Text For Citation: 01 Item/Group: 012 Hazard: REFINERY

29 CFR 1910.119(d)(3)(ii): The employer did not document that the equipment in t he process complied with recognized and generally accepted good engineering prac tices: a)The employer does not document that pressure safety valve PSV-217 compl ies with RAGAGEP. The total backpressure on this valve exceeds approximately 23% of the valve's set pressure. As per API 520, Part 1, backpressure on conventional valve s should not exceed 10 % of the set pressure. Documents provided by the employer shows PSV-217 with a set pressure of 85 psig, with a total backpressure of 20.0 0 psig under the fire case scenario. Increased backpressure can result in valves not performing as designed. This violation was documented on or about December 20, 2010. b)The employer does not document that pressure safety valve PSV-809 co mplies with RAGAGEP. The total backpressure on this valve exceeds approximately 11% of the valve's set pressure. As per API 520, Part 1, backpressure on convent ional valves should not exceed 10 % of the set pressure. Documents provided by t he employer shows PSV-809 with a set pressure of 90 psig, with a total backpress ure of 10.17 psig under the fire case scenario. Increased backpressure can resul t in valves not performing as designed. This violation was documented on or about December 20, 2010. c)The emp loyer does not document that pressure safety valve PSV-810 complies with RAGAGEP . The total backpressure on this valve exceeds approximately 16% of the valve's set pressure. As per API 520, Part 1, backpressure on conventional valves should not exceed 10 % of the set pressure. Documents provided by the employer shows P SV-810 with a set pressure of 90 psig, with a total backpressure of 15.27 psig u nder the fire case scenario. Increased backpressure can result in valves not per forming as designed. This violation was documented on or about December 20, 2010 . d)The employer does not document that pressure safety valve PSV-1001 complies with RAGAGEP. The total backpressure on this valve exceeds approximately 11% of the valve's set pressure. As per API 520, Part 1, backpressure on conventional v alves should not exceed 10 % of the set pressure. Documents provided by the empl oyer shows PSV-1001 with a set pressure of 75 psig, with a total backpressure of 8.48 psig under the fire case scenario. Increased backpressure can result in valves not performing as designed. This violation was documented on or about December 2 0, 2010. e)The employer does not document that pressure safety valve PSV-1002 co mplies with RAGAGEP. The total backpressure on this valve exceeds approximately 28% of the valve's set pressure. As per API 520, Part 1, backpressure on convent ional valves should not exceed 10 % of the set pressure. Documents provided by t he employer shows PSV-1002 with a set pressure of 50 psig, with a total backpres sure of 14.17 psig under the fire case scenario. Increased backpressure can resu lt in valves not performing as designed. This violation was documented on or abo ut December 20, 2010. f)The employer does not document that pressure safety valv e PSV-1003 complies with RAGAGEP. The total backpressure on this valve exceeds approximately 23% of the v alve's set pressure. As per API 520, Part 1, backpressure on conventional valves should not exceed 10 % of the set pressure. Documents provided by the employer s hows PSV-1003 with a set pressure of 75 psig, with a total backpressure of 17.45 psig under the fire case scenario. Increased backpressure can result in valves not performing as designed. This violation was documented on or about December 2 0, 2010. g)The employer does not document that pressure safety valve PSV-1004 co mplies with RAGAGEP. The total backpressure on this valve exceeds approximately 11% of the valve's set pressure. As per API 520, Part 1, backpressure on convent ional valves should not exceed 10 % of the set pressure. Documents provided by t he employer shows PSV-1004 with a set pressure of 75 psig, with a total backpres sure of 8.96 psig under the fire case scenario. Increased backpressure can resul t in valves not performing as designed. This violation was documented on or about December 20, 2010. h)Calumet does not comply with RAGAGEP, such as, but not limited to API 752, CCPS, and AI ChE/Dow Fire and Explosion Index; in allowing employees to occupy inadequately p rotected (i.e., not adequately protected by separation or building construction) structures which are exposed to explosion, fire, toxic material, corrosive mate rial, or high pressure hazards resulting from the release of highly hazardous ch emicals from process equipment, in the Hydrotreater, 100, 400, and 1100 Units Th e buildings located in unacceptable areas of the blast zone include the main off ice, laboratory, and truck loading building. i)The employer does not document th at process equipment complies with RAGAGEP. Pressure vessel D-101 was not re-rat ed in accordance with API 510. The vessel is stamped at 75 psig at 250 F and was re-rated to 75 psig at 650. The re-rating of D-210 was addressed by MOC 2010-60. The MOC only contains information addressing the m etallurgy of the materials used in the vessels; indicating that they do not lose their properties at the new design temperature of 650 F. However, other informa tion required by API 510 and other codes has not been addressed. j)The employer does not document that process equipment complies with RAGAGEP. Pressure vessel D-210 was not re-rated in accordance with API 510. The vessel is stamped at 80 p sig at 100 F and was re-rated to 80 psig at 650. The re-rating of D-210 was addr essed by MOC 2010-61. The MOC only contains information addressing the metallurg y of the materials used in the vessels; indicating that they do not lose their p roperties at the new design temperature of 650 F. However, other information req uired by API 510 and other codes has not been addressed. k)The employer does not develop safe work practices to provide for the control of hazards during operations such as lockout/tagout. Per Calumet Lubricants Co. policy "Lockout & Tagout of Equipment", dated 5/03/2010, Section 13 Car Sealing, Subsection 13.2, "Block valves upstream and downstream of PSV's require a car s eal or car seal open (CSO) tag." This policy does not require a car seal or phys ical locking barrier. Per ASME Boiler and Pressure Vessel Code, Division 1, it s tates, intervening valves are allowed only when administrative controls are prov ided to prevent unauthorized valve operation and the valves are provided with me chanical locking elements. Examples ofmechanical locking elements per ASME inclu de, but are not limited to, locks with or without chains, and plastic or metal s traps. By not fully developing safe work practices, employees were not provided with clear instructions about what methods must be used to isolate valves and/or equipment. This violation was documented on or about December 20, 2010. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of this ci tation, the employer must submit documentation showing that it is in compliance with the standard, including the steps that it is taking to ensure that employee s are not being exposed to highly hazardous chemicals.