Text For Citation: 01 Item/Group: 023 Hazard: REFINERY

1910.1910.119(j)(4)(iii): The frequency of inspections and tests of process equi pment conducted by the employer is not consistent with good engineering practice s. This violation was observed on or about October 4, 2010 when in response to a re quest for documents; Calumet Lubricants, Cotton Valley Louisiana, provided infor mation related to the inspection of its piping and pressure vessels at the refin ery. a)Calumet is not completing visual inspections of its pressure vessels loca ted in Units 100, 300, 400, 800, and 1100 within the timeframes specified by con sensus standards, such as but not limited, to API 510. API 510 recommends a visu al inspection of all pressure vessels a minimum of every 5 years and a UT/intern al inspection at least every 10 years. The following pressure vessels have not b een inspected in accordance with RAGAGEP, such as but not limited to API 510. Ca lumet is not completing inspections of pressure vessels as required by the equip ment manufacturer. Pressure Vessels Unit 400 Pressure Vessels 1.T-401: Thickness measurements (UT-u ltrasonic thickness) A UT inspection was not performed by the required date of S eptember 15, 2010 for two TML (6" and 1" nozzle) in accordance with API 510 and the UltraPipe assessment calculated by Calumet. 2.FB-403: was manufactured in 19 99. There is no baseline UT information available for FB-403 and no UT data has ever been collected. Corrosion rates have not been calculated as per Calumet Lub ricants, Sections 5.1 and 5.2, Frequency of Inspections, and in accordance with API 510. A UT inspection was not performed by the required date of September 201 0. Moore model 5400 fans: The required manufacturer's inspections have not been performed to include an annual inspection of the system pressure, nuts and bolts , resilient mounts, and blade tips. Cooling Products, Inc.: The required manufac turer's inspections have not been performed to include: once each month the pitc h and angle and setting of the fan blades should be carefully checked; once ever y 60 days the motor bearings should be checked and lubricated if necessary. 3.R-40 1: was manufactured in 1954. A UT inspection was not performed every ten years i n accordance with API 510 and theUltraPipe assessment calculated by Calumet Lubr icants. Only one inspection was conducted between 1995 and 2008 and the 2008 ins pection has different TML points than the July 1995 UT inspection. No corrosion rate has been calculated as in accordance with API 510. 4.D-210: The manufacture date for D-210 is unknown and this pressure vessel was put into service by Calu met prior to 1995. A UT inspection was not performed for two specific TMLs by th e required dates of June 6, 2009 and June 28, 2010 in accordance with API 510 an d the UltraPipe assessment calculated by Calumet Lubricants. One TML is beyond i ts retirement date of April 28, 2010. Unit 100 Pressure Vessels 1.T-101: The man ufacture date for T-101 is unknown. Previous internal inspection and UT inspecti on were conducted in 2005. Corrosion rates have not been calculated as per Calum et Lubricants, Sections 5.1 and 5.2, Frequency of Inspections, and in accordance with API 510. A UT inspection w as not performed for four specific TMLs by the required date of November 29, 200 8 in accordance with API 510 and the UltraPipe assessment calculated by Calumet Lubricants. No inspections have been conducted in accordance with the API 510 ti meframe requirements for the nozzles and man-ways. 2.D-102: was manufactured in 1926. A UT inspection was not performed by the required dates of July 25, 2007, March 17, 2008 and November 6, 2008 for twelve TMLs in accordance with API 510 a nd the calculated UltraPipe assessment conducted by Calumet Lubricants. One TML is beyond its retirement date of April 28, 2010. There is a November 2005 recomm endation by the Calumet inspection team to replace D-102 (aka-Desalter). 