Text For Citation: 02 Item/Group: 004 Hazard: REFINERY

29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process: a) Sunoco Marcus Hook Refinery - The employer did not conduct a Management Of Change (MOC) to manage changes to a covered process, as evident by the fact that the 17-1P was operated in "partial reverse mode", and the employer did not conduct an MOC, on or about 1/21/2009. b) Sunoco Marcus Hook Refinery - The employer did not conduct a Management Of Change (MOC) to manage changes to equipment in a covered process, as evident by the fact that a 2000 gallon skid-mounted ammonia storage tank with vaporizer and associated piping was installed in the 10-Plant on or about March 24, 2004, and the temporary MOC #10-420040323-2 associated with this change was not extended, removed, or made permanent, and the equipment was placed into operation before the Pre-Startup Safety Review (PSSR) was complete, and the equipment remained in operation approximately five years later, on or about 3/11/2009. c) Sunoco Marcus Hook Refinery - The employer did not conduct a Management Of Change (MOC) to manage changes to equipment in a covered process, as evident by the fact that a temporary MOC was initiated on 4/15/2005, for the installation of a new injection point and the modification of piping for the ammonia tank in 10 Plant, and the temporary change was complete and the MOC was removed before the Pre-Startup Safety Review (PSSR) was completed, on or about 3/11/2009. d) Sunoco Marcus Hook Refinery - The employer did not conduct a Management Of Change (MOC) to manage changes to equipment in a covered process, as evident by the fact that the 2,000 gallon skid-mounted ammonia storage tank was replaced in 2008, and the change included a change in how inventory of the storage tank was controlled, and the employer did not conduct an MOC to manage the change, on or about 5/05/2009. NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS REQUIRED 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 #4D and affirmed as a final order on 1/21/2008, with respect to a workplace located at the Philadelphia plant.