Text For Citation: 01 Item/Group: 024 Hazard: REFINERY

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment th at were outside acceptable limits (as defined by process information in 29 CFR 1 910.119(d) before further use or in a safe and timely manner: a)The employer doe s not correct deficiencies in equipment that are outside acceptable limits (defi ned by the process safety information in paragraph (d) of this section) before f urther use or in a safe and timely manner when necessary means are taken to assu re safe operation. As described in the 2001 Calumet Lubricants Flare Study, cond ucted by Jacob and Associates LLC, the "Tower T-803 Fin Fan Failure" scenario in dicated that PSV-809, protecting T-803, set at 90 psig, size 4 x P x 6, would re lieve at the rate of 68933 lbs/hr. The current flare system in service onsite is designed for a maximum flow of 50,695 lbs/hr. As a result, should T-803 experience a fin fan failure (loss of cooling), the potential relieving flow would overpower the existing flare. As per P&ID SOL-A- 021A, PSV-809 is currently in service with a consolidated valve, style 1905PC-2, size 4 x P x 6, serial number TM03316. By n ot correcting deficiencies in equipment that are outside acceptable limits befor e further use or in a safe and timely manner, employees are exposed to potential equipment failures which can result in serious injury or death. This may be a s ystem-wide occurrence which would require the re-evaluation of all PSV's and fla re equipment design throughout the facility. This violation was documented on or about December 20, 2010. b)The employer does not correct deficiencies in equipm ent that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) bef ore further use or in a safe and timely manner when necessary means are taken to assure safe operation. As described in the 2001 Calumet Lubricants Flare Study, conducted by Jacob and Associates LLC, the "Tower T-700 Fin Fan Failure" scenar io indicated that PSV-702, protecting T-700, set at 115 psig, size 4 x M x 6, wo uld relieve at the rate of 117753 lbs/hr. The current flare system in service on site is designed for a maximum flow of 50,695 lbs/hr. As a result, should T-700 experience a fin fan failure (loss of cooling), the potential relieving flow wou ld overpower the existing flare. As per P&ID 700-A-003, PSV-702 is currently in service with a consolidated valve, style 1905MT-1, size 4 x M x 6, serial number TG-58158. By not correcting deficiencies in equipment that are outside acceptab le limits before further use or in a safe and timely manner, employees are expos ed to potential equipment failures which can result in serious injury or death. This may be a system-wide occurrence which would require the re -evaluation of all PSV's and flare equipment design throughout the facility. Thi s violation was documented on or about December 20, 2010. c)The employer does no t correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before furth er use or in a safe and timely manner when necessary means are taken to assure s afe operation. As described in the 2001 Calumet Lubricants Flare Study, conducte d by Jacob and Associates LLC, PSV-701 was undersized and not adequate based upo n the fire case relief scenario. As stated under the "Zone 8" summary, finding 1 , "Relief valve PSV-701 needs to be changed; it is not adequate, the relief valv e should be changed to a 1.5 x G x 2.5." Calculations in the relief study were b ased upon the larger"G" orifice size. Without a "G" orifice, per the flare study , the valve is too small. In 2008, nearly 7 years after the flare study was comple ted, the employer responded to the change stating the "valve never installed bec ause it was determined adequate protection was available with existing valve and equalization line to T-700." No additional design data or calculations were pro vided to support keeping the older, smaller valve in service. No adjustment to t he flare study was made to show a smaller valve orifice was adequate. Field veri fication of PSV-701 indicated a valve size "1 x E x 5" was currently present on D-700. By not correcting deficiencies in equipment that are outside acceptable l imits before further use or in a safe and timely manner, employees are exposed t o potential equipment failures which can result in serious injury or death. This may be a system- wide occurrence which would require the re-evaluation of all P SV's and flare equipment design throughout the facility. This violation was docu mented on or about December 20, 2010. d)Calumet is not ensuring that employees occupy buildings (containing cont rol equipment) which are adequately protected (i.e., adequately protected by sep aration or building construction) thereby exposing them to explosion, fire, toxi c material, corrosive material, or high pressure hazards resulting from the rele ase of highly hazardous chemicals from process equipment, in the 100, 400, and 1 100 Units. The building located in an unacceptable blast zone area is the facili ty control room. The control room is subject to potential overpressures of 14.7 psi. This building also does not comply with current RAGAGEP, such as but not li mited to API 752. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of t he date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including the steps that it is taking to en sure that employees are not being exposed to highly hazardous chemicals.