Violation Detail
Standard Cited: 19100119 J04 III Process safety management of highly hazardous chemicals.
This violation item has been deleted.
Inspection Nr: 312412356
Citation: 01012
Citation Type: Willful
Abatement Status:
Initial Penalty: $56,000.00
Current Penalty: $56,000.00
Issuance Date: 04/28/2010
Nr Instances: 14
Nr Exposed: 24
Abatement Date: 06/03/2010
Gravity: 10
Report ID: 0854910
Contest Date: 05/27/2010
Final Order: 10/23/2013
Related Event Code (REC):
Emphasis:
| Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
|---|---|---|---|---|---|---|
| Penalty | F: Formal Settlement | 10/23/2013 | $56,000.00 | 06/03/2010 | Willful | |
| Penalty | Z: Issued | 04/28/2010 | $56,000.00 | 06/03/2010 | Willful |
Text For Citation: 01 Item/Group: 012 Hazard: REFINERY
29 CFR 1910.119(j)(4)(iii) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience. A. The employer did not ensure the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspection of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. The employer did not implement an inspection program of piping in the #1 Crude Unit at a frequency consistent with industry good practice; API 570. At the time of the inspection, the employer identified API 570 as the Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) used onsite. Multiple piping circuits were first inspected, both internal and external inspections, after the opening of the inspection. Piping circuit 10-076, inspected 11/25/09, although in service, was identified as having "0" remaining life. The employer was not able to provide prior inspection history for piping circuit 10-076. By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices, the employer was deprived of critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility. B. The employer did not ensure the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspection of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. The employer did not implement an inspection program of piping in the #1 Crude Unit at a frequency consistent with industry good practice; API 570. At the time of the inspection, the employer identified API 570 as the Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) used onsite. Multiple piping circuits were first inspected, both internal and external inspections, after the opening of the inspection. Piping circuit 10-091, inspected 11/30/09, although in service, was identified as "low thickness measurement needs to be replaced." The employer was not able to provide prior inspection history for piping circuit 10-091. By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices, the employer was deprived of critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility. C. The employer did not ensure the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspection of the facility from November 2009to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. The employer did not implement an inspection program of piping in the #1 Crude Unit at a frequency consistent with industry good practice; API 570. At the time of the inspection, the employer identified API 570 as the Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) used onsite. Multiple piping circuits were first inspected, both internal and external inspections, after the opening of the inspection. Piping circuit 10-208, inspected 11/20/09, although in service, was identified as "Thickness measurements of .104 inches with a minimum thickness of .101 inches were recorded." Being .003 inches from the minimum thickness would require extreme attention to ensure failure would not occur, yet the employer was not able to provide prior inspection history for piping circuit 10-208, or demonstrate that the piping was being closely monitored as it approached the minimum thickness. By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices, the employer was deprived of critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility. D. The employer did not ensure the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspection of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. The employer did not implement an inspection program of piping in the #1 Crude Unit at a frequency consistent with industry good practice; API 570. At the time of the inspection, the employer identified API 570 as the Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) used onsite. Multiple piping circuits were first inspected, both internal and external inspections, after the opening of the inspection. Piping circuit 10-215, inspected 11/22/09, although in service, was identified as "Thickness readings were measured at .170 inches and a minimum thickness of .168 inches." Being .002 inches from the minimum thickness would require extreme attention to ensure failure would not occur, yet the employer was not able to provide prior inspection history for piping circuit 10- 215, or demonstrate that the piping was being closely monitored as it approached the minimum thickness. By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices, the employer was deprived of critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility. E. The employer did not ensure the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspection of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT,84087. The employer did not implement an inspection program of piping in the #1 Crude Unit at a frequency consistent with industry good practice; API 570. At the time of the inspection, the employer identified API 570 as the Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) used onsite. Multiple piping circuits were first inspected, both internal and external inspections, after the opening of the inspection. Piping circuit 10-172, inspected 11/16/09, although in service, was identified as "Low thickness measurements are recorded at .101 inches to .104 inches which is at the calculated minimum thickness." The employer was not able to provide prior inspection history for piping circuit 10-072. By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices, the employer was deprived of critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility. F. The employer did not ensure the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspection of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. The employer did not implement an inspection program of piping in the #1 Crude Unit at a frequency consistent with industry good practice; API 570. At the time of the inspection, the employer identified API 570 as the Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) used onsite. Multiple piping circuits were first inspected, both internal and external inspections, after the opening of the inspection. Piping circuit 10-224, inspected 11/19/09, although in service, was identified as "..low thickness measurements that are at minimum thickness." The employer was not able to provide prior inspection history for piping circuit 10-224. By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices, the employer was deprived of critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility. G. The employer did not ensure the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspection of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. The employer did not implement an inspection program of piping in the #1 Crude Unit at a frequency consistent with industry good practice; API 570. At the time of the inspection, the employer identified API 570 as the Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) used onsite. Multiple piping circuits were first inspected, both internal and external inspections, after the opening of the inspection. Pipingcircuit10-173, inspected 11/16/09, although in service, was identified as "The piping TML is below minimum with a measured thickness of 0.99 inches." The employer was not able to provide prior inspection history for piping circuit 10-173. By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices, the employer was deprived of critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility. H. The employer did not ensure the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspection of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. The external inspection of MDDW RTR-30101 conducted on or about Oct. 10, 2007 did not follow Recognized and Generally Accepted Good Practices (RAGAGEP) in that no measurements of the nozzle thickness at the base of the reactor beyond the elbow of the nozzle were determined. Industry good practice, API 510, requires that a "representative number of thickness measurements must be conducted on each vessel". Guidance on establishing these locations is provided in API 510 "to establish general and localized corrosion rates in different sections of the vessel" API recommends that "those knowledgeable in localized corrosion mechanism be consulted about the appropriate placement and number of TMLs" and cautions that "it is important inspections are conducted using scanning methods such as profile radiography, scanning ultrasonics, and/or other suitable NDE methods that will reveal the scope and extent of localized corrosion" In addition, API 574 provides additional guidance for selection of TML's. By not following RAGAGEP and selecting more than (1) TML on the elbow, the employer did not identify corrosion patterns that were leading to accelerated thinning. As a result, the RTR-30101 nozzle failed catastrophically on November 4, 2009 exposing employees to hazards which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility I. The employer did not ensure that the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. Silver Eagle Refinery did not implement an inspection program of pressure equipment at a frequency consistent with industry good practice (API 510). On 1/08/10 an internal inspection of EXC-10207 was conducted. Comments from the Mistras inspector, hired by Silver Eagle, indicated that no previous corrosion rate had been established for this equipment even though it was constructed in 1963: "No history or documentation exists for this exchanger therefore the corrosion rate was estimated from the time of manufacture (1963)." By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices,the employer did not identify critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility. J. The employer did not ensure that the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. Silver Eagle Refinery did not implement an inspection program of pressure equipment at a frequency consistent with industry good practice (API 510). On 1/04/10 an internal inspection of EXC-10206 was conducted (MDDW 1-UOSH134). Comments from the Mistras inspector, hired by Silver Eagle, indicated that no previous corrosion rate had been established for this equipment even though it was constructed in 1960: "No history or documentation exists for this exchanger therefore the corrosion rate was estimated from the time of manufacture (1960)." By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices, the employer did not identify critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility. K. The employer did not ensure that the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. Silver Eagle Refinery did not implement an inspection program of pressure equipment at a frequency consistent with industry good practice (API 510). On 1/04/10 an internal inspection of EXC-10209A was conducted (MDDW 1-UOSH134). Comments from the Mistras inspector, hired by Silver Eagle, indicated that no previous corrosion rate had been established for this equipment even though it was constructed 45 years ago. By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices, the employer did not identify critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility. L. The employer did not ensure that the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, WoodsCross, UT, 84087. Silver Eagle Refinery did not implement an inspection program of pressure equipment at a frequency consistent with industry good practice (API 510). On 1/06/10 an internal inspection of EXC-10209B was conducted (MDDW 1-UOSH134). Comments from the Mistras inspector, hired by Silver Eagle, indicated that no previous corrosion rate had been established for this equipment: "The remaining life for this vessel could not be calculated due to no corrosion rate noted since this vessel was manufactured." By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices, the employer did not identify critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility. M. The employer did not ensure that the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. Silver Eagle Refinery did not implement an inspection program of pressure equipment at a frequency consistent with industry good practice (API 510). On 1/08/10 an internal inspection of EXC-10210 was conducted (MDDW 1-UOSH134). Comments from the Mistras inspector, hired by Silver Eagle, indicated that the actual thickness is thicker than the nominal thickness ascertained from the U1-A. By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices, the employer did not identify critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility. N. The employer did not ensure that the frequency of inspections and tests of process equipment were consistent with applicable manufacturers' recommendations and good engineering practices. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. Silver Eagle Refinery did not implement an inspection program of pressure equipment at a frequency consistent with industry good practice (API 510). On 12/28/09 an external inspection of TWR 10138 was conducted (MDDW 1-UOSH134). Comments from the Mistras inspector, hired by Silver Eagle, indicated that no previous corrosion rate had been established for this equipment: "No history or documentation exists for this column therefore the corrosion rate cannot be established at this time." By not conducting inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices, the employer did not identify critical information used to assess mechanical integrity of process equipment. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. Thismay be a system-wide occurrence that requires evaluation of all inspection and testing schedules, policies, and procedures throughout the facility.
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