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

29 CFR 1910.119(j)(5) The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation. A) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the employer did not correct equipment deficiencies in a timely manner for six relief systems in the Alky Unit. Forty-two months will have lapsed between employer's acknowledgement of the deficiency and mitigation of the hazard. BWO Technical Manager stated these deficiencies are scheduled to be mitigated during the next Alky Unit turn-around (TAR) in the fall of 2011. This mitigation schedule was verbally conveyed to OSHA engineer from the BWO Technical Manager during an interview on September 29, 2010. The following Alky Unit deficiencies were reported in a Final South Flare Study by Ambitech in May of 2008 (BWO UOSH- 008B-0995): 1.Change RV-3396 discharge piping from 8" to 12" diameter. 2.Change RV-3480 discharge piping from 6" to 10" diameter. 3.Change RV-3475 discharge piping from 3" to 4" diameter. 4.Change RV-3474 discharge piping from 3" to 4" diameter. 5.Change RV-3314 discharge piping from 4" to 6" diameter. 6.Change RV-310 discharge piping from 2" to 3" diameter. 7.Change RV-3396 discharge piping from 8" to 12" diameter. The deficiencies were first identified in a draft South Flare Study to the employer in December of 2007. After employer review, the final South Flare Study was issued by Ambitech in May of 2008. No risk analysis has been performed to justify the decision to delay to replace the piping until fall of 2011. The mitigation effort could be longer than 42 months if the ALKY TAR is delayed. The replacement of relief valve discharge piping (a.k.a. tailpipe piping) may require shut-down or an alternate path for the relief discharge must be found, although the employer recently (March 2010) upsized 100 lineal feet of sub- header flare piping from 8" to 10" diameter as recommended in the same Flare Study. Serious injury or death to an employee could occur in the event of a failure of deficient process equipment that may result in employee exposures to hazardous chemicals. This may be a system-wide occurrence that requires evaluation of all procedures throughout the facility. B) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the employer did not correct equipment deficiencies in a timely manner for relocating the existing South Flare K.O. Drum and installing a new South Flare K.O. Drum. Forty-two months will have lapsed between employer's acknowledgement of the deficiency and mitigation of the hazard. The following Alky Unit deficiencies were reported in a Final South Flare Study by Ambitech in May of 2008 (BWO UOSH-008B-0997). These two deficiencies are scheduled to be mitigated during the next Alky Unit turn-around (TAR) in the fall of 2011 per BWO Technical Manager. This mitigation schedule was verbally conveyed to OSHA engineer from BWO Technical Manager during an interview on September 29, 2010. 1.Add a new 10 ft. diameter X 24 ft. long South Flare KO Drum in parallel to the existing Drum (BWO UOSH-008B-0097). 2.Relocate existing South Flare KO Drum, pumps and flame front generator 175 to 225 ft. away from the base of the flare stack. The deficiencies were first identified in a draft South Flare Study to the employer in December of 2007. After employer review, the final South Flare Study was issued by Ambitech in May of 2008(BWO UOSH-008B-0997). The employer has decided to perform this work during next TAR of the Alky Unit in the fall of 2011. No risk analysis has been performed to justify the decision to delay the replacement and relocation of the South Flare KO drum and flame front generator until fall of 2011. The HDS, MSCC, Crude and LPG Storage Unit also collected by the South Flare Unit so it is not clear why this work is tied to the Alky Unit TAR. The mitigation effort could be longer than 42 months if the Alky unit TAR is delayed. The Final South Flare Study recommended moving the existing South Flare K.O. Drum 175 ft. to 225 ft. away from the flare stack. In its current location the radiative heat exchange between the flare flame and the K.O. Drum may ignite the vapors and then the liquids in the South Flare K.O. drum resulting in fire. Serious injury or death of an employee could result in the event of a fire. This may be a system-wide occurrence that requires evaluation of all procedures throughout the facility. Note: Section 4.4.2.3 of the 1997 API RP 521 Guide for Pressure-Relieving and Depressuring Systems offers guidance for protecting humans and vessels from the radiation (heat) generated by a flare. It can be used to calculate the minimum distance from the midpoint of the flare flame to the object being considered.