Violation Detail
Standard Cited: 19100119 J04 I Process safety management of highly hazardous chemicals.
Inspection Nr: 312412356
Citation: 01010
Citation Type: Serious
Abatement Date: 06/01/2014 X
Initial Penalty: $56,000.00
Current Penalty: $3,000.00
Issuance Date: 04/28/2010
Nr Instances: 32
Nr Exposed: 24
Related Event Code (REC):
Gravity: 10
Report ID: 0854910
Contest Date: 05/27/2010
Final Order: 10/23/2013
Emphasis:
Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
---|---|---|---|---|---|---|
Penalty | P: Petition to Mod Abatement | 04/18/2014 | $3,000.00 | 06/01/2014 | Serious | |
Penalty | F: Formal Settlement | 10/23/2013 | $3,000.00 | 02/20/2014 | Serious | |
Penalty | Z: Issued | 04/28/2010 | $56,000.00 | 06/03/2010 | Willful |
Text For Citation: 01 Item/Group: 010 Hazard: REFINERY
29 CFR 1910.119(j)(4)(i) Inspection and testing: Inspections and tests shall be performed on process equipment. A. The employer did not adequately inspect and test the #2 Crude Unit Crude Heater, FUR- 20250, following an incident on July 22, 2009 when oil was observed spraying from a split tube. 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. At the time of the incident, the employer was required to make a decision to run, repair, or replace the failed tube. Per the incident summary (MDDW 1-UOSH205 0002): a. The furnace was taken off-line to assess problem b. Employer found tube leak c. Contractor (Mistras) performed NDE by ultra-sonic on lower half of vertical tubes d. Pressure tested tube bundle with steam e. Found additional leaks f. Decision made to replace entire tube bundle Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) offer testing procedures and a basis for making such a decision. Documents were requested by UOSH for any and all inspection reports associated with this incident. The employer's submission for Document Request MDDW 1-UOSH-205 did not include an inspection report even though the incident summary indicates that one was performed. Documents provided by the employer did not demonstrate that a RAGAGEP was used as a determination for returning the #2 Crude Unit Heater (FUR-20250) to service. Without an adequate inspection, a crude heater tube may leak and then crude would fill the furnace box. A furnace fire or pool fire might occur if containment is lost exposing employees to hazardous conditions which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all inspection and testing procedures throughout the facility. B. The employer did not adequately inspect and test pressure safety valves, specifically performing "as-received" pop pressure tests. 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. Inspections and tests were not performed on process equipment to maintain mechanical integrity of Pressure Safety Valves. Per API 510 Section 6 "pressure-relieving devices shall be tested and inspected at intervals that are frequent enough to verify that the valves perform reliably in the particular service conditions." API 576 Section 6, states "the pop pressure of the valve when removed from service should be estimated...this as-received test pressure should be recorded for review and facilitation of any necessary corrective action." Valves, including, but not limited to PSV-29401 protecting TWR-20250 (MDDW 1-UOSH36 0008), PSV-59139 protecting VES-50104 (MDDW 1-UOSH36 0010), and PSV-39422 protecting TWR-30103 (MDDW 1-UOSH36 0011) did not receive an "as-received" pop pressure test. These 3 valves were removed from service and sent to NEVCO, Inc. for clean/repair/inspect services. The employer did not instruct NEVCO to perform an as-received pop pressure test. On the three Test Certificates from 2008 and 2009, NEVCO Q.C. Supervisor wrote in the Pre-Test Information box that only a "Standard Repair" was requested and performed. As-received, pop pressure test for pressure safety valves is essential for the refineryinspector to know at what pressure the old valve would have relieved at, to assess risk, to form an opinion regarding the next inspection date, or to recommend the installation of protective rupture discs. In the event of an equipment failure, employees could be exposed 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 all pressure safety valves throughout the facility. C. The employer did not adequately inspect piping restraints on the discharge piping from pressure safety valves. 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. Inspections and tests were not performed on process equipment to maintain Mechanical Integrity. Field observations identified multiple restraints were disconnected and/or corroded. Examples include, but are not limited to, discharge piping from pressure safety valves PSV 39410 and PSV 39421. By not inspecting discharge piping from pressure safety valves, the disconnected/failed discharge piping restraint may allow the PSV and its connected piping to fail catastrophically from unrestrained reaction forces during a release event. In the event of an equipment failure, employees could be exposed 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 all discharge piping from pressure safety valves throughout the facility. D. The employer did not ensure that inspections and tests were performed on process equipment, specifically external inspections 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform external inspections of some pressure vessels, specifically COL-10201, for the period between 1992 (promulgation of OSHA PSM Standard) and November 4, 2009 (opening date of this inspection). Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require external inspection of pressure vessels at least every 5 years. Policies and procedures provided by the employer as MDDW 1-UOSH-48, state: "Frequency - Each vessel above ground shall be given a visual external inspection, preferably while in operation, at least every five years or at the same interval as required internal or on-stream inspection, which ever is less." Without adequate external inspections to detect anomalous surface conditions, the vessel could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all process equipment throughout the facility. Note: Per requirements established by the State of Utah, Boiler and Pressure Vessel Code, R616-2-8 and associated Boiler and Pressure Vessel Compliance Manual, Revision 8b, external inspections of pressure vessels must be conducted and inspection intervals may not exceed 60 months. E. The employer did not ensure that inspections and tests were consistently performed onprocess equipment, specifically external inspections 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform external inspections of some pressure vessels, specifically EXC- 10202. External inspection and thickness measurements were taken in December 2008 but no previous external inspections in 2003, 1998 and 1993 had been conducted. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require external inspection of pressure vessels at least every 5 years. Policies and procedures provided by the employer as MDDW 1-UOSH-48, state: "Frequency - Each vessel above ground shall be given a visual external inspection, preferably while in operation, at least every five years or at the same interval as required internal or on- stream inspection, which ever is less." Without adequate external inspections to detect anomalous surface conditions, the vessel could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all process equipment throughout the facility. Note: Per requirements established by the State of Utah, Boiler and Pressure Vessel Code, R616-2-8 and associated Boiler and Pressure Vessel Compliance Manual, Revision 8b, external inspections of pressure vessels must be conducted and inspection intervals may not exceed 60 months. F. The employer did not ensure that inspections and tests were performed on process equipment, specifically external inspections 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform external inspections of some pressure vessels, specifically TWR-20250, for the period between 1992 (promulgation of OSHA PSM Standard) and November 4, 2009 (opening date of this inspection). Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require external inspection of pressure vessels at least every 5 years. Policies and procedures provided by the employer as MDDW 1-UOSH-48, state: "Frequency - Each vessel above ground shall be given a visual external inspection, preferably while in operation, at least every five years or at the same interval as required internal or on-stream inspection, which ever is less." Without adequate external inspections to detect anomalous surface conditions, the vessel could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all process equipment throughout the facility. Note: Per requirements established by the State of Utah, Boiler and Pressure Vessel Code, R616-2-8 and associated Boiler and Pressure Vessel Compliance Manual, Revision 8b, external inspections of pressure vessels must be conducted and inspection intervals may not exceed 60months. G. The employer did not ensure that inspections and tests were consistently performed on process equipment, specifically external inspections 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform external inspections of some pressure vessels, specifically TWR- 30103. External inspection and thickness measurements were taken in November 2007 but no previous external inspections in 2002 and 1997 had been conducted. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require external inspection of pressure vessels at least every 5 years. Policies and procedures provided by the employer as MDDW 1-UOSH-48, state: "Frequency - Each vessel above ground shall be given a visual external inspection, preferably while in operation, at least every five years or at the same interval as required internal or on- stream inspection, which ever is less." Without adequate external inspections to detect anomalous surface conditions, the vessel could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all process equipment throughout the facility. Note: Per requirements established by the State of Utah, Boiler and Pressure Vessel Code, R616-2-8 and associated Boiler and Pressure Vessel Compliance Manual, Revision 8b, external inspections of pressure vessels must be conducted and inspection intervals may not exceed 60 months. H. The employer did not ensure that inspections and tests were consistently performed on process equipment, specifically external inspections 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform external inspections of some pressure vessels, specifically TWR- 50102. External inspection and thickness measurements were taken in December 2008 but no previous external inspections in 2003, 1998 and 1993 had been conducted. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require external inspection of pressure vessels at least every 5 years. Policies and procedures provided by the employer as MDDW 1-UOSH-48, state: "Frequency - Each vessel above ground shall be given a visual external inspection, preferably while in operation, at least every five years or at the same interval as required internal or on- stream inspection, which ever is less." Without adequate external inspections to detect anomalous surface conditions, the vessel could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all process equipment throughout the facility. Note: Per requirements established by the State of Utah, Boiler and Pressure Vessel Code, R616-2-8 and associated Boiler and Pressure Vessel Compliance Manual, Revision 8b, external inspections of pressure vessels must be conducted and inspection intervals may not exceed 60 months. I. The employer did not ensure that inspections and tests were performed on process equipment, specifically external inspections 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform external inspections of some pressure vessels, specifically VES-50104, for the period between 1992 (promulgation of OSHA PSM Standard) and November 4, 2009 (opening date of this inspection). Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require external inspection of pressure vessels at least every 5 years. Policies and procedures provided by the employer as MDDW 1-UOSH-48, state: "Frequency - Each vessel above ground shall be given a visual external inspection, preferably while in operation, at least every five years or at the same interval as required internal or on-stream inspection, which ever is less." Without adequate external inspections to detect anomalous surface conditions, the vessel could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all process equipment throughout the facility. Note: Per requirements established by the State of Utah, Boiler and Pressure Vessel Code, R616-2-8 and associated Boiler and Pressure Vessel Compliance Manual, Revision 8b, external inspections of pressure vessels must be conducted and inspection intervals may not exceed 60 months. J. The employer did not ensure that inspections and tests were performed on process equipment, specifically internal or on-stream inspections 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform internal or on-stream inspections of some pressure vessels, specifically COL- 10201, for the period between 1992 (promulgation of OSHA PSM Standard) and November 4, 2009 (opening date of this inspection). Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require internal inspections of pressure vessels be made at least every 10 years. 2006 API 510 Section 6.5.1.1 specifically requires a Risk Based Inspection Assessment to be in place if internal inspection intervals exceed 10 years regardless if the service is corrosive or non- corrosive. Silver Eagle was not able to produce records indicating they had substituted on- stream inspections for internal inspections as allowed by API 510 Section 6.5.2.1. Without an adequate check of internal pressure boundary surfaces for damage, the vessel could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result inserious injury or death. This may be a system-wide occurrence that requires evaluation of all process equipment throughout the facility. Note: Per requirements established by the State of Utah, Boiler and Pressure Vessel Code, R616-2-8 and associated Boiler and Pressure Vessel Compliance Manual, Revision 8b, external inspections of pressure vessels must be conducted and inspection intervals may not exceed 60 months. K. The employer did not ensure that inspections and tests were performed on process equipment, specifically internal or on-stream inspections 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform internal or on-stream inspections of some pressure vessels, specifically EXC-10202. Thickness measurements were taken in December 2008, but no corresponding internal or on-stream inspection records in 2008 or 1998 were found. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require internal inspections of pressure vessels be made at least every 10 years. 2006 API 510 Section 6.5.1.1 specifically requires a Risk Based Inspection Assessment to be in place if internal inspection intervals exceed 10 years regardless if the service is corrosive or non-corrosive. Silver Eagle was not able to produce records indicating they had substituted on-stream inspections for internal inspections as allowed by API 510 Section 6.5.2.1. Without an adequate check of internal pressure boundary surfaces for damage, the vessel could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all process equipment throughout the facility. Note: Per requirements established by the State of Utah, Boiler and Pressure Vessel Code, R616-2-8 and associated Boiler and Pressure Vessel Compliance Manual, Revision 8b, external inspections of pressure vessels must be conducted and inspection intervals may not exceed 60 months. L. The employer did not ensure that inspections and tests were performed on process equipment, specifically internal or on-stream inspections 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform internal or on-stream inspections of some pressure vessels, specifically TWR-20250, for the period between 1992 (promulgation of OSHA PSM Standard) and November 4, 2009 (opening date of this inspection). Unless otherwise established by a risk- based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require internal inspections of pressure vessels be made at least every 10 years. 