Text For Citation: 01 Item/Group: 009 Hazard: REFINERY

29 CFR 1910.119(j)(2) Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment. A. The employer did not establish and implement adequate written procedures to maintain the on-going integrity of process equipment, specifically policies and procedures which incorporate Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) to maintain the on-going integrity of pressure vessels. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. Documents provided as the facility's Mechanical Integrity Program (MI), last updated on March 16, 2006, Version 1:2, were inadequate. During review of Silver Eagle's Standard Policies and Procedures No. 4.1, titled "Mechanical Integrity", and Standard Policies and Procedures No. 4.2, titled "Pressure Vessel Inspection Manual", both did not list API 579 Fitness for Service (FFS) for inspection or API RP 572 Inspection of pressure Vessels (Towers, Drums, Reactors, Heat Exchangers and Condensers). By not identifying and following RAGAGEP's specific to pressure vessels, policies and procedures may not identify critical components of inspection and operations that may lead to catastrophic failures. Such failures can expose employees to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of mechanical integrity programs, policies, and procedures throughout the facility. B. The employer did not establish and implement policies and procedures which incorporate Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) to maintain the on-going integrity of process equipment. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. Documents provided as the facility's Mechanical Integrity Program (MI), last updated on March 16, 2006, Version 1:2, were inadequate. The employer did not implement API 579 Fitness for Service (FFS) to demonstrate the structural integrity of an in-service component that may contain a flaw or damage. The guidelines provided in API 579 are used to make run-repair-replace decisions to help determine if pressurized equipment containing flaws can continue to operate safely for some period of time. Silver Eagle's Mechanical Integrity Program outline did not reference API 579. An adequate written Mechanical Integrity Program would have contained policies and procedures directing employees to perform a Fitness For Service evaluation on the leaking tube in the Crude #2 Heater when employees found it smoking and leaking on July 22, 2009. By not identifying and following RAGAGEP's specific to Fitness for Service (FFS), policies and procedures may not identify critical components of inspection and operations that may lead to catastrophic failures. Such failures can expose employees to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of mechanical integrity programs, policies, and procedures throughout the facility. C. The employer did not establish and implement adequate written procedures to maintain the on-going integrity of process equipment, specifically policies and procedures which incorporate Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) to maintain the on-going integrity of covered process piping. This violation was identifiedduring inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. Documents provided as the facility's Mechanical Integrity Program (MI), last updated on March 16, 2006, Version 1:2, were inadequate. During review of process documents, it was identified that the employer consistently did not keep records regarding MI of covered piping as evidenced by the recent flurry of piping inspections which proceeded without any historical context such as previous inspection records, retirement dates, next inspection interval or previously determined corrosion rates. An adequate written MI Program would have contained policies and procedures directing employees to keep piping records. These written policies and procedures would have instructed employees to keep piping records based on the RAGAGEP: 1.API 570 Piping Inspection Code, Section 7.6 which mandates: a.Fabrication, Construction, and design information b.Inspection History c.Repair, Alteration, re-rating information d.Fitness-For-Service Assessment Documentation 2.API RP 574 Inspection Practices for Piping System Components which recommends piping inspections records include: a.Original date of installation b.Material specs and strengths c.Original thickness measurements d.Location and dates of all subsequent thickness measurements e.Calculated retirement thickness f.Previous repair/replacements g.Pertinent operational changes By not identifying and following RAGAGEP's specific to piping, policies and procedures may not identify critical components of inspection and operations that may lead to catastrophic failures. Such failures can expose employees to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of mechanical integrity programs, policies, and procedures throughout the facility.