3.E-102 : A UT inspection was not performed for six TMLs by the required date of Novembe r 20, 2010 in accordance with API 510. Unit 800 Pressure Vessels 1.T-801: was ma nufactured in 1956. There is no baseline UT information available for T-801 and the design maximum allowable working pressure (MAWP) of the vessel is not known. The previous internal inspection and UT inspections were conducted in 2005. Corrosion rates have not b een calculated as per Calumet Lubricants, Sections 5.1 and 5.2, Frequency of Ins pections, and in accordance with API 510. A UT inspection was not performed by t he required date of February 15, 2010. 2.D-301: The manufacture date for D-301 i s unknown but was put into service by Calumet prior to 1997. There is no baselin e UT or external visual inspection information available for D-301. The previous internal inspection was conducted in 2008 and UT inspection was conducted in 20 03. A UT inspection was not performed by the required date of July 24, 2010 in a ccordance with the inspection dates calculated by UltraPipe and the RBI assessme nt conducted by Calumet. 3.E-301A: The last UT inspection was conducted in June 2003. Only 7 of 18 TML were actually tested; missing UT data on the shell. A UT inspection was not performed by the required date of June 1, 2010 in accordance with the inspection dates calculated by UltraPipe and the RBI assessment conduct ed by Calumet. 4.E-302A: was manufactured in 1953. The last UT inspection was co nducted in July 2003 and this is the only recorded UT inspection. Only 10 of 18 TML were actually tested; and UT data is missing on the shell. A UT inspection w as not performed by the required date of July 23, 2010 in accordance with the in spection dates calculated by UltraPipe and the RBI assessment conducted by Calumet. 5.E-302B: was manufacture d in 1953. A UT inspection was not performed for specific TML by the required da te of June 1, 2009 or July 24, 2010 in accordance with the inspection dates calc ulated by UltraPipe and the RBI assessment conducted by Calumet. 6.RX-301: UT in spections were not performed for specific TML by the required dates of November 7, 2008, September 28, 2009, and April 30, 2010 in accordance with the inspectio n dates calculated by UltraPipe and the RBI assessment conducted by Calumet. RX- 301 is missing UT data on the shell, top head and bottom head. TML point #18 has exceeded its calculated retirement date. 7.RX-302: UT inspections were not perf ormed for specific TML by the required dates of November 7, 2008 and January 9, 2009 in accordance with the inspection dates calculated by UltraPipe and the RBI assessment conducted by Calumet. RX-302 is missing UT data on the shell, top he ad, 10" outlet, and 1.5" drain. TML point #19 has exceeded its calculated retire ment date, 5/2/2009. 8.RX-305: UT inspections were not performed by the required dates of November 7, 2008 and March 24, 2010 in accordance with the inspection dates calculated by UltraPipe and the RBI assessment conducted by Cal umet. RX-305 is missing UT data on the shell, top head and bottom head. 9.D-302: was manufactured in 1958. UT inspection was not performed by the required date of July 23, 2010 in accordance with the inspection dates calculated by UltraPipe by Calumet. UT data is missing on the shell, the bottom/top and head. External visual inspection of D-302 has been not conducted every five years and an intern al visual has not been performed every ten years. 10.FB-302, FB-303, FB203B: hav e not had an external visual inspection every five years as is required by API 5 10, 6.4. 11.E-302A: was manufactured in 1953 and the only record of inspection i s in 2003. A UT inspection was not performed by the required date of July 23, 20 10, in accordance with the inspection dates calculated by UltraPipe and used by Calumet Lubricants. 