2006 API 510 Section 6.5.1.1 specifically requires a Risk Based Inspection Assessment to be in place if internal inspection intervals exceed 10 years regardless if the service is corrosive or non-corrosive. Silver Eagle was not able to produce records indicating they hadsubstituted on-stream inspections for internal inspections as allowed by API 510 Section 6.5.2.1. Without an adequate check of internal pressure boundary surfaces for damage, the vessel could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all process equipment throughout the facility. Note: Per requirements established by the State of Utah, Boiler and Pressure Vessel Code, R616-2-8 and associated Boiler and Pressure Vessel Compliance Manual, Revision 8b, external inspections of pressure vessels must be conducted and inspection intervals may not exceed 60 months. M. The employer did not ensure that inspections and tests were performed on process equipment, specifically internal or on-stream inspections 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform internal or on-stream inspections of some pressure vessels, specifically TWR-30103. Thickness measurements were taken in November 2007, but no corresponding internal or on-stream inspection records in 2007 or 1997 were found. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require internal inspections of pressure vessels be made at least every 10 years. 2006 API 510 Section 6.5.1.1 specifically requires a Risk Based Inspection Assessment to be in place if internal inspection intervals exceed 10 years regardless if the service is corrosive or non-corrosive. Silver Eagle was not able to produce records indicating they had substituted on-stream inspections for internal inspections as allowed by API 510 Section 6.5.2.1. Without an adequate check of internal pressure boundary surfaces for damage, the vessel could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all process equipment throughout the facility. Note: Per requirements established by the State of Utah, Boiler and Pressure Vessel Code, R616-2-8 and associated Boiler and Pressure Vessel Compliance Manual, Revision 8b, external inspections of pressure vessels must be conducted and inspection intervals may not exceed 60 months. N. The employer did not ensure that inspections and tests were performed on process equipment, specifically internal or on-stream inspections 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform internal or on-stream inspections of some pressure vessels, specifically TWR-50102. Thickness measurements were taken in December 2008, but no corresponding internal or on-stream inspection records in 2008 or 1998 were found. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and GenerallyAccepted Good Engineering Practices (RAGAGEP) require internal inspections of pressure vessels be made at least every 10 years. 2006 API 510 Section 6.5.1.1 specifically requires a Risk Based Inspection Assessment to be in place if internal inspection intervals exceed 10 years regardless if the service is corrosive or non-corrosive. Silver Eagle was not able to produce records indicating they had substituted on-stream inspections for internal inspections as allowed by API 510 Section 6.5.2.1. Without an adequate check of internal pressure boundary surfaces for damage, the vessel could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all process equipment throughout the facility. Note: Per requirements established by the State of Utah, Boiler and Pressure Vessel Code, R616-2-8 and associated Boiler and Pressure Vessel Compliance Manual, Revision 8b, external inspections of pressure vessels must be conducted and inspection intervals may not exceed 60 months. O. The employer did not ensure that inspections and tests were performed on process equipment, specifically internal or on-stream inspections 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform internal or on-stream inspections of some pressure vessels, specifically VES-50104, for the period between 1992 (promulgation of OSHA PSM Standard) and November 4, 2009 (opening date of this inspection). Unless otherwise established by a risk- based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require internal inspections of pressure vessels be made at least every 10 years. 2006 API 510 Section 6.5.1.1 specifically requires a Risk Based Inspection Assessment to be in place if internal inspection intervals exceed 10 years regardless if the service is corrosive or non-corrosive. Silver Eagle was not able to produce records indicating they had substituted on-stream inspections for internal inspections as allowed by API 510 Section 6.5.2.1. Without an adequate check of internal pressure boundary surfaces for damage, the vessel could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all process equipment throughout the facility. Note: Per requirements established by the State of Utah, Boiler and Pressure Vessel Code, R616-2-8 and associated Boiler and Pressure Vessel Compliance Manual, Revision 8b, external inspections of pressure vessels must be conducted and inspection intervals may not exceed 60 months. P. The employer did not ensure that inspections and tests were performed on process equipment, specifically visual external piping circuit inspections. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historicallydid not perform inspections of some piping circuits, specifically #2 Crude Unit, # 4"-BF-21055, Mistras circuit No. 010 between FUR-20250 and COL-20250. One visual inspection and thickness measurement was conducted in June 2009, but visual external inspections were not conducted in 2004, 1999, and 1994. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require visual external inspection of Class 1 and Class 2 piping circuits at least every 5 years. Silver Eagle was not able to produce records indicating inspection of this piping circuit had been conducted. Without adequate external inspections to detect anomalous surface conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. Q. The employer did not ensure that inspections and tests were performed on process equipment, specifically visual external piping circuit inspections. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform inspections of some piping circuits, specifically #2 Crude Unit, # 6"-BO-21007, Mistras circuit No. 35 between TWR-20250 and FF-20250. One visual inspection and thickness measurement was conducted in June 2009, but visual external inspections were not conducted in 2004, 1999, and 1994. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require visual external inspection of Class 1 and Class 2 piping circuits at least every 5 years. Silver Eagle was not able to produce records indicating inspection of this piping circuit had been conducted. Without adequate external inspections to detect anomalous surface conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. R. The employer did not ensure that inspections and tests were performed on process equipment, specifically visual external piping circuit inspections. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform inspections of some piping circuits, specifically #2 Crude Unit, # 6"-BO-21007, Mistras circuit No. 125 between TWR-20250 and FF-20250. One visual inspection and thickness measurement was conducted in June 2009, but visual external inspections were not conducted in 2004, 1999 and 1994. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require visual external inspection of Class 1 and Class 2 piping circuits at least every 5 years. Silver Eagle was not able to produce records indicating inspection of this piping circuit had been conducted. Without adequate external inspections to detect anomalous surface conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed to hazardous situations such as fires, explosions, and/or chemicalreleases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all piping throughout the facility. S. The employer did not ensure that inspections and tests were performed on process equipment, specifically visual external piping circuit inspections. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform inspections of some piping circuits, specifically MDDW Unit, Line # 8"-HS- 31045, Mistras circuit No. 112 between VES-30101 and the hydrogen recycle compressor. One visual inspection and thickness measurement was conducted in May 2009, but visual external inspections were not conducted in 2004, and 1999. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require visual external inspection of Class 1 and Class 2 piping circuits at least every 5 years. Silver Eagle was not able to produce records indicating inspection of this piping circuit had been conducted. Without adequate external inspections to detect anomalous surface conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. T. The employer did not ensure that inspections and tests were performed on process equipment, specifically visual external piping circuit inspections. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform inspections of some piping circuits, specifically MDDW Unit, Line # 8"-HS- 31045, Mistras circuit No. 113 between VES-30101 and the hydrogen recycle compressor. One visual inspection and thickness measurement was conducted in May 2009, but visual external inspections were not conducted in 2004, and 1999. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require visual external inspection of Class 1 and Class 2 piping circuits at least every 5 years. Silver Eagle was not able to produce records indicating inspection of this piping circuit had been conducted. Without adequate external inspections to detect anomalous surface conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. U. The employer did not ensure that inspections and tests were performed on process equipment, specifically visual external piping circuit inspections. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform inspections of some piping circuits, specifically MDDW Unit, line # 8"-WB- 31026, Mistras Circuit No. 29, between RTR30103 and EXC30101-B. One visual inspectionand thickness measurement was conducted in May 2009, but visual external inspections were not conducted in 2004, and 1999. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require visual external inspection of Class 1 and Class 2 piping circuits at least every 5 years. Silver Eagle was not able to produce records indicating inspection of this piping circuit had been conducted. Without adequate external inspections to detect anomalous surface conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. V. The employer did not ensure that inspections and tests were performed on process equipment, specifically visual external piping circuit inspections. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform inspections of some piping circuits, specifically #2 Crude Unit, # 4"-BF-21055, Mistras circuit No. 010 between FUR-20250 and COL-20250. One visual inspection and thickness measurement was conducted in June and September of 2009, but visual external inspections were not conducted in 2004, and 1999. