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

29 CFR 1910.119(f)(1)(i)[C] The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements: Temporary operations; A. The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities, specifically addressing temporary operations. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. As per documents provided by the employer, the upper safe limit for the MDDW RTR-30101 feed is listed at 800 F, yet the temporary operating procedure "Hot Hydrogen Strip", dated August 21, 2007, included in the operating manual, step 2.3.1.13, indicates that this upper temperature limit of 800 F is routinely exceeded. This procedure states "Start increasing the furnace outlet in 13 F increments every 15 minutes to 900 F", and step 2.3.1.15 states "Hold for 16 hours." Feed from the furnace flows directly into RTR-30101. Operator interviews stated that temperatures above 800F were common as per the procedure. As provided, the Mobile Operating Guide did not instruct facilities to exceed safe upper operating limits during catalyst regeneration. By not developing and implementing operating procedures that provide clear instructions for temporary operations, employees were increasing temperatures of process equipment above established safe upper limits. Operations outside safe upper limits can cause catastrophic failures which can expose employees to serious injury or death. This may be a system-wide occurrence that requires evaluation of all written operating procedures throughout the facility. B. The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities, specifically addressing temporary operations. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. As per documents provided by the employer, the safe upper limit for temperature of the RTR-30103 inlet is exceeded in the 11/3/09 "Hot Hydrogen Strip" procedure. The safe upper limit for RTR-30103 is 800F, yet through the 11/3/09 "Hot Hydrogen Strip" procedure, dated November 3, 2009, Step 12, states "Start increasing the furnace outlet in 13 degree F increments every 15 minutes to 800 F". The Step 13 instructions acknowledge that exothermic activity can result in temperature increases above 800 F as noted by "Watch the MDDW and HDS reactor bed temperatures for exothermic activity. If exotherm becomes greater than 30 F, hold reactor inlet temp constant until exotherm reduces to 20 F." In addition, the procedure states to "Observe safety precautions in the Mobile Operating Guide." Through this procedure, temperatures can reach 830 F. The Mobile Operating Guide does not instruct facilities to exceed safe upper operating limits during catalyst regeneration. By not developing and implementing operating procedures that provide clear instructions for temporary operations, employees were increasing temperatures of process equipment above established safe upper limits. Operations outside safe upper limits can cause catastrophic failures which can expose employees to serious injury or death. This may be a system-wide occurrence that requires evaluation of all written operating procedures throughout the facility.