Text For Citation: 01 Item/Group: 022 Hazard: REFINERY

1910.119(j)(4)(ii): The inspections and testing procedures did not follow recogn ized and generally accepted good engineering practices: a.The employer's inspect ions and testing procedures for collecting thickness measurements do not follow recognized and generally accepted good engineering practices such as API 510 (20 06), Section 5.6.2.1; which specifies that the thickness for all major component s (shells, heads, cone sections) and a representative sample of vessel nozzles s hould be measured and recorded. Calumet is not performing the proper inspections on the following pressure vessels: 1. T-802: Ultrasonic thickness (UT) measurem ents have not been performed. 2. T-101: UT measurements have not been performed. 3. E-302: UT measurements hav e not been performed. 4. T-401: UT measurements have not been performed. 5. RX-3 02: UT measurements have not been performed. 6. RX-305: UT measurements have not been performed. 7. D-302: UT measurements have not been performed. 8. E-301A: U T measurements have not been performed. b.The employer's inspections and testing procedures for classifying piping systems containing flammable liquids and gase s do not follow recognized and generally accepted good engineering practices suc h as API 570. API 570 classifies piping which contains C3, C4, and C5 liquids an d gases as Class 1 piping. Calumet Lubricant's inspection records classify all piping in the 400 Unit as Class II p iping. Examples of piping circuits, which should be classified as Class I becaus e they contain methane, ethane, C3, C4, or C5 liquids and gases are, such as but not limited to the following: 1. 400-08; D-210 Vent to PSV-217 Class II 2" and 3" Piping 2. 400-09; D-210 Vapors Class II 1" Piping 3. 400-10; T-401 Overhead t o E-401 Class II 6" Piping 4. 400-11; T-401 Overhead to D-401 Class II 6" Piping 5. 400-12; Reflux to T-401 Class II 2" and 3" Piping 6. 400-13; P401A/B Dischar ge Class II 1" and 2" Piping 7. 400-14; D-401 to P401A/B Suction Class II 3" Pip ing 8. 400-15; E-401 to D-401 Class II 4" Piping 9. 400-16; Makeup Gas to T-401 Class II 1" Piping 10. 400-17; D-401 Vapor to Fue l Drum Class II 2" Piping 11. 400-18; T-401 to R401SS Class II 6" Piping 12. 400 -19; R401SS to T-401 Class II 10" Piping 13. 400-20; T-401 Outlet to LCV-401 Loo p Class II 2" and 3" Piping 14. 400-21; T-401 Outlet to E-404 TS Class II 4" Pip ing Calumet is not correctly classifying piping located in the 400 Unit. API 570 recommends UT inspection of Class I piping every 5 years and Class II piping ev ery 10 years. Therefore, incorrectly classifying piping circuits will result in longer periods between inspection cycles; potentially resulting in a catastrophi c event should a pipe become too thin and rupture. c.The employer is not conducting audits of its internal inspection program to de termine if it is meeting the requirements of the inspection code. During this in spection, deficiencies such as: missing or incorrect TML locations, missing or i ncorrectly entered TML values, TML that are not reproducible, and inaccurate iso metric drawings were identified. API 570, Section 5.13 indicates that an interna l audit be conducted periodically to determine the following: 1. The requirement s and principles of this inspection code API 570 are being met; 2. All-owner use r responsibilities are being properly discharged; 3. Intervalsand extent of insp ections are adequate for covered piping systems; 4. All general types of inspect ions and surveillance are being adequately applied; 5. Inspection data analysis, evaluation, and recording are adequate; 6. All repairs, re-ratings, and alterations comply with this code. d.The employe r's inspection and testing procedures for its Risk Based Inspection (RBI)Program is not in accordance with API 580 (2009). The Calumet Lubricants RBI program do es not include or consider the following: 1. As per API 580, Section 16, RBI ass essments should be team-based and include a team leader, inspector, corrosion sp ecialist, process specialist, operations personnel, maintenance personnel, safet y and environmental manager, and management; 2. As per API 580 Section 7 the RBI assessment should have clear goals and objectives; 3. As per API 580, Section 6 .6.2 is a logical and structured process for planning and evaluating inspection activities for pressure equipment; 4. As per API 580, Section 7.3.4 the first st ep in the application of RBI is screening of entire process units to rank relative risk. The screening points ou t areas that are higher in priority and suggests which process to begin with; 5. As per API 580 an RBI plan should be completed. The Calumet Lubricants RBI prog ram has not been incorporated into, delineated or included in the Calumet Mechan ical Integrity/Quality Assurance Manual. Calumet Lubricants does not have an RBI program meeting the criteria of API 580. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the abatement date, the employer must submit documentatio n showing that it is in compliance with the standard, including the steps that i t is taking to ensure that all inspection and testing procedures follow recogniz ed and generally accepted good engineering practices:g