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require visual external inspection of Class 1 and Class 2 piping circuits at least every 5 years. Silver Eagle was not able to produce records indicating inspection of this piping circuit had been conducted. Without adequate external inspections to detect anomalous surface conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. W. The employer did not ensure that inspections and tests were performed on process equipment, specifically visual external piping circuit inspections. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform inspections of some piping circuits, specifically HDS Reformer Unit, Line # 3"- RF-51116, Mistras circuit No. 004 between PMP-50101 and EXC-50102A. One visual inspection and thickness measurement was conducted in June 2009, but visual external inspections were not conducted in 2004, and 1999. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require visual external inspection of Class 1 and Class 2 piping circuits at least every 5 years. Silver Eagle was not able to produce records indicating inspection of this piping circuit had been conducted. Without adequate external inspections to detect anomalous surface conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout thefacility. X. The employer did not ensure that inspections and tests were performed on process equipment, specifically visual external piping circuit inspections. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform inspections of some piping circuits, specifically Reformer HDS Unit, Line # 4"- HD-51125, Mistras circuit No. 057 between TWR-50102 and EXC-50111. One visual inspection and thickness measurement was conducted in July 2009, but visual external inspections were not conducted in 2004, and 1999. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require visual external inspection of Class 1 and Class 2 piping circuits at least every 5 years. Silver Eagle was not able to produce records indicating inspection of this piping circuit had been conducted. Without adequate external inspections to detect anomalous surface conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. Y. The employer did not ensure that inspections and tests were performed on process equipment, specifically thickness testing of Class II piping. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform thickness testing of Class II piping on the MDDW Unit, Line # 8"-HS-31045, Mistras circuit No. 112 between VES-30101 and the hydrogen recycle compressor. One thickness measurement was conducted in May 2009, but thickness measurements were not conducted in 1999. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require piping thickness measurements of Class II piping circuits at least every 10 years. These non destructive examinations for piping thickness must be performed to assure that the piping has sufficient thickness to provide both pressure containment and mechanical support. Silver Eagle was not able to produce records indicating historical piping thickness measurements of this piping circuit had been conducted. Piping inspections should be frequent enough to assure that all piping has sufficient thickness to provide both pressure containment and mechanical support. Without adequate thickness inspections to detect anomalous conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. Z. The employer did not ensure that inspections and tests were performed on process equipment, specifically thickness testing of Class II piping. 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. Inspections and tests were not performed onprocess equipment to maintain its mechanical integrity. The employer historically did not perform thickness testing of Class II piping on the MDDW Unit, Line # 8"-HS-31045, Mistras circuit No. 113 between VES-30101 and the hydrogen recycle compressor. One thickness measurement was conducted in May 2009, but thickness measurements were not conducted in 1999. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require piping thickness measurements of Class II piping circuits at least every 10 years. These non destructive examinations for piping thickness must be performed to assure that the piping has sufficient thickness to provide both pressure containment and mechanical support. Silver Eagle was not able to produce records indicating historical piping thickness measurements of this piping circuit had been conducted. Piping inspections should be frequent enough to assure that all piping has sufficient thickness to provide both pressure containment and mechanical support. Without adequate thickness inspections to detect anomalous conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. AA. The employer did not ensure that inspections and tests were performed on process equipment, specifically thickness testing of Class II piping. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform thickness testing of Class II piping on the MDDW Unit, line # 8"-WB-31026, Mistras Circuit No. 29, between RTR30103 and EXC30101-B. One thickness measurement was conducted in May 2009, but thickness measurements were not conducted in 1999. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require piping thickness measurements of Class II piping circuits at least every 10 years. These non destructive examinations for piping thickness must be performed to assure that the piping has sufficient thickness to provide both pressure containment and mechanical support. Silver Eagle was not able to produce records indicating historical piping thickness measurements of this piping circuit had been conducted. Piping inspections should be frequent enough to assure that all piping has sufficient thickness to provide both pressure containment and mechanical support. Without adequate thickness inspections to detect anomalous conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. BB. The employer did not ensure that inspections and tests were performed on process equipment, specifically thickness testing of Class II piping. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform thickness testing of Class II piping on the #2 Crude Unit, # 4"-BF-21055, Mistrascircuit No. 010 between FUR-20250 and COL-20250. Measurements were conducted in June 2009 and September 2009, but thickness measurements were not conducted in 1999. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require piping thickness measurements of Class II piping circuits at least every 10 years. These non destructive examinations for piping thickness must be performed to assure that the piping has sufficient thickness to provide both pressure containment and mechanical support. Silver Eagle was not able to produce records indicating historical piping thickness measurements of this piping circuit had been conducted. Piping inspections should be frequent enough to assure that all piping has sufficient thickness to provide both pressure containment and mechanical support. Without adequate thickness inspections to detect anomalous conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. CC. The employer did not ensure that inspections and tests were performed on process equipment, specifically thickness testing of Class II piping. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform thickness testing of Class II piping on the HDS Reformer Unit, Line # 3"-RF-51116, Mistras circuit No. 004 between PMP-50101 and EXC-50102A. One thickness measurement was conducted in June 2009, but thickness measurements were not conducted in 1999. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require piping thickness measurements of Class II piping circuits at least every 10 years. These non destructive examinations for piping thickness must be performed to assure that the piping has sufficient thickness to provide both pressure containment and mechanical support. Silver Eagle was not able to produce records indicating historical piping thickness measurements of this piping circuit had been conducted. Piping inspections should be frequent enough to assure that all piping has sufficient thickness to provide both pressure containment and mechanical support. Without adequate thickness inspections to detect anomalous conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. DD. The employer did not ensure that inspections and tests were performed on process equipment, specifically thickness testing of Class II piping. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform thickness testing of Class II piping on the Reformer HDS Unit, Line # 4"-HD-51125, Mistras circuit No. 057 between TWR-50102 and EXC-50111. One thickness measurement was conducted in July 2009, but thickness measurements were not conducted in 1999. Unlessotherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require piping thickness measurements of Class II piping circuits at least every 10 years. These non destructive examinations for piping thickness must be performed to assure that the piping has sufficient thickness to provide both pressure containment and mechanical support. Silver Eagle was not able to produce records indicating historical piping thickness measurements of this piping circuit had been conducted. Piping inspections should be frequent enough to assure that all piping has sufficient thickness to provide both pressure containment and mechanical support. Without adequate thickness inspections to detect anomalous conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. EE. The employer did not ensure that inspections and tests were performed on process equipment, specifically thickness testing of Class I piping. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform thickness testing of Class I piping on the #2 Crude Unit, # 6"-BO-21007, Mistras circuit No. 35 between TWR-20250 and FF-20250. One thickness measurement was conducted in June 2009, but visual external inspections were not conducted in 2004, 1999, and 1994. Silver Eagle could not produce documents demonstrating inspections prior to 2009 had been conducted. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require piping thickness measurements of Class 1 piping circuits at least every 5 years. These non destructive examinations for piping thickness must be performed to assure that the piping has sufficient thickness to provide both pressure containment and mechanical support. Piping inspections should be frequent enough to assure that all piping has sufficient thickness to provide both pressure containment and mechanical support. Without adequate thickness inspections to detect anomalous conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility. FF. The employer did not ensure that inspections and tests were performed on process equipment, specifically thickness testing of Class I