Violation Detail
Standard Cited: 19100119 J04 I Process safety management of highly hazardous chemicals.
Inspection Nr: 314767104
Citation: 01021
Citation Type: Serious
Abatement Date: 03/31/2011 X
Initial Penalty: $7,000.00
Current Penalty: $7,000.00
Issuance Date: 03/14/2011
Nr Instances: 7
Nr Exposed: 35
Related Event Code (REC):
Gravity: 10
Report ID: 0625700
Contest Date: 04/04/2011
Final Order: 04/11/2012
Emphasis:
Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
---|---|---|---|---|---|---|
Penalty | Z: Issued | 03/14/2011 | $7,000.00 | Serious |
Text For Citation: 01 Item/Group: 021 Hazard: REFINERY
29 CFR 1910.119(j)(4)(i): Inspections and tests were not performed on process eq uipment to maintain its mechanical integrity: a)The employer did not require Cha rter Chambers, LLC to perform inspections and tests on process equipment to main tain its mechanical integrity. As per the "Pressure Relief Valve Test & Inspecti on Report", dated 1/26/2010, PSV-2(900) was not subjected to an "as received pop test." As a result, the pop test was not performed. This violation was document ed on or about December 20, 2010. b)The employer did not require Charter Chambers, LLC to perform inspections and tests on process equipment to maintain its mechanical integrity. As per the "Pre ssure Relief Valve Test & Inspection Report", dated 8/24/2010, PSV-1403 was not subjected to an "as received pop test." As a result, the pop test was not perfor med. This violation was documented on or about December 20, 2010. c)The employer did not require Charter Chambers, LLC to perform inspections and tests on proce ss equipment to maintain its mechanical integrity. As per the "Pressure Relief V alve Test & Inspection Report", dated 8/24/2010, PSV-1404 was not subjected to a n "as received pop test." As a result, the pop test was not performed. This viol ation was documented on or about December 20, 2010. d)The employer is not conduc ting inspection and testing of underground piping systems. Calumet failed to complete visual and UT piping inspections for any of its under ground piping systems as specified by consensus standards, such as but not limit ed to API 570. API 570 recommends a visual inspection of Class I and Class II pi ping every 5 years, and UT testing of Class I piping every 5 years and Class II piping every 10 years. Calumet did not inspect underground piping until OSHA was onsite. The following underground piping circuits did not have a visual inspect ion within the specified time frame: 1. D1501 to P1501 A/B flare drum liquid to pump 2. D1506 to sump at truck loading dock (piping was not coated and wrapped 3 . D1505 to P1517 knockout drum adjacent to treater to pump suction. The employer violated this standard on or about October 9, 2010, when it was determined that Calumet Lubricants failed to conduct inspectionss and testing of its undergroun d piping. e)The employer is not conducting inspection and testing of insulated piping. Cal umet failed to complete piping inspections for any of the insulated piping as sp ecified by consensus standards, such as but not limited to API 570. The employer has not effectively implemented its mechanical integrity program, Section 9.3 a nd 14, Corrosion Under Insulation (CUI). During this, inspection it was determin ed that Calumet did not conduct corrosion under insulation (CUI) inspections for all piping circuits located in the 100, 400, and 1100 Units. The employer viola ted this standard on or about October 9, 2010, when it was determined that Calum et Lubricants failed to conduct inspectionss and testing of its insulated piping . f)The employer is not conducting inspection and testing of deadleg piping. Cal umet failed to complete piping inspection and testing for deadleg piping, as spe cified by consensus standards, such as but not limited to API 570. The employer has not effectively implemented its mechanical integrity program, Section 3.1(b), 9.2, and 14, "Dead legs". During this, inspection it was determined that Calumet did not conduct in spections of deadleg piping for piping circuits located in the 100, 400, and 110 0 Units. Deadleg piping was identified on piping circuits such as, but limited t o the following: 400-001, 400-004, 400-005, 400-006, 400-009, 400-010, 400-013, 400-022, 400-023, 400-028,400-031, 400-032, 400-033. The employer violated this standard on or about October 9, 2010, when it was determined that Calumet Lubric ants failed to conduct inspectionss and testing of its deadleg piping. g)The emp loyer did not ensure that critical valves were inspected at a frequency consiste nt with applicable manufacturers' recommendations and good engineering practices. T he employer violated this standard on or about January 5, 2011 when an investiga tion discovered there was no documentation to indicate the following critical va lves were inspected or tested: FSV-113(900), FSV-114(900), FSV-115(900), FSV-307 (900), FSV- 309(900), FSV-310(900), FSV-311(900), and VGV 1402. The employer vio lated this standard on or about October 9, 2010, when in response to a request f or documents Calumet Lubricants-Cotton Valley did not provide information relate d to the inspection of its underground piping or piping is insulated at the refi nery. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of t his citation, the employer must submit documentation showing that it is in compl iance with the standard, including the steps that it is taking to ensure that em ployees are not being exposed to highly hazardous chemicals. The employer must include in the abatemen t plan information describing the actions it is taking to ensure that an asbesto s survey will be completed. The violation must be abated no later than 60 days f rom the receipt of this citation.