Text For Citation: 01 Item/Group: 006A 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: ALON USA, LP, 200 Refinery Road, Big Spring, TX. The employer does not document that the equipment in the process complied with recognized and generally accepted good engineering practices (RAGAGEP), such as but not limited to, API RP 620 or 2007 ASME BPV Code, Section VIII, DIV 1, UG 134(d)) when it failed to provide adequate controls to prevent intervening valves on the upstream or downstream lines to / from relief devices from potentially being closed during a relieving event or when it used intervening valves on the upstream or downstream lines remained in the open position during operation; when a pressure vessel was the possible source of a relieving event or when it used some component of the relief system which did not meet RAGAGEP design requirements. This violation was observed on or about April 15, 2009 in the following instances: a) Several pressure relief valves in the #1 SCOT Unit (068RV-416, 068RV-422, 068RV-423 and 068RV-420), #2 SCOT Unit (72RV-909 and 72RV-904) and Sour Water Stripper (074RV- 423) had no car seals or positive locking devices installed on valves located on the downstream side of these relief valves. These valves could conceivably be closed in the event of a relieving event, thus compromising the effectiveness of the relief devices. b) A gate valve located in a flare line (FLR-209A-A) feeding the Northside flare knockout drum did not have a car seal or positive locking device mounted on it. This flare line, which provided flare service to the Aromex and Rexformer Units, could thus conceivably be closed in the event of a relieving event, thus compromising the effectiveness of the relief devices. c) A gate valve located in a flare line (FLR-209A-A) feeding the Northside Flare Knockout Drum did not have a car seal or positive locking device mounted on it. A positive locking device that was on this valve on April 22, 2009 had been removed and placed on an adjacent gate valve that was not secured on April 22, 2009. This flare line, which provided flare service to the #1 SCOT and Diesel Hydrotreater Units, could thus conceivably be closed in the event of a relieving event, thus compromising the effectiveness of the relief devices. d) A gate valve mounted in the flare line from the #1 SCOT Unit (FLR-068-184-FA4A2) where it met the flare line from the Diesel Hydrotreater (FLR-014-117-FA4A2), did not have a car seal or positive locking device mounted on it. This flare line, which provided service to the #1 SCOT Unit, could thus conceivably be closed in the event of a relieving event, thus compromising the effectiveness of the relief devices. e) The pressure relief valves on the #1 SCOT Stripper (068RV-420), Sour Water Stripper Reboiler (074RV-410) and the Sour Water Stripper Feed / Bottom Exchanger (074RV-431) did not meet recognized and generally accepted engineering practices (RAGAGEP), in that these relief valves lacked adequate flow capacity to properly relieve expected loads from these vessels in the event of pressure buildup due to fire or blocked flow. f) Both #1 and #2 Sulfur Recovery Units used a steam powered eductor system to carry gases and vapors from the sulfur pits to the incinerator by pulling air in from an open vent andsweeping the vapor along in the air stream. A blocked steam line to either eductor system would result in the uncontrolled release of gas containing hydrogen sulfide through the air vent. Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking in the workplace to ensure documentation that the equipment in the process complies with recognized and generally accepted good engineering practices.