12.V-103: has not had an external visual inspection every fi ve years as is required by API 510, 6.4. Relief System Pressure Vessels 1.D-1501(knockout drum): was manufactured in 1947. D-1501 has not had an externa l visual inspection every five years as is required by API 510, 6.4. There has b een no UT inspection on this vessel since August 1984; hence, no internal or thi ckness measurement inspections have been conducted in the past ten years. 2.D-15 05 (knockout drum): was manufactured in 1970. D-1505 has not had an external vis ual inspection every five years as is required by API 510, 6.4. There has been n o UT inspection on this vessel since August 1976; hence, no internal or thicknes s measurement inspections have been conducted in the past ten years. b)Calumet i s not completing visual inspections of its piping systems located in the 100, 40 0, 1100, Treater and hydrotreater units within the timeframes specified by conse nsus standards, such as but not limited to, API 570. API 570 indicates that a vi sual inspection of Class I and Class II piping be performed every 5 years. API 5 70 also states that thickness measurements be performed every 5 years for Class I piping and every 10 years for Class II piping. The following piping circuits d id not have a visual and/or thickness measurements in accordance with API 570. Hydrotre ater Unit-Piping Circuits 1.HT030 Compressed gas HRG to E303 Class II 6"Piping: Thickness measurements- UT (UT-ultrasonic thickness) inspections were not perfor med by the required date of June 1, 2010 in accordance with UltraPipe and the RB I assessment calculated by Calumet. Calumet hasnot performed a visual inspection of this piping circuit every five years as is required by API 510, Table 6-1. 2 .HT030A Compressed gas HRG to FB-301 Class II 6"Piping: UT inspections were not performed by the required date of June 1, 2010 in accordance with the RBI assess ment conducted by Calumet. Calumet has not performed a visual inspection of this piping circuit every five years as is required by API 510, Table 6-1. 3.HT029 C ompressed gas RX304 to RX305 Class II 6" Piping: UT inspections were not perform ed by the required date of June 1, 2010 in accordance with the RBI assessment co nducted by Calumet. TMLs have not been established for TML points 1, 2, 6, and 7 . Calumet has not performed a visual inspection of this piping circuit every fiv e years as is required by API 510, Table 6-1. 4.HT019 RX-305 Bottoms to D-301 Class II 4 " and 6" Piping: UT inspections were not performed by the required date of June 1, 2010 in accordance with the RBI assessment conducted by Calumet. Calumet has not performed a visual inspection of this piping circuit every five years as is required by API 510, Table 6-1. 5.HT018 Compressed gas E302 to FB-301 Class II 4 " Piping: UT inspections were not performed by the required date of June 1, 2010 in accordance with the RBI assessment conducted by Calumet. Calumet has not per formed a visual inspection of this piping circuit every five years as is require d by API 510, Table 6-1. TML ports are missing on the insulated portion of the p iping. 6.HT015 D301-D303 Class II 3" Piping: UT inspections were not performed b y the required date of 6/1/10 in accordance with the RBI assessment conducted by Calumet. Calumet has not performed a visual inspection of this piping circuit e very five years as is required by API 510, Table 6-1. 7.HT009 E304- H301 Class I I 3" Piping: UT inspections were not performed by the required date of June 1, 2 010 in accordance with the RBI assessment conducted by Calumet. Calumet has not performed a visual inspecti on of this piping circuit every five years as is required by API 510, Table 6-1. TML ports are missing on the insulated portion of the piping. 8.HT007A HT-006-E 304C Class II 2" Piping: UT inspections were not performed by the required date of June 1, 2010 in accordance with the RBI assessment conducted by Calumet. Calu met has not performed a visual inspection of this piping circuit every five year s as is required byAPI 510, Table 6-1. 9.HT007 P301A/B-E301D Class II 3" Piping: UT inspections were not performed by the required date of June 1, 2010 in accor dance with the RBI assessment conducted by Calumet. Calumet has not performed a visual inspection of this piping circuit every five years as is required by API 510, Table 6-1. 