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

29 CFR 1910.119(f)(1) 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 29 CFR 1910.119(f)(1)(i-iv). A) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the employer did not implement written operating procedures that provide clear instruction for safely conducting activities involved in each covered process. On or about August 12, 2010, the Compliance Officers observed that an intervening or block valve upstream of pressure relief valve RV- 3307 (protecting Alky drum D-304) was car-sealed open with a chain. A plastic strip connected two links of the chain. The plastic strip did not have a number on it. A lock was observed abandoned on the platform adjacent to the relief valve. Other block valves observed by the Compliance Officers that were similarly car-sealed had numbered metal bands connecting two links of the chain. In an interview, the Technical Manger stated to the OSHA Mechanical Engineer that Big West Oil LLC was responsible to ensure that only metal strips, not plastic strips, were used as car-seals and that the strips were properly numbered. Flying J Refinery Policy No. 30 titled Relief Valve Removal and Block Valve Closing (BWO UOSH-042-0001) defines a car-seal as "a chain and lock or a numbered car-seal." The employer did not implement their written procedure which called for numbering of car-seals to verify that a block valve has not been closed without proper procedures. Car seal procedures must be established and implemented to enable the employer to identify car-seals in order to ensure the integrity of process piping and to avoid a release of and potential employee exposures to hazardous chemicals contained by the process equipment. This may be a system wide occurrence that requires evaluation of all procedures throughout the facility.t