Text For Citation: 01 Item/Group: 010 Hazard: REFINERY

29 CFR 1910.119(d)(3)(i)(D): Process safety information pertaining to the equipm ent did not include relief system design and design basis: The employer does not have written process safety information (PSI) pertaining to relief system desig n and design basis. The employer did not have complete written PSI related to PS V-701. As described in the 2001 Calumet Lubricants Flare Study, conducted by Jac ob and Associates LLC, PSV-701 was undersized and not adequate based upon the fi re case relief scenario. As stated under the "Zone 8" summary, finding 1, "Relie f valve PSV-701 needs to be changed; it is not adequate, the relief valve should be changed to a 1.5 x G x 2.5." Calculations in the relief study were based upon the larger "G" orifice size. Without a "G" o rifice, per the flare study, the valve is too small. In 2008, nearly 7 years aft er the flare study was completed, the employer responded to the change stating t he "valve never installed because it was determined adequate protection was avai lable with existing valve and equalization line to T-700." No MOC was conducted to assess and document the operating change of keeping the smaller valve in serv ice. No additional design data or calculations were provided to support keeping the older, smaller valve in service. No adjustment to the flare study was made t o show a smaller valve orifice was adequate. Field verification of PSV-701 indic ated a valve size "1 x E x 5" was currently present on D-700. Consequently, sinc e no evaluation was done, it is not known whether the PSI is accurate. This viol ation was documented on or about December 20, 2010. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in complianc e with the standard, including the steps that it is taking to ensure that employ ees are not being exposed to highly hazardous chemicals.