Text For Citation: 01 Item/Group: 020 Hazard: REFINERY

29 CFR 1910.119(j)(2): The employer did not establish and implement written proc edures to maintain the on-going mechanical integrity of process equipment: a)The employer does not establish and implement written procedures to ensure the on-g oing integrity of process equipment. Specifically PSV-306 and PSV-1403 had the w rong spring. The mechanical integrity program does not include procedures which would prevent the installation of pressure safety valves which contain incorrect parts. During a review of Pressure Safety Valves (PSV), PSV-306 and PSV-403 were identi fied as containing incorrect parts, specifically PSV-306 had the wrong spring. A s a result, both valves failed a leak test. Calumet Lubricants Co. "Mechanical I ntegrity Requirements", dated 12/03/2008, contains subsections related to inspec tion and testing of PSVs, but does not address procedures for ensuring that corr ect internal components are installed in all PSVs. The result is deficient equip ment was in service within the refinery. Incorrect internal parts in PSV can res ult in the PSV not functioning as designed which could result in catastrophic eq uipment failures. b)The employer does not establish and implement adequate writt en procedures. Mechanical The mechanical integrity program does not include proc edures which would prevent the installation of pressure safety valves containing the wrong parts. During CSHO a review of Pressure Safety Valves (PSV's) covered by the Mechanical Integr ity Program, PSV-507 and PSV-512 were identified as containing incorrect parts, specifically the wrong upper washer, spring, lower washer, and disc holder. Alth ough the Calumet Lubricants Co. "Mechanical Integrity Requirements", dated 12/03 /2008, contains subsections related to inspection and testing of PSV's and ruptu re disks, the policies and procedures do not contain procedures for ensuring tha t correct internal components are installed in all PSV's. As a result, PSV's are in service with incorrect internal components. By not establishing and implemen ting a comprehensive mechanical integrity program, deficient equipment was in se rvice within refining units. Incorrect internal parts in PSV's can result in the PSV not functioning as designed. Such an event can lead to catastrophic equipme nt failures. c)The employer is not implementing adequate procedures to ensure the on-going in tegrity of process equipment. The employer's written Mechanical Integrity proced ure 3.2(g) states "Run nut to 1" of stud shows past the nut." This procedure has not been implemented in the 1100 Unit resulting in the presence of "short bolts " in the following process equipment. Line 2" HL-1100-027-1A1A on the LCV-1123 c ircuit on the flange connecting the Valtek Valve to the line. Line 4" HL-1100-01 7-1A1A on the TCV-1100B circuit on the flange connecting the Valtek Valve to the line. Line 4" HL-1100-017-1A1A on the LCV-1123 circuit on the flange connecting the horizontally-orientated Valtek Valve to the line.Line 2" HL-1100-024-A2-1-2 on the FCV-1114 circuit on the flange connecting the vertically-orientated Valt ek Valve to the line. Line 3" HL-1100-023-A2-1-2 on the 1102 circuit on the flan ge connecting the vertically-orientated Valtek Valve to the line. "Short Bolts" are bolts that are not in accordance with Mechanical Integrity Pro gram 3.2(g), "Run nut to 1" of stud shows past the nut". This violation was obse rved on or about October 01, 2010. d)The employer does not establish and impleme nt written procedures to ensure the identification and resolution of anomalous i nspection data as part of its on-going mechanical integrity program. The followi ng anomalous data was identified: Piping Circuits Missing, incorrectly recorded or incorrect location of TML ports: C-001, C- 001A, C-003, C-004, C-006, C-008, C-011, C-012, C-013, C-016, C-018, C- 024, C-025, C-030, C-031, C-032, C-034, C- 037, C-038, C-039, C-040, 11-004, 11-016; 400-12, 400-18, 400-19, 400-20, 400-21 1100-1, 1100-1A, 1100-3, 1100-13, 1100-15, 1100-18, 1100-19, 1100-23 TML ports are missing on the insulated portion of the piping. HT018, HT009, 400-005, 400-0 21, 400-022, 400-033 UT data not recorded on the pipe or in the database: C-001, C-001A, C-004, C- 03 0, C-037. Incorrectly recorded UT data: C-016, C-018, C-028 No isometric drawing or incorrect isometric (different than 2000 isometric) drawing, or TML points m issing on the drawing C-004, C-005/005A, C-007, C- 010, C-011, C-013, C-014, C-0 15, C-016, C-018, C-023, C-031, C-032, C-033, C-034, C-037, C-038, 11-004, 11-01 6; 400-011, 400-20, 1100-02, 1100-3, 1100- 5, 1100-15, 1100-20 Thickness Measure ment Locations not tested 11-001 -two of five established TML have UT data 11-00 4 -one of six established TML has UT data. 11-016 -one of two established TMLs h as UT data. 400-20 -eight of twenty TML established have UT data. 400-21 -six of thirty-eight TML established have UT data. 400-22 -one of twenty-five TML estab lished has UT data. 400-23 -two of nineteen TML established have UT data. 400-24 -no UT data has been collected for this circuit.400-24 -no UT data has be en collected for this circuit. 