Text For Citation: 01 Item/Group: 016 Hazard: REFINERY

29 CFR 1910.119(e)(6): The employer did not ensure after the initial process haz ard analysis that the process hazard analysis was updated and revalidated at lea st every five (5) years by a team meeting the requirements of 20 CFR 1910.119(e) (4) to assure that the process hazard analysis was consistent with the current p rocess: a)The employer does not consider in its 1100 Crude Unit PHA update/revalidation, the throughput increase and any potential effects the increase might have on th e adequacy of the current process, including the existing relief system. As prov ided by the employer, throughput design changes were made in 2002 for the 1100 C rude Unit to increase throughput to 3600 Barrels Per Day (BPD). The employer sta ted that in place of an MOC, a PHA would be conducted. Review of the 1100 Crude Unit PHA, dated 4/16/2002, did not identify where throughput was assessed. Data supporting evidence of evaluation, consultation with the refinery's engineering/ technical staff, and whether the existing/current engineering analysis of the re lief system is adequate for the new unit throughput is not in the PHA. Documents provided by the employer stated that "Calumet Lubricants Co. has reviewed the d esign to the piping associated with all Pressure Safety Valves (PSV's)...", but does not address throughput changes. A detailed review of the relief system and associated capacity is critical during any change to ensure th e current system can appropriately function with increased throughput. This viol ation was documented on or about December 20, 2010. b) The employer does not con sider in its 700 Unit PHA update/revalidation, the throughput increase and any p otential effects the increase might have on the adequacy of the current process, including the existing relief system. As provided by the employer, throughput d esign changes were made in 2003 for the 700 Unit to increase throughput to 5200 Barrels Per Day (BPD). The employer stated that in place of an MOC, a PHA would be conducted. Review of the 700 Unit PHA, dated 10/27/2004, does not identify wh ere throughput was assessed. Data supporting evidence of evaluation, consultatio n with the refinery's engineering/technical staff, and whether the existing/curr ent engineering analysis of the relief system is adequate for the new unit throu ghput is not in the PHA. Documents provided by the employer stated that "Calumet Lubricants C o. has reviewed the design to the piping associated with all Pressure Safety Val ves (PSV's)...", but does not address throughput changes. A detailed review of t he relief system and associated capacity is critical during any change to ensure the current system can appropriately function with increased throughput. This v iolation was documented on or about December 20. 2010. Pursuant to 29 CFR 1903.1 9, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, includ ing the steps that it is taking to ensure that employees are not being exposed t o highly hazardous chemicals.