Text For Citation: 01 Item/Group: 017 Hazard: CHEMICAL

29 CFR 1910.119(l)(1): The employer did not implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and changes to facilities that affect a covered process: (a)Suncor Energy (U.S.A.), Inc., 5801 Brighton Blvd., Commerce City, Colorado: On or about September 8, 2008, and at times prior thereto, the employer did not conduct a Management of Change to address the change in composition of the Unit 74 Sour Water Stripper Effluent which was injected into the overhead piping circuit including D-37, X-159 and D319 of the #1 Crude Unit, West Plant. Chemical changes included but were not limited to decreases in the levels of ammonia and MDEA in the sour water stripper effluent. This change in chemical content of the SWS effluent can be tied to increased corrosion and pipe failures in the referenced piping circuit. Employees are exposed to the hazards of hydrogen sulfide, and fire and explosion hazards due to loss of containment. (b)On or about December 17, 2008, and at times prior thereto, the employer did not conduct a Management of Change for the January 2008 installation of the gas detection system for the Asphalt Unit Control Room. Employees in this shelter-in- place building are subject to hazards related to overexposure to hydrogen sulfide and explosions and fire from the ignition of flammable vapors. (c)On or about December 17, 2008, and at times prior thereto, the employer did not conduct a Management of Change for the change of ventilation system and toxic contaminant detection systems used to protect employees in the West Plant Crude Unit control room and the construction of the CFT offices in the WP Old Lab. The conversion was completed on or about May 13, 2008. Employees in this shelter-in- place building are subject to hazards related to overexposures to hydrogen sulfide and explosions and fires from the ignition of flammable vapors. (d)On or about August 18, 2008, and at times prior thereto, the employer did not conduct a Management of Change when the throughput in the #1 Crude Unit changed. Employees are exposed to the hazards of hydrogen sulfide and fire and explosion hazards due to loss of containment. Abatement Note: Abatement certification and documentation are required for this item (see enclosed "Sample Abatement-Certification Letter").