Text For Citation: 01 Item/Group: 026 Hazard: REFINERY

29 C.F.R. 1910.119(l)(1) The employer did not establish and implement written pr ocedures to manage changes (except for "replacements in kind") to process chemic als, technology, equipment, and procedures; and, changes to facilities that affect a covered process: a)The employer does not establish and implement written procedu res when there are changes in process equipment. Calumet did not establish writt en procedures to manage change when they operated a pressure vessel T-101 (leaki ng light hydrocarbons) which had a small hole present at the top of the vessel; and then continued to operate the pressure vessel with a temporary weld patch. C rude Tower, T-101 is designed to operate as-built, and any change from the origi nal design (operating the Tower with a hole and/or operating the tower with a te mporary patch is a change from original design. Crude Tower, T-101 is designed t o operate as-built, and any change from the original design (operating the Tower with a hole and/or operating the tower with a temporary patch is a change from original design. The unit was operated with light hydrocarbons being released for at least two da ys. This exposes employees to fire and explosion hazards. The violation was docu mented on or about October 28, 2010. b)The employer does not complete MOCs for a throughput increase and any potential effects the increase might have on the ad equacy of the current process, including the existing relief system. As provided by the employer, throughput design changes were made in 2002 for the 1100 Crude Unit to increase throughput to 3600 Barrels Per Day (BPD). The employer stated that in place of an MOC, a PHA would be conducted. Review of the 1100 Crude Unit PHA, dated 4/16/2002, did not identify where throughput was assessed, nor was a n MOC conducted. Data supporting evidence of evaluation, consultation with the r efinery's engineering/technical staff, and whether the existing/current engineer ing analysis of the relief system is adequate for the new unit throughput is not in the PHA and not in an MOC. A detailed revi ew of the relief system and associated capacity is critical during any change to ensure the current system can appropriately function with increased throughput. This violation was documented on or about December 20, 2010. Pursuant to 29 C. F. R. 1903.19, within ten (10) calendar days of the abatement date, the employer must submit documentation that it is in compliance with the standard, including describing the steps it is taking to ensure MOCs are conducted for all changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.