Text For Citation: 01 Item/Group: 007A Hazard: REFINERY

29 CFR 1910.119(j)(2) The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment. A) On or about July 9, 2010, at Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, OSHA engineer observed a broken thermocouple connection on Reheater No. 2, in the Sulfur Recovery Unit (SRU). The exchanger is symbolically represented as E-1103 on SRU P&ID drawing No. 21 (BWO UOSH-010B10-0006). The thermocouple is represented as TE-1827 A&B on SRU P&ID drawing No. 21 (BWO UOSH-010B10-0006). The escort and Sulfur Recovery Unit Engineer was not able to provide a definitive answer regarding the status of the broken thermocouple and there were no explanatory tags hung on the broken thermocouple and could result in serious injury from hazardous chemicals exposures. The employer did not implement their own written BWO procedure to maintain the on- going integrity of process equipment. Section 8.1 of BWO's Mechanical Integrity Program for Controls (BWO UOSH-016B-0010) calls for "equipment included in this program found to be outside acceptable limits shall be corrected/repaired as soon as practically possible". B) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the employer did not establish and implement adequate written procedures to maintain the on-going integrity of process equipment, not limited to a procedure for corrosion-under-insulation inspection. In response to UOSH document requests regarding Mechanical Integrity, documents submitted by the employer demonstrated that there was a paucity of written MI policies and procedures. For example, on September 21, 2010, in response to Document Request #16, for any and all policies, procedures, or statements regarding a requirement to inspect for corrosion under insulation, the PSM Engineer referred the Compliance Officer to documents BWO UOSH- 18A and BWO UOSH-018B. The Compliance Officer reviewed these documents along with those submitted in response to request for MI procedures for piping: UOSH-004, UOSH- 016A, UOSH-016B, and UOSH-81 (note from employer stated: BWO UOSH-018A-0025 and UOSH-16--specifically, some of the mechanical integrity procedures pertaining to piping inspections can be found at pages 1-6, 23, and 25), UOSH-127 (piping specifications), UOSH-130, and the Auditing Report Form (BWO UOSH-115). None of these documents identified procedures to complete an inspection for corrosion-under-insulation with regard to piping. Procedures to inspect for corrosion under insulation must be established and implemented to enable the employer to maintain the on-going integrity of process piping and to avoid a release of the piping and potential employee exposures to hazardous chemicals contained by the process piping. This may be a system-wide occurrence that requires evaluation of all procedures throughout the facility. C) The employer did not establish and implement written procedures to maintain the on- going integrity of process equipment, such as but not limited to procedures for inspecting relief devices. This violation was identified during the inspection at Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, on September 1, 2010, when the Compliance Officer reviewed the documents submitted in response to requests for the corporate and refinery mechanical integrity (MI) program procedures (BWO UOSH-16) and all MI procedures (program and task specific instructions) related to the inspection, testing, servicing, repair, alteration of pressure vessels, piping and relief system equipment (BWO UOSH-18) which did not establish site-specific procedures with details for inspecting, testing,maintaining, and repairing relief devices. Not establishing written procedures to maintain the on-going integrity of relief devices prevents the employer from preventing hazardous chemical exposures to employees. This may be a system-wide occurrence that requires evaluation of all procedures throughout the facility. D) The employer did not establish and implement written procedures to maintain the on- going integrity of process equipment, such as but not limited to procedures for establishing thickness measurement locations (TML) for injection points and nearby piping. During the inspection at Big West Oil, 333 W Center Street, North Salt Lake, on September 21, 2010, the Compliance Officer reviewed the documents submitted in response to requests for the corporate and refinery mechanical integrity (MI) program procedures (BWO UOSH-16) and all MI procedures (program and task specific instructions) related to the inspection, testing, servicing, repair, alteration of piping (BWO UOSH-16, BWO UOSH-18, BWO UOSH-081, BWO UOSH-130) submitted in response to requests for MI procedures. These documents did not establish procedures to establish TML for injection points and nearby piping. Procedures to establish TML for injection points and nearby piping must be established and implemented to enable the employer to maintain the on-going integrity of process piping and to avoid a release of the piping and potential employee exposures to hazardous chemicals contained by the process piping. E) The employer did not establish and implement policies and procedures which incorporate Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) to maintain the on-going integrity of pressure relief valves. BWO Reliability Manual for Mechanical Integrity and Equipment Reliability (BWO UOSH-016A-0003) indicates that written MI procedures are detailed in Appendix