Text For Citation: 01 Item/Group: 006B Hazard: REFINERY

29 CFR 1910.119(f)(1): The employer had not developed and implemented written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information: ALON USA, LP, 200 Refinery Road, Big Spring, TX. The employer does not implement its car seal program which requires that Operations Coordinators conduct inspections to ensure that pressure relief valves / gate valves have car seals or other positive locking devices in place when a pressure vessel is the possible source of a relieving event or when it utilizes some component of the relief system which does not meet RAGAGEP design requirements. This violation was observed on or about April 15, 2009 in the following instances: a) The Operations Coordinators failed to identify that car seals or other positive locking devices were present on 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) The Operations Coordinators failed to identify that car seals or other positive locking devices were present on 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) The Operations Coordinators failed to identify that car seals or other positive locking devices were present on 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) The Operations Coordinators failed to identify that car seals or other positive locking devices were present on 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. 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 that inspections are conducted and documented that pressure relief valves / gate valves have car seals or other positive locking devices.