10.HT004 D301-P-304A/B Class II 3" Piping: UT inspections were n ot performed by the required date of June 1, 2010 in accordance with the RBI ass essment conducted by Calumet. Calumet has not performed a visual inspection of t his piping circuit every five years as is required by API 510, Table 6-1. 11.HT003A P-304A/B Discharge-D304 Class II 3" Piping: UT inspections were not pe rformed by the required date of June 1, 2010 in accordance with the RBI assessme nt conducted by Calumet. Calumet has not performed a visual inspection of this p iping circuit every five years as is required by API 510, Table 6-1. 12.HT002A P 304A/B-E-302A/B Class II 3" Piping: UT inspections were not performed by the req uired date of 6/1/10 in accordance with the RBI assessment conducted by Calumet. Calumet has not performed a visual inspection of this piping circuit every five years as is required by API 510, Table 6-1. Treater Unit Piping 1.T-050 caustic from D509D-D-509B/C Class II 3/4" Piping: UT inspections were not performed by the required date of March 10, 2009 in accordance with the UltraPipe assessment conducted by Calumet. 2.T-051 caustic from D509A-D-509D Class II 2" Piping: UT i nspections were not performed by the required date of March 10, 2009 in accordan ce with the UltraPipe assessment conducted by Calumet. 400 Unit Piping Calumet has not performed a visual inspection of piping circuits 400-01 to 400-3 3 every five years as is required by API 570, Table 6-1. The following piping ci rcuits were not inspected: 1.400-01; D-210 to Tank 41 Class II Piping 2.400-02; D-210-Tank 41 Class II 2" Piping 3.400-03; D-210-T-800 Class II 1.5" Piping 4.40 0-04; D-210 from D101/1101 Class II 2" and 3" Piping 5.400-05; D-210 to P204A/B Class II 2" and 3" Piping 6.400-06; P204A/B Discharge to H-202 Class II 2" Pipin g 7.400-07; 2"-HL-400-004-1A1A Class II 2" Piping 8.400-08; D-210 Vent to PSV-21 7 Class II 2" and 3" Piping 9.400-09; D-210 Vapors Class II 1" Piping 10.400-10; T-401 Overhead to E-401 Class II 6" Piping:Calumet has not performed a visual inspection of this piping circuit every five years as is requ ired by API 570, Table 6-1. Also, baseline UT data was not collected on an injec tion point (which was leaking) and UT inspections of injection points on this pi peline circuit were not collected every three years in accordance with API 570, Table 6-1. 11.400-11; T-401 Overhead to D-401 Class II 6" Piping 12.400-12; Refl ux to T-401 Class II 2" and 3" Piping 13.400-13; P401A/B Discharge Class II 1" a nd 2" Piping 14.400-14; D-401 to P401A/B Suction Class II 3" Piping 15.400-15; E -401 to D-401 Class II 4" Piping 16.400-16; Makeup Gas to T-401 Class II 1" Pipi ng 17.400-17; D-401 Vapor to Fuel Drum Class II 2" Piping 18.400-18; T-401 to R4 01SS Class II 6" Piping 19.400-19; R401SS to T-401 Class II 10" Piping 20.400-20; T-401 Outlet to LCV-401 Loop Class II 2" and 3" Piping:Calumet has no t performed a visual inspection of this piping circuit every five years as is re quired by API 570, Table 6-1. Also, only eight of twenty TMLs established has UT data; therefore UT measurements are not collected in accordance with API 570. 2 1.400-21; T-401 Outlet to E-404 TS Class II 4" Piping:Calumet has notperformed a visual inspection of this piping circuit every five years as is required by API 510, Table 6-1. Also, only six of thirty-eight TMLs established has UT data; th erefore UT measurements are not collected in accordance with API 570. 22.400-22; T-401 to E-403A/B/C Class II 3", 4" and 6" Piping:Calumet has not performed a v isual inspection of this piping circuit every five years as is required by API 5 10, Table 6-1. Also, only one of twenty- five TMLs established has UT data; ther efore UT measurements are not collected in accordance with API 570. 