A. Appendix A offered inadequate written MI procedures for pressure safety valves. For example Task #640 titled "Maintenance and Inspection Tasks for Relief Valves" (BWO UOSH-016A-0024) offered only the follow written procedures for pressure safety valves: "Operators should observe for leakage daily "Maintenance/Engineering determines if pressure safety valve will be checked during next turnaround. "Maintenance remove/reinstall valves for inspection and repair "Maintenance insures documentation is up to date "Test and repair boiler relief valves annually The employer must write and implement policies and procedures based on RAGAGEPs for the following applicable activities: design, inspection, repair, preventive maintenance, alteration, rerating, and fitness for service. These policies and procedures must apply to the following process equipment; pressure vessels, storage tanks, piping, pressure relief valves, relief vent systems, instrumentation, controls, and pumps. Serious injury or death to an employee from exposure to hazardous chemicals could occur in the event of equipment failure if the employer does not establish and implement written procedures to maintain the on-going integrity of process equipment. This may be a system wide occurrence that requires evaluation of all procedures throughout the facility. As an example, written policies and procedures for maintaining the MI of pressure safety valves would include but not be limitedto: 1.Inspection requirements: a.Written procedure for external visual inspection b.Written procedure for periodic check of positions of upstream and downstream block valves c.Written procedure for as-received pop testing and interpretation of results d.Written procedure for visual inspection of inlet and outlet piping for fouling and plugging whenever valve is removed e.Written description of inspection interval at fixed period based on inspection codes or determined by results of as-received pop testing 2.Design Requirements: a.Written procedure for component materials b.Written procedure for sizing design basis and calculations c.Written procedure for inspection and testing of new/rebuilt valves 3.Repair/Replace Requirements: a.Written procedure for ASME VR stamp for repairs b.Written procedure for vendor qualifications c.Written procedure for employer documentation d.Written procedure for removing valve on-line (identify other pathways) e.Written procedures for craft skill procedures for tasks encountered such as gasket installation, bolt tightening, etc. F) The employer did not establish and implement policies and procedures which incorporate Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) to maintain the on-going integrity of vessels, relief valves and piping. BWO Reliability Manual for Mechanical Integrity and Equipment Reliability (BWO UOSH-016A-0003) indicates that written MI procedures are detailed in Appendix A. Appendix A offered only insufficient and abbreviated written MI tasks such as: "Task #510 for vessels has nine lines of text with brief inspection task descriptions such as: "visually inspect vessel", "perform thickness testing of shell, head and nozzle" "check trays", "check liners for cracks, bypassing, bulging or corrosion" (BWO UOSH- 016A-0021). "Task # 610 for piping has seven lines of text with brief inspection task descriptions such as: "visually inspect all piping" and "review NDT reports" (BWO UOSH-016A-0021). "Task # 640 for relief valves has five lines of text with brief inspection task descriptions such as: "observe for leakage", "remove valves for inspection" and "test and repair boiler relief valves". Serious injury or death to an employee from exposure to hazardous chemicals could occur in the event of equipment failure if the employer does not establish and implement written procedures to maintain the on-going integrity of process equipment. This may be a system wide occurrence that requires evaluation of all procedures throughout the facility. Written procedures would be sufficient if the following were addressed: 1.how and when procedure will be used 2.who will use the procedure 3.does the procedure impact safety or environmental issues 4.does procedure address sequencing of tasks 5.is procedure written as a command 6.is there enough specificity in the procedure so there is no guessing or interpretation required G) The employer did not establish and implement policies and procedures which incorporate Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) to maintain the on-going integrity of process equipment. BWO Reliability Manual for Mechanical Integrity and Equipment Reliability (BWO UOSH-016A-0003 and 0004) lists "Good Engineering Practices" employed by BWO. The employer failed to include API 579 Fitness for Service (FFS) on this list to demonstrate the structural integrity of an in-service component that may contain a flaw or damage. The guidelines provided in this API 579 Standard are used to make run-repair-replace decisions to help determine if pressurized equipment containing flaws can continue to operate safely for some period of time. BWO's MI Program does not reference API 579. Serious injury or death to an employee from exposure to hazardous chemicals could occur in the event of equipment failure if the employer does not establish and implement written procedures to maintain the on-going integrity of process equipment. This may be a system wide occurrence that requires evaluation of all procedures throughout the facility.