devices in accordance with RAGAGEP, such as meeting the requirements of BVPC UG-125 through UG-137 for all pressure vessels falling under the scope of BPVC Section VIII, Division 1. (b)On or about October 8, 2008, and at times prior thereto, the employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP) in that the pressure setting for pressure relief valves RV15 and RV874, which were installed to protect pressure vessel W-1 from overpressure, were set higher than 100 percent and 105 percent, respectively, of the maximum allowable working pressure (MAWP) of W-1. Employees are potentially exposed to hazards associated with fires and explosions resulting from overpressurized pressure vessels, such as W-4, containing highly hazardous chemicals. One feasible means of abatement would be for the employer to ensure pressure settings of pressure relief devices are in accordance with RAGAGEP, such as BPVC UG-134(a). (c)On or about October 29, 2008, and at times prior thereto, the employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP) in that a report, which addresses the procedures, results, recommendations, and conclusions for the 2004 PHA for the #1 Crude Unit was not written. Employees are exposed to hazards associated with fires and explosions as a result of inadequate documentation of the PHA review for the Crude Unit. One feasible means of abatement would be for the employer to ensure that PHA review procedures, results, recommendations, and conclusions are documented inaccordance with RAGAGEP, such as Chapter 6.3 of Guidelines for Process Safety Documentation, Center for Chemical Process Safety of the American Institute of Chemical Engineers, 1995. (d)On or about October 29, 2008, and at times prior thereto, the employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP) in that the documentation of the 2004 PHA for the #1 Crude Unit did not include the majority of the process safety information, such as the complete process technology package which includes the equipment safe operating limits, for the #1 Crude Unit. Employees are exposed to hazards associated with fires and explosions as a result of inadequate documentation of the PHA review for the Crude Unit. One feasible means of abatement would be to ensure that PHA reviews are documented in accordance with RAGAGEP, such as Chapter 6.3 of Guidelines for Process Safety Documentation, Center for Chemical Process Safety of the American Institute of Chemical Engineers, 1995. Such documentation shall include the process safety information reviewed to allow auditing of the PHA for technical quality. (e)On or about December 17, 2008, and at times prior thereto, the employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP) in that the West Plant Main Control Room and Old Lab (CFT Offices) building was not designed and constructed to protect the shelter-in-place occupants from releases of toxic contaminants such as hydrogen sulfide and flammable vapors within the refinery. Employees were exposed to hazards such as fires and explosions, as well as overexposure to hydrogen sulfide. One feasible means of abatement would be to ensure that all shelter-in-place buildings are designed and constructed in accordance with API RP 752. Abatement Note: Abatement certification and documentation are required for this item (see enclosed "Sample Abatement-Certification Letter").