Text For Citation: 02 Item/Group: 001 Hazard: REFINERY

29 CFR 1910.119(d)(3)(i)(B): Process safety information pertaining to the equipment in the process did not include the piping and instrument diagrams (P&ID'S): a) Sunoco, Marcus Hook, 10-4 Plant - Sunoco did not ensure that the P&IDs accurately represented the following equipment for the process: 1) Various vessel and exchanger information tables did not include each vessel's/exchanger's design and operating pressures and/or temperatures. These vessels/exchangers included but were not limited to: A) V-17 & V113 on P&ID:26005A, sheet 02 B) E-7 & E-9A/B on P&ID:26005A, sheet 10 C) V-15 & V22 on P&ID: 25005A, sheet 26 D) E-15A/B/C on P&ID:26005A, sheet 14 E) E-8A/B & T-3 on P&ID:26005A, sheet 13 F) E94A/B on P&ID:26005A, sheet 08 G) V-11 & V-12 on P&ID:26005A, sheet 04 H) E-16 & T-4 on P&ID:26005A, sheet 01 2) Various intervening block valves upstream & downstream of relief valves which had been identified by Sunoco as being part of the car-seal program, were not identified as such on the P&IDs as being car-sealed open. Intervening block valves not identified on the P&IDs as being car-sealed included but were not limited to: A) Block valves for RV-101, P&ID:26005A, sheet 08 B) Block valves for RV-102, P&ID: 26005A, sheets 04 &08 C) Block valve for Flare Header, P&ID:A-28409, sheet 01 D) Upstream block for SV-31, P&ID: 26005A, sheet 13 E) Downstream block valve for SV-157, P&ID:26005A, sheet 13 F) Downstream block valve for SV-20C, P&ID:26005A, Sheet 14 G) Downstream block valve for SV-20B, P&ID:26005A, Sheet 14 H) Downstream block valve for SV-20A, P&ID:26005A, Sheet 14 I) Block valves for RV-155, P&ID:26005A, Sheet 14 J) Downstream block valve for RV-153, P&ID:26005A, Sheet 14 K) Downstream block valve for RV-154, P&ID:26005A, Sheet 14 L) Upstream block valve for SV-17A, P&ID:26005A, Sheet 26 M) Upstream block valve for SV-17B, P&ID:26005A, Sheet 26 N) Block valves for RV-158, P&ID:26005A, Sheet 10 O) Block valves for SV-21, P&ID:26005A, Sheet 10 P) Block valves for RV-159, P&ID:26005A, Sheet 10 Q) Block valves for RV-22B, P&ID:26005A, Sheet 10 R) Downstream block valve for RV-22A, P&ID:26005A, Sheet 10 S) Downstream block valve for RV-159, P&ID:26005A, Sheet 10 T) Downstream block valve for RV-160, P&ID:26005A, Sheet 10 U) Block valves for RV-131, P&ID: 26005A, sheet 02 3) Various relief valves located on P&IDs did not have any set pressure values identified. Those relief valves included but were not limited to: A) SV-24A, P&ID: 26005A, sheet 02 (Gas Compressor Discharge Drum, V-17) B) SV-24B, P&ID: 26005A, sheet 02 (Gas Compressor Discharge Drum, V-17) C) RV-158, P&ID: 26005A, sheet 10 (E-7, Shell side) D) RV-121, P&ID: 26005A, sheet 16 (E-96C/D, shell side) E) RV-???, P&ID: 26007A, sheet 09 (R28 Separator) F) RV-???, P&ID: 26007A, sheet 09 (R29 Separator) 4) Downstream block valves of relief valves were not identified on the P&IDs. These unidentified downstream block valves included but were not limited to: A) Block valve downstream of SV-20C, P&ID: 26005A, sheet 14 B) Block valve downstream of SV-20B, P&ID: 26005A, sheet 14 5) Relief valves are not identified on the P&IDs. These valves include, but are not limited to: A) E-16 exchanger on P&ID: 26005A sheet 1 B) R28 Separator on P&ID 26007A, sheet 9 C) R29 Separator on P&ID 26007A, sheet 9 6) Specific relief valves identified in the P&IDs do not have accurately corresponding serial numbers within the PCMS & Marlin systems. Such valves included but were not limited to: A) E-94: 1) RV-101, tube side relief, is wrongly identified (PCMS) as having valve SV-2576 installed with actual valve being SV-4312 2) RV-102, shell side relief, is wrongly identified (PCMS) as having valve SV-2578 installed with actual valve being SV-2576 B) E-15A: 1) RV-153, shell side relief, is wrongly identified (PCMS) as having valve SV-0962 installed with actual valve being SV-6062 2) SV-20C, tube side relief, is wrongly identified (PCMS) as having valve SV-2062 installed with actual valve being SV-0962 C) E-15B: 1) On the PCMS SV-3429 is identified as being for both tube & shell side relief valves (RV-154 & SV-20B) 2) RV-154, shell side relief, is wrongly identified (PCMS) as having valve SV-2315 installed with actual valve being SV-2439 D) E-15C: 1) SV-20C, shell side relief, is wrongly identified (PCMS) as having valve SV-2068 installed with actual valve being SV-6068 Deficiencies listed above were observed & documented between 2/2/2009 and 4/27/2009. Sunoco, Inc. was previously cited for a violation of this Occupational Safety and Health Standard or its equivalent standard, which was contained in OSHA Inspection: #312716386, Citation #1, Item #1A and affirmed as a final order on 1/21/2008, with respect to a workplace located at the Philadelphia plant. NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS REQUIRED