Text For Citation: 01 Item/Group: 013 Hazard:

29 CFR 1910.119(i)(2)(i): The pre-startup safety review did not confirm that construction and equipment is in accordance with design specifications prior to the introduction of highly hazardous chemicals to a process: a) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - The employer's pre-startup safety review (PSSR) failed to confirm that prior to the introduction of highly hazardous chemicals (HHC) into the DCU process that the construction and equipment is in accordance with design specifications when field verification, inspection, and testing was not conducted and documented in Limetree's Vessels and Exchangers Checklist. In particular, the employer failed to complete the following items prior to startup: restore missing cladding on internal surfaces of Coke drums, correct corrosion under insulation (CUI) on Coke drums, correcting pitting on Blowdown Drum Overhead Separator (D-8513), and Flare Knockout Drum (D-7941), and restore pressure vessel fireproofing. Failure to confirm pressure vessels meet design specifications and inadequate inspection and testing can result in loss of containment and expose employees to fire, toxic, and explosion hazards. b) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - The employer's PSSR failed to confirm that prior to the introduction of HHC into the DCU process that the construction and equipment is in accordance with design specifications when field verification, inspection, and testing was not conducted and documented in Limetree's Piping and Pipe Support Checklist. In particular, the employer failed to complete the following items prior to startup: correct corrosion on flanges and bolts, inspect insulated piping for CUI, label all process piping, restore fireproofing on pipe supports, and verify all piping is adequately supported. Failure to confirm piping and pipe supports meet design specifications and inadequate inspection, and testing can result in loss of containment from piping and expose employees to fire, toxic, and explosion hazards. c) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU), the employer's PSSR failed to confirm that prior to the introduction of HHC into the DCU process that the construction and equipment is in accordance with design specifications when the following items in Limetree's Safety Valves Checklist were not completed and documented. In particular, the employer failed to complete the following items prior to startup: verify inlet outlet of pressure relief devices/vacuum relief devices are inspected for fouling in plugging, evaluate the potential for external pressure (vacuum) during pump-out from TK-8501, verify relief device sizing calculations are adequate, and verify isolation valves that may inhibit operation of relief valves are controlled in accordance with car seal program and included on a list. Failure to confirm safety valves meet design specifications and inadequate inspection, and testing can result in loss of containment and expose employees to fire, toxic, and explosion hazards. d) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - The employer's PSSR failed to confirm that prior to the introduction of HHC into the DCU process that the construction and equipment is in accordance with design specifications when field verification, inspection, and testing was not conducted and documented in Limetree's Heaters Checklist. In particular, the employer failed to complete the following items prior to startup: verify heater tubes were adequately inspected including taking wall thickness measurements of tubes in convection section, establish criteria for heater inspections including locating condition monitoring locations for heater tubes, bends and fittings, and restoring fireproofing as required. Failure to confirm heaters meet design specifications and inadequate inspection, and testing can result in loss of containment and expose employees to fire, toxic, and explosion hazards. e) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - The employer's PSSR failed to confirm that prior to the introduction of HHC into the DCU process that the construction and equipment is in accordance with design specifications when Limetree's Instrumentation Checklist failed to complete the following prior to startup. In particular, the employer failed to complete the following items prior to startup: verify instruments were inspected and tested and results documented, verify instrument air lines and process tubing are cleaned and flushed, verify that all safety systems (i.e. emergency shutdown, interlocks, fire, flammable and toxic gas detectors are tested and documented, and verify distributed control system (DCS) alarms are appropriate (i.e. no redundant alarms, nuisance or confusing alarms are present. Failure to confirm instrumentation meets design specifications and inadequate inspection, and testing can result in upset process conditions and loss of containment, exposing employees to fire, toxic, and explosion hazards. f) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - The employer's PSSR failed to confirm that prior to the introduction of HHC into the DCU process that the construction and equipment are in accordance with design specifications when field verification, and inspection, was not conducted and documented for occupied buildings. In particular, the PSSR did not include any requirements for buildings. In particular, the Coker Unit Operator Shelter Building (#8503) was not adequately designed as a shelter in place to protect occupants in the event of a fire, explosion or toxic release in accordance with API 752 - Management of Hazards Associated with Location of Process Plant Permanent Buildings and LIMETREE BAY TERMINALS L.L.C. LIMETREE BAY REFINING L.L.C. Integrated Contingency Plan St. Croix, United States Virgin Islands September 2020. Failure to confirm buildings meet design specifications and not equipping occupied buildings with the means to detect, alarm, and control toxic vapor ingress during an emergency can expose employees to fire, toxic, and explosion hazards. g) On or about May 12, 2021, at Limetree Bay Refining, LLC., Delayed Coker Unit (DCU) - The employer's PSSR failed to confirm that prior to the introduction of HHC into the DCU process that the construction and equipment is in accordance with design specifications when field verification, inspection, and testing was not conducted and documented in Limetree's. In particular, the PSSR did not include any requirements for storage tanks in the Coker Unit, including the Vacuum Residuum Tank (TK-8501). Failure to confirm storage tanks meet design specifications and inadequate inspection and testing resulted in the vacuum collapse of the tank and exposed employees to fire, toxic, and explosion hazards.