Text For Citation: 01 Item/Group: 011 Hazard: REFINERY

29 CFR 1910.119 (j)(2) The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment. a)The employer did not implement its Mechanical Integrity Program (General Thickness Monitor Requirement Section 3.1) for resolving anomalous pressure vessel inspection data. The employer did not address the inconsistencies on thickness measurements taken on the shell and channel box of heat exchanger E-103D on January 2004 and July 2009. The report for the shell side indicates a serious anomaly which was not addressed for the last seven (7) years. Test results which were collected on 01/2004 (shell) (Bates #7995-7996) have several readings with thickness higher than the initial thickness which was measured in 1972 by more than 0.020". This violation was documented on May 6, 2011. b)The employer does follow the External Inspection of Piping procedure from their Global Inspection Practices Manual which references API 570 for piping inspections The company failed to include the appropriate thickness measurements (previous thickness) for Piping Circuit P020L500-X in its calculation of corrosion rates in 2009. Section 7.1.3 of API 570 specifically states that "corrosion rates shall be calculated on either a short term or a long term basis" for existing piping. The employer violated this standard on or about March 14, 2011 when the employer did not complete the corrosion analysis required by API 570 for inspections on P020L500-X piping circuit. c)The employer's Mechanical Integrity Program does not ensure that Hydrocracker Reactors R-101, R-102, and R-103 were adequately protected from overpressure. Set pressures for reactor safety relief valves: SV-020l020, SV-020l021, SV-020l022, SV- 020l023, SV-020l024, and SV-020l025 were set higher than the maximum allowable working pressure (MAWP). This violation was documented on or about March 14, 2011. As per API RP 520: "Sizing, Selection, and Installation of Pressure-Relieving Devices in Refineries, Part I - Sizing and Selection" (7th edition, January 2000; Section 3.5.2.2.2, pages 39 and 40) when multiple pressure relief devices are used on a vessel (sized for operating non-fire contingencies), the set pressure of the first device shall not exceed the Maximum Allowable Working Pressure (MAWP) and the set pressure of the additional device or devices shall not exceed 105% of the MAWP. In addition, see pages 97 and 98 of the ASME Code, Section VIII (2004), UG-134: "Pressure Setting of Pressure Relief Devices" which also confirms the set pressure requirements for relief devices. Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an abatement plan describing the actions it is taking to ensure that steps are taken to resolve anomalous data readings. The violation must be abated no later than 10 days from the receipt of this citation.