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

29 CFR 1910.119(j)(4)(i) Inspections and tests shall be performed on process equipment. A) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the employer did not perform inspections and tests on process equipment to maintain its mechanical integrity. The employer did not perform "as-received" pop pressure tests for pressure safety valves including but not limited to the following: 1.PSV-3396 protecting T-304 in the Alky Unit. This valve was removed from service in 2006 and sent to Furmanite for rebuild (BWO UOSH-092 0025). On 6/2/2006, Furmanite crossed out the "Pre-Test Results (as-found condition)" portion of the VR Certification Card and wrote "NA". 2.PSV-3396 protecting T-304 in the Alky Unit. This valve was removed from service in 2006 and sent to Furmanite for rebuild (BWO UOSH-092 0024). On 6/23/2006, Furmanite crossed out the "Pre-Test Results (as-found condition)" portion of the VR Certification Card and wrote "NA". 3.PSV-3423 protecting T-303 in the Alky Unit. This valve was removed from service in 2008 and sent to Furmanite for rebuild (BWO UOSH-092 0008). On 9/18/2008, Furmanite crossed out the "Pre-Test Results (as-found condition)" portion of the VR Certification Card and wrote "NA". 4.PSV-5590 protecting E-1390 in the Amine Unit. This valve was removed from service in 2006 and sent to Furmanite for rebuild (BWO UOSH-092 0035). On 10/3/2006, Furmanite crossed out the "Pre-Test Results (as-found condition)" portion of the VR Certification Card and wrote "NA". The employer did not instruct Furmanite to perform as-received pop-pressure tests. As- received, pop pressure test for pressure safety valves is essential for the refinery inspector to know at what pressure the old valve would have relieved at, to assess risk, to form an opinion regarding the next inspection date or to recommend the installation of protective rupture discs. Serious injury or death could occur to an employee from exposure to hazardous chemicals in the event of equipment failure that may have been prevented by performing necessary tests on process equipment. This may be a system-wide occurrence that requires evaluation of all pressure safety valves throughout the facility. B) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the employer did not perform external inspections of some pressure vessels as evidenced by the lack of documentation of these inspections for the period between 1992 (promulgation of OSHA PSM Standard) and May 17, 2010 (opening date of this inspection). Unless otherwise established by a risk-based inspection (RBI) assessment, the RAGAGEP requires external inspection of pressure vessels at least every 5 years. These external inspections check the outside surface of the vessel, insulations systems, painting and coating systems, supports and check for leakage, hot spots, vibration, bulging, out-of-roundness, sagging and distortion. Through BWO Document request Nos. 94, 95, 96, 97 and 98, the records of 5 pressure vessels was selected and reviewed. Review of pressure vessel records by OSHA Engineerdiscovered the following external inspection deficiencies: 1.T-304 in the Alky Unit: There is one documented external inspection of this vessel on April 19, 2000 (BWO UOSH-096-0253). This was the only recorded external inspection between 1992 and present. Based on this one documented inspection, there should have been documented external inspections for this vessel also in 1995 and 2005. BWO Inspector indicated that external inspections were performed but not documented during an interview on August 19, 2010. 2.E-1390 in the Amine Unit: There are two documented external inspections of this vessel one on March 1, 2006 (BWO UOSH-095-0012) and the other on May 17, 2000 (BWO UOSH-095-0005). These were the only recorded external inspections between 1992 and present. Based on these two documented inspections, there should have been documented external inspections for this vessel also in 1995 and 2005. During an interview on August 19, 2010, BWO Inspector indicated that external inspections were performed but were not documented. 3.D-304 in the Alky Unit: There are two documented external inspections of this vessel one on May 18, 2000 (BWO UOSH-098-0005) and the other on August 26, 2009 (BWO UOSH-098-0008). These were the only recorded external inspections between 1992 and present. Based on these two documented inspections, there should have been documented external inspections for this vessel also in 1995 and 2005. BWO Inspector, indicated that external inspections were performed but not documented during an interview on August 19, 2010. 4.T-1310 in the Amine Unit: There is one documented external inspection of this vessel on May 17, 2000 (BWO UOSH-094-0009). This was the only recorded external inspection between 1992 and present. Based on this one documented inspection, there should have been documented external inspections for this vessel also in 1995 and 2005. BWO Inspector indicated that external inspections were performed but not documented during an interview on August 19, 2010. Without adequate external inspections to detect anomalous surface conditions, the vessel could fail resulting in a catastrophic release and exposure to employees. Serious injury or death could occur to an employee from exposure to hazardous chemicals in the event of equipment failure that may have been prevented by performing necessary inspections and tests on process equipment. This may be a system-wide occurrence that requires evaluation of all pressure safety valves and pressure vessels throughout the facility. Note: 2000 API Recommended Practice (RP) 576 Inspection of Pressure-Relieving Devices: 1.Section 6.1 Reasons for Inspection; "inspecting pressure-relieving devices is to ensure that they will provide this protection". 2.Section 6.1 Reasons for Inspection; "pre-testing of the pressure-relieving deviceshould be included in the shop inspection/overhaul". 3.Section 6.2.8 Determining "As-Received" Pop Pressure; "This "as-received" pop pressure is used in determining the inspection interval". 4. Section 6.4.1.1; Frequency of Shop Inspection/overhaul; Consistent "as-received" pop test results may allow for increasing the inspection interval while erratic results may require decreasing the inspection interval. 2006 API 510 Pressure Vessel Inspection Code: 1.Section 6.6 Pressure relieving devices should be inspected per API 576 2.Section 6.6.2.1 Pressure-relieving devices shall be tested and inspected at intervals that are frequent enough to verify that the valves perform reliably and the inspection interval is determined by the inspector 3.When a pressure relieving device is found to be stuck the inspection interval shall be reduced 2006 API 510 Pressure Vessel Inspection Code: In-Service Inspection, Rating, Repair, and Alteration, Section 6.4.1 "Unless justified by a RBI assessment, each aboveground vessel shall be given a visual external inspection at an interval that does not exceed the lesser of five years or the required internal inspection.