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

29 CFR 1910.119(f)(1): The employer did not implement written operating procedur es that provide clear instructions for safely conducting activities involved in eac h covered process: This violation was documented on or about November 4, 2010 (u nless otherwise noted) when the following were noted: a)Approved shortcuts are t aken when performing Operating Procedure Rx-302 Shutdown/Startup Before / After Zinc Oxide Change-out procedure. According to the procedure, step 3.2.6 states " Repeat pressure up and bleed down three times", and step 3.3.1 states "Open nitr ogen flow ~ 25%." Operator interviews indicate that these deviations are not unu sual, and is not necessarily hazardous. The purpose of step 3.2.6 is to purge ox ygen from the equipment If the oxygen is low enough after a single purge there i s no reason to do more. The same goes for the nitrogen. Its purpose is to displa ce oxygen. 100% flow will do this faster than 25% flow. This is evidence that the abovementioned procedure is poorly written. If it said repeat step 3.2.6 until the oxygen concentration was below the maximum accepted value, there would be need to bypass steps. b)The employer failed to implement written operating procedures that provide clear instructions for safely conducting activ ities involved in each covered process consistent with the process safety inform ation. Review of the facility's "Inspection Procedure for Pressure Safety Valves and Rupture Disks", dated 3/20/2008, states that maintenance/inspection personn el are required to check "if block valves are present, (and) ensure that they ar e locked or car sealed open." Said policy requires block valves to be car sealed open. Multiple valves, including, but not limited to, valve #2598 (300 Unit) an d valve #2599 (300 Unit) were found to be in service and not car sealed open wit h a car seal or locking device. By not implementing written procedures, employees may be unaware of actual requirements and not take appropriate steps to ensure block valves are maintained in the open position. A s a result, valves could be inadvertently closed isolating relief devices. This violation was documented on or about December 20, 2010. This exposes employees t o fire and explosion hazards. Pursuant to 29 CFR 1903.19, within ten (10) calend ar days of the abatement date, the employer must submit an abatement plan descri bing the actions it is taking to ensure that procedures are well written and fol lowed properly.