23.400-23; T -401 Outlet to E-403A/B/C Class II 3" Piping:Calumet has not performed a visual inspection of this piping circuit every five years as is required by API 510, Ta ble 6-1. Also, only two of nineteen TMLs established has UT data; therefore UT m easurements are not collected in accordance with API 570. 24.400-24; E-403A/B/C to E-404 Class II 3" Piping:Ca lumet has not performed a visual inspection of this piping circuit every five ye ars as is required by API 510, Table 6-1. Also, no UT data has been collected fo r this circuit; therefore UT measurements are not collected in accordance with A PI 570. 25.400-25; E-403A/B/C to E-404 Class II 3" Piping:Calumet has not perfor med a visual inspection of this piping circuit every five years as is required b y API 510, Table 6-1. Also, only six of twenty-three TMLs established has UT dat a; therefore UT measurements are not collected in accordance with API 570. 26.40 0-26; E-404 to Inlet/Outlet Class II 3" Piping 27.400-27; E-404 to Inlet/Outlet Class II 3" Piping 28.400-28; FB-403 Outlet to Manifold Class II 3" Piping 29.40 0-29; FB-403 Outlet to Manifold Class II 3" Piping 30.400-30; FB-403 Outlet to M anifold Class II 2" Piping 31.400-31; E-204 Bypass to T-401 Class II 3"and "4 Piping 32.400-32; E-204 SS In /Out Class II 3"and 4" Piping:Calumet has not performed a visual inspection of t his piping circuit every five years as is required by API 570, Table 6-1. Also, only six of twenty-eight TMLs established has UT data; therefore UT measurements are not collected in accordance with API 570.33.400-33; H202 Hot Oil to T-401 C lass II 4" Piping:Calumet has not performed a visual inspection of this piping c ircuit every five years as is required by API 570, Table 6-1. Also, no UT data h as been collected for this circuit; therefore UT measurements are not collected in accordance with API 570. 100 Unit Piping Calumet has not performed a visual i nspection of piping circuit C-001 to C- 004; C-007 to C-020; and C-022 to C-040 every five years as is required by API 570, Table 6-1. The following piping circ uits were not inspected: Some UT inspections conducted provided UT data which wa s either anomalous or unreliable. These TMLs are then placed in a 5-10 year cycl e without retesting to determine an accurate reading. Consequently, the data col lected for these TML do not meet the frequency of testing requirements in accordance wi th API 570. 1.C-001 P-101 A/B to E-101A Class II 4" Piping 2.C-001A E-101 A/B to E-102 Class II 4" Piping 3.C-002 E-101A Shell side to E-101B Shell side Class I I 12" Piping 4.C-003 T-101 to E-101A/B Class II 12" Piping:Baseline UT data was not collected on injection points and UT inspections of injection points on this pipeline circuit were not collected every three years in accordance with API 57 0, Table 6-1. A UT inspection was not performed for TML 6 by the required date o f 11/16/2005 in accordance with API 570 and the calculated UltraPipe assessment conducted by Calumet. 5.C-004 H-101 to T-101 Class II 4" and 8" Piping:Calumet h as not performed a visual inspection of this piping circuit every five years as is required by API 570, Table 6-1. A UT inspection was not performed for TML 4 b y the required date of 11/17/2005 in accordance with API 570 and the calculated UltraPipe assessment conducted by Calumet. 6.C-007 E-102 to T-101/B Class II 2" Piping 7.C-008 T-101C to T-101 Class II 4" Piping:Calumet has not performed a visual inspection of this piping circuit ever y five years as is required by API 570, Table 6-1. A UT inspection was not perfo rmed for TML 4 by the required date of 11/14/2005 in accordance with API 570 and the calculated UltraPipe assessment conducted by Calumet. 8.C-009 T-101B to T-1 01 Class II 4" Piping:Calumet has not performed a visual inspection of this pipi ng circuit every five years as is required by API 570, Table 6-1. 9.C-010 T-101A to T-101 Class II 4" Piping:Calumet has not performed a visual inspection of th is piping circuit every five years as is required by API 570, Table 6-1. 