Text For Citation: 01 Item/Group: 018 Hazard: REFINERY

1910.119(f)(1)(ii): The employer did not develop and implement written operating procedures that address operating limits, consequences of deviation from those lomits, and/or methods for correcting deviations from the operating limits: This violation was observed on or about October 6, 2010 when it was noted that operating limits are not addressed in the following operating procedures. a)Solv ent Section Emergency Operations procedure dated 8/20/2010 Item 3.1.6 directs op erators to "Maintain Reflux rate on FIC-806 to T-803." It does not say what the rate is or what it should be, or how to correct the rate if it's wrong, or list consequences of deviation. FIC-806, the reflux flow controller, is listed in the Solvent Unit Alarm Response Table, but the Normal Operating Range is defined as "proportional to charge rate." Since it doesn't say what the proportion is, the re is no way of knowing what the normal value is. The alarm set points for this parameter are available in the DCS, but alarm set points are not necessarily the same as operating limits. Item 3.1.9 directs operators to "Maintain Reflux rate on T-207, T801, and T 802 at normal rates." It does not say what the rate is or what it should be, or how to correct the rate if it's wrong, or list consequences of deviation. The Solvent U nit Alarm Response Table, lists the Normal Operating Range for reflux rate for T -802, but not the others." The alarm set points for this parameter are available in the DCS, but alarm set points are not necessarily the same as operating limi ts. Item 3.1.13 directs operators to "Hold Level in T-202 and maintain normal re flux rate." It does not say what the level should be, what the normal reflux rat e is, how to correct either if it's wrong, or list consequences of deviation. Th e Solvent Unit Alarm Response Table, lists the Normal Operating Range for T-202 level, but not reflux rate." The alarm set points for this parameter are availab le in the DCS, but alarm set points are not necessarily the same as operating li mits. Item 3.1.17 contains a NOTE that requires the operator to "Watch the reflu x rate and hold at normal rate." It does not say what the normal reflux rate is, h ow to correct either if it's wrong, or list consequences of deviation. FIC-806, the reflux flow controller, is listed in the Solvent Unit Alarm Response Table, but the Normal Operating Range is defined as "proportional to charge rate." Sinc e it doesn't say what the proportion is, there is no way of knowing what the nor mal value is. The alarm set points for this parameter are available in the DCS, but alarm set points are not necessarily the same as operating limits. Item 3.1. 18 directs operators to "Hold Level in T-800 and maintain normal reflux rate." I t does not say what the level should be, what the normal reflux rate is, how to correct either if it's wrong, or list consequences of deviation. LIC-800, the T- 800 level controller is listed in the Solvent Unit Alarm Response Table, but the re is no listing for a Reflux rate controller or any information on what the reflux rate shouldbe. The alarm set points for this parameter are available in the DCS, but alarm set points are not necessarily the same as operating limits. Item 3.1.23 c ontains a NOTE that requires the operator to "Watch the pressure on T- 600. Make -up gas may have to be added to hold positive pressure." It does not indicate ho w much positive pressure is desirable vs. how much is too much, how to correct e ither if it's wrong, or list consequences of negative pressure. This information is not in the Solvent Unit Alarm Response Table. The alarm set points for this parameter are available in the DCS, but alarm set points are not necessarily the same as operating limits. Item 3.5.5 directs the operator to "Monitor T-800 ope rations - adjust reboiler heat input. It does not say what parameter(s) T-800 sh ould be monitored, what the normal parameters are, how to correct what's wrong, or list consequences of deviation. It also doesn't say how much adjustment is required/allowed, how to correct what 's wrong, or list consequences of deviation. This information is not in the Solv ent Unit Alarm Response Table. The alarm set points for this parameter are avail able in the DCS, but alarm set points are not necessarily the same as operating limits. Item 3.6.2 directs the operator to "Increase T-803 O/H production - moni tor FIC-814. It does not say how much of an increase is required/ allowed in the O/H production nor what to monitor FIC-814 for. There are no consequences of de viation or steps to correct them. FIC-814 is not listed in the Solvent Unit Alar m Response Table. The alarm set points for this parameter are available in the D CS, but alarm set points are not necessarily the same as operating limits. Item 3.8.4 states "Monitor T-803 flash-in temperature." There is no indication in either the procedure or the Solvents Alarm Response Tables of what the pressu re should be. There are no consequences of deviation or steps to correct them. T he alarm set points for this parameter are available in the DCS, but alarm set p oints are not necessarily the same as operating limits. Item 3.9.3, Item 3.10.2, and Item 3.11.2 state "Decrease hot oil flow to R-800 as applicable." There is nothing in the procedure or the Solvents Alarm Response Table that indicates wha t "as applicable" means. The alarm set points for this parameter are available i n the DCS, but alarm set points are not necessarily the same as operating limits . Item 3.19.2 states "Reduce reboiler heat input." There is nothing to indicate how much to reduce it. There is no indication in either the procedure or the Sol vents Alarm Response Tables of what the pressure should be. There are no consequences of deviation or steps to correct them. The alarm set points for this parameter a re available in the DCS, but alarm set points are not necessarily the same as op erating limits. Item 3.21.2 states "Decrease heat input to tower bottom." There is nothing toindicate how much to reduce it. There is no indication in either th e procedure or the Solvents Alarm Response Tables of what the pressure should be . There are no consequences of deviation or steps to correct them. The alarm set points for this parameter are available in the DCS, but alarm set points are no t necessarily the same as operating limits. Item 3.27.2 states "Decrease heat in put to tower bottom." There is nothing to indicate how much to reduce it. There is no indication in either the procedure or the Solvents Alarm Response Tables of what the pressure should be. There are no cons equences of deviation or steps to correct them. The alarm set points for this pa rameter are available in the DCS, but alarm set points are not necessarily the s ame as operating limits. Item 3.28.2 states "Reduce reboiler heat input." There is nothing to indicate how much to reduce it. There is no indication in either t he procedure or the Solvents Alarm Response Tables of what the pressure should b e. There are no consequences of deviation or steps to correct them. The alarm se t points for this parameter are available in the DCS, but alarm set points are n ot necessarily the same as operating limits. b)Hydrotreater Unit Emergency Opera tions procedure dated 11/04/2009 Item 5.4 of Section 5, Leak in Process Line or Vessel, directs the operator to "Shut down the heater." There is guidance for how to do this in Section 4, He ater Tube Failure, but there is no reference to lead the operator to Section 4. Item 18.6 of Section 18, Loss of Recycle Hydrogen Compressor, directs the operat or to "Shut down the heater." There is guidance for how to do this in Section 4, Heater Tube Failure, but there is no reference to lead the operator to Section 4. Items 4.8, 5.3, and 6.6 of the procedure, direct the operator to "Control pre ssure with HY-320." There is no indication in either the procedure or the Hydro- Treater Alarm Response Tables of what the pressure should be. Item 14.1 requires the operator to decrease the heater outlet to control RX-304 inlet temperature. There is a NOTE in this step that describes how to calculate the new setpoint. Item 13.2 also requires the operator to decrease the heater outlet to control RX-304 inlet temperature, but there is no note giving guidance for calculating t he new setpoint. c)100 Unit Emergency Operations procedure dated 8/24/10 Step 3. 7.2 says "Monitor Stripper levels. Adjust LCV as necessary." It does not say wha t the levels should be and there are no LCVs at all listed in the 100 Unit Alarm Response Tables. The alarm set points for this parameter are available in the D CS, but alarm set points are not necessarily the same as operating limits.This e xposes employees to fire and explosion hazards. Pursuant to 29 CFR 1903.19, with in ten (10) calendar days of the abatement date, the employer must submit an aba tement plan describing the actions it is taking to ensure that operating procedu res include normal operating limits for the operating parameters associated with the procedure.