400-25 -only six of twenty-three TML established have UT data. 400-32 -only six of twenty-eight TML established have UT data. 400 -33 -No UT data has been collected for this circuit. Thickness Monitoring Locati ons which are not reproducible D-1001: The pressure vessel has been painted so t he current TML are not reproducible. D-210: The pressure vessel has been painted so the current TML are not reproducible. R-401: Only one inspection was conduct ed between 1995 and 2008 and the 2008 inspection has different TML points than t he July 1995 UT inspection. Thickness measurements that increase over time UT te st data is entered into the UlraPipe system. When the thickness of pipe is found to be larger than the previous measurement; the UltraPipe program enters an "RR " notation adjacent to the test result to notify the user that the value is a potential error (metal pipe cannot grow in thickness). It is then incumbent upon the user to resolve this value (i.e., re-take the meas urement, calibrate the equipment, establish a new baseline, etc.). Calumet has n ot implemented a written program to resolve thickness monitoring results that ar e greater than those obtained during the previous inspection. e)Calumet is not i mplementing a program to ensure appropriate corrosion rates are established for piping in accordance with the Calumet "Inspection Procedure for Piping Systems". Section 5.2 requires that "initially the ultrasonic thickness measurements shal l be repeated every two years to confirm the corrosion rate. For most of the pip ing vessels in Units 100, 400, and 1100, the thickness monitoring inspections ar e not conducted every two years in accordance with the program. This is particul arly critical for this facility since in many instances they cannot reproduce ol d TML or the old TML have been abandoned and replaced with new TML; and hence no corrosion rate have been established for many piping circuits. No baseline UT data was collected and no corrosion rates have been established for piping circuit such as but not lim ited to the following. 11-001 H-1101 to T-1101 11-004 P-1101 A/B Discharge to T- 1101 11-016 D-1101 Relief FH-1 to FH-20400-008 f)Calumet has not established and implemented a written program that ensures that historical UT measurements whic h are at or beyond their retirement date are resolved or reconciled. Piping and pressure vessels operated beyond their thickness retirement date have a greater chance of rupture resulting in flammable vapor clouds and the potential for fire and explosion. TC-1 Crude Tower (T-101) 1994 Alltech Inspection Report TML pointInspection Date Expected Life (years)TML Retire Date N-221/944.14 years2/98 S-21/941.36 years5/9 5 Crude Unit Piping 1994 Alltech Inspection Report TML pointInspection DateExpec ted Life (years)TML Retire Date C016-1501/940 years1/94 C016-1701/940 years1/94 Naphtha Piping 1990 Walter Rossler Company Inspection Report Naptha Piping Circu its- Naptha 01 to Naptha-051 Calumet Inspection Program D-210: TML is beyond its retirement date of April 28, 2010. D-102: TML is beyond its retirement date of April 28, 2010. There is a November 2005 recommendation by the Calumet inspectio n team to replace D- 102 (aka-Desalter). RX-301: TML point #18 has exceeded its calculated retirement date. RX-302: TML point #19 has exceeded its calculated retirement date, 5/2/20 09. g)Calumet did not comply with RAGAGEP, such as but not limited to NFPA 496, by failing to implement a preventative maintenance schedule/ program for the pos itive pressure control system located in the refinery control room. During this inspection OSHA found the positive pressure control system present in the refine ry control room was not operational and there is no preventative maintenance pro gram in place which addresses this equipment. Indicators (functional magnehelic gauge and audible alarm) of a functioning positive pressure control system were not operational. Pressurization is used to keep a positive pressure in a buildin g for the purpose of keeping harmful or hazardous vapors from entering.Pursuant to 29 CFR 1903.19, within ten (10) calen dar days of the date of this citation, the employer must submit documentation sh owing that it is in compliance with the standard, including the steps that it is taking to ensure that employees are not being exposed to highly hazardous chemi cals.