10.C-01 1 T-101C to E-105 Shell side Class II 2" Piping:Calumet has not performed a visu al inspection of this piping circuit every five years as is required by API 570, Table 6-1. 11.C-012 T-101 to T-101C Class II 3" Piping:Calumet has not performe d a visual inspection of this piping circuit every five years as is required by API 570, Table 6-1. A UT inspection was not performed for TML 1,7,8 by the required date of 11/14/2005. 12.C-013 T-101 to T-101A Class II 3" P iping:Calumet has not performed a visual inspection of this piping circuit every five years as is required by API 570, Table 6-1. A UT inspection was not perfor med for TML 1, 4, 5 by the required date of 11/14/2005. 13.C-014 T-101 to T-101B Class II 3" Piping:Calumet has not performed a visual inspection of this piping circuit every five years as is required by API 570, Table 6-1. A UT inspection was not performed for TML 1, 2, 3 by the required date of 11/14/2005. 14.C-015 T -101A to FB-101 Class II 3" Piping 15.C-016 P-101 Discharge to Tank 39 Class II 2" Piping 16.C-017 FB-7 to P-101A Class II 2" Piping 17.C-018 E-102 Shell side t o FB-7 Class II 2" Piping 18.C-019 FB-101B-1/2 to P-106 Class II 2" Piping:Calum et has not performed a visual inspection of this piping circuit every five years as is required by API 570, Table 6-1. 19.C-020 E-105 Shell side to FB-101C Class II 2" Piping:Calumet has not performe d a visual inspection of this piping circuit every five years as is required by API 570, Table 6-1. 20.C-022 P-101C Discharge to Tank 39 Class II 2" Piping:Calu met has not performed a visual inspection of this piping circuit every five year s as is required by API 570, Table 6-1..21. C-023 Natural Gas to H-101 3"and 4" Class II 2" Piping 22.C-024 H-101 Heater Inlet from E-707 and E-715 Class II 6" Piping: Calumet has not performed a visual inspection of this piping circuit eve ry five years as is required by API 570, Table 6-1. 23.C-025 FB-101C Fin Fan to D-103 and 29 Tank Class II 2" Piping 24.C-026 P101-B to 39 and 29 Tanks Class II 2" Piping 25.C-027 D-101 and P-104A/B Class II 4" and 6" Piping:Calumet has not performed a visual inspection of this piping circuit every five years as is req uired by API 570, Table 6-1. 26.C-028 P-104A/B Discharge Class II 4" Piping:Calu met has not performed a visual inspection of this piping circuit every five years as is requ ired by API 570, Table 6-1. 27.C-029 P-104A/B to T-101 Reflux Class II 4" Piping 28.C-030 E-105 to D-102 Desalter Class II 4" Piping 29.C-031 D-101 to Fuel Gas Class II 2" Piping:Calumet has not performed a visual inspection of this piping circuit every five years as is required by API 570, Table 6-1. A UT inspection w as not performed for TML 1, and 2 by the required date of 11/14/2005. No UT insp ection has been performed for TML 4, 5, 6, 7 in accordance with API 570. 30.C-03 2 T-101 to P-103 A/B Suction Class II 4" Piping:Calumet has not performed a visu al inspection of this piping circuit every five years as is required by API 570, Table 6-1. 31.C-033 P-103 A/B Discharge to D-700 Class II 3" Piping:Calumet has not performed a visual inspection of this piping circuit every five years as is required by API 570, Table 6-1. A UT inspection was not performed for TML 1, an d 2 by the required date of 11/14/2005. 32.C-034 P-103 A/B Discharge Class II 3" Piping:Calumet has not performed a visual inspection of this piping circuit every five years as is requ ired by API 570, Table 6-1. A UT inspection was not performed for TML 3 and 4 by the required date of 11/14/2005. 34.C-035 FB-101 to D-101 and E-103 Class II 6" Piping 35.C-036 D-102 to 700 Charge Drum Class II 6" Piping:Calumet has not per formed a visual inspection of this piping circuit every five years asis required by API 570, Table 6-1. A UT inspection was not performed for TML 2 by the requi red date of 11/14/2005 and TML 4 by the required date 1/18/2009. 36.C-037 D-102 to E-102 and E-105 Class II 4" Piping:Calumet has not performed a visual inspect ion of this piping circuit every five years as is required by API 570, Table 6-1 . A UT inspection was not performed for TML 1 and 3 by the required date of 11/1 4/2005. 