Text For Citation: 01 Item/Group: 027 Hazard: REFINERY

29 CFR 1910.119(l)(2)(ii): The written procedures to manage changes did not assu re that the impact of the change on safety and health was addressed prior to any change: a) The employer does not address all potential safety and health impacts of the change in the MOC procedure prior to the change. Review of MOC #2005-03, to allo w the hydrotreater throughput to increase to 5100 BPD, does not include the asse ssment of pressure relief systems. Per the MOC 2005-03 summary sheet, "PSV/Safet y Systems/Shutdowns" is not checked off on the list and no supporting documentat ion was provided demonstrating a review. No notes or indications on the MOC form show that the relief system was assessed and determined to be sufficient with t he throughput increase. By not fully evaluating all potential safety and health impacts, the employer was potentially deprived of critical information used to d etermine if the change is safe. This violation was documented on or about Decemb er 20, 2010. b) The employer does not address all potential safety and health im pacts of the change in the MOC procedure prior to the change. Review of MOC #200 2-13, 100/700 Unit feed train, does not include the assessment of pressure relief systems. Per documents provided, this MOC was conducted as a result of a throughput increase to 12000 BPD in the 100/700 Unit. Per the MOC 2002-13 summary sheet, "PSV/Safety Systems/ Shutdowns" is not checked off on the list and no supporting documentation was pr ovided demonstrating a review. No notes or indications on the MOC form show that the relief system was assessed and determined to be sufficient with the through put increase. By not fully evaluating all potential safety and health impacts, t he employer was potentially deprived of critical information used to determine i f the change is safe. This violation was documented on or about December 20, 201 0. c) The employer does not address all potential safety and health impacts of t he change in the MOC procedure prior to the change. Review of MOC #2002-49, T-70 0 Diesel Recovery Project, does not include the assessment of pressure relief sy stems. Per documents provided, this MOC was conducted as part of a redesign to enable Calumet Cotton Valley to recover diesel put of the resid bottoms. Per the MOC 2002-49 summary sheet, "PSV /Safety Systems/Shutdowns" is not checked off on the list and no supporting docu mentation was provided demonstrating a review. No notes or indications on the MO C form show that the relief system was assessed and determined to be sufficient with the throughput increase. By not fully evaluating all potential safety and h ealth impacts, the employer was potentially deprived of critical information use d to determine if the change is safe. This violation was documented on or about December 20, 2010. d) The employer does not address all potential safety and hea lth impacts of the change in the MOC procedure prior to the change. Review of MO C #2005-04, Solvents Unit Capacity Increase to 5100 BPD, does not include the as sessment of pressure relief systems. Per documents provided, this MOC was conduc ted as part of a redesign to increase throughput in the Solvents Unit to 5100 BPD. Per the MOC 2005-04 summary sheet, "PSV/Safety Sy stems/Shutdowns" is not checked off on the list and no supporting documentation was provided demonstrating a review. No notes or indications on the MOC form sho w that the relief system was assessed and determined to be sufficient with the t hroughput increase. By not fully evaluating all potential safety and health impa cts, the employer was potentially deprived ofcritical information used to determ ine if the change is safe. This violation was documented on or about December 20 , 2010. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in com pliance with the standard, including the steps that it is taking to ensure that ensure that management of change documentation is completed and employees are no t being exposed to highly hazardous chemicals.