37.C-038 E-105 to D-102 Class II 4" Piping:Calumet has not performed a v isual inspection of this piping circuit every five years as is required by API 5 70, Table 6-1. 38.C-039 Crude Pumparound from SK-37 to SK-37:Calumet has not per formed a visual inspection of this piping circuit every five years as is required by API 570, Table 6-1. 39.C-040 E-102 to E-105 Class II 4" Piping 4" 1100 Unit Piping Calumet has not performed a visual inspection of piping circui t 1100-01 to 1100-26 every five years as is required by API 570, Table 6-1. The following piping circuits were not inspected: 1.11-001 H-1101 to T-1101 Class II 6" Piping:Calumet has not performed a visual inspection of this piping circuit every five years as is required by API 510, Table 6-1. Only two of five establis hed TMLs has UT data; therefore UT measurements have not been collected every 10 years in accordance with API 570 and the Calumet RBI assessment. No baseline UT data was collected and no corrosion rate for this piping circuit has been estab lished in accordance with API 570, Section 7.1.2. TML ports are missing on the i nsulated portion of the piping. 2.11-001A H-1101 Outlet to T-1101 Class II 6" Pi ping 3.11-002 T-1101 to T-1102 Class II 8" Piping 4.11-003 P-1101 A/B Suction from T-1102 Class II 8" Piping 5.11-004 P-1101 A/B D ischarge to T-1101 Class II 8" Piping:Calumet has not performed a visual inspect ion of this piping circuit every five years as is required by API 570, Table 6-1 . Only one of six established TMLs has UT data; therefore UT measurements have n ot been collected every 10 years in accordance with API 570 and the Calumet RBI assessment. No baseline UT data was collected and no corrosionrate has been esta blished for the TMLs not tested in accordance with API 570, Section 7.1.2. TML p orts are not accurately reflected on the isometric drawing. 6.11-005 T-1102 Over head to E-1102 Class II 4" and 8" Piping 7.11-006 T-1102 to D-1102 Class II 4" a nd 8" Piping 8.11-007 Feed to T-1102A from T-1102 Class II 3" Piping 9.11-008 T- 1102A from T-1102 Class II 3" Piping 10.11-009 T-1102A to E-1102 Class II 2" Pip ing 11.11-011 T-1101 Bottom Outlet Class II 2" Piping 12.11-012 H-1101 Inlet from E- 707 Class II 3" Piping 13.11-013 FB-1101 & E-1101 to D-1101 Class II 4" Piping 1 4.11-014 FB-1101 Outlet to TCV-110A Class II 4" Piping 15.11-015 E-1101 Outlet t o FB-1101 Class II 4" Piping 16.11-016 D-1101 Relief Class II 2" Piping:Calumet has not performed a visual inspection of this piping circuit every five years as is required by API 510, Table 6-1. Only one of two established TMLs has UT data ; therefore UT measurements have not been collected every 10 years in accordance with API 570 and the Calumet RBI assessment. No baseline UT data was collected and no corrosion rate has been established for the TMLs not tested in accordance with API 570, Section 7.1.2. TML ports are not accurately reflected on the isom etric drawing. 17.11-017 P-1102 A/B Suction Class II 2" and 3"Piping 18.11-018 F B-1102 Outlet to Storage Class II 2" Piping 19.11-019 FB-1102 Outlet to Storage Class II 2" Piping 20.11-020 D-1101 Outlet t o Blue Drum 1 Class II 1" Piping 21.11-021 Inlet to E-1101 Class II 4" Piping 22 .11-022 E-1101 Tube Side to E-1102 Class II 4" Piping 23.11-023 E-1102 Inlet Tub e Side Class II 4" Piping24.11-024 E-1102 to FB-1103 Class II 4" Piping 25.11-02 5 FB-1103 to Storage Class II 2" Piping 26.11-026 H-203 Inlet/Outlet Class II 2" Piping Relief System Piping Circuits 1.Calumet has not performed a visual inspe ction or UT inspection of the flare system piping circuits FH-1 to FH-20 as is r equired by API 570, Table 6-1. Pursuant to 29 CFR 1903.19(d), within 10 days, th e employer must submit an abatement plan describing the actions it is taking to ensure that an a visual inspection i s completed. The violation must be abated no later than 60 days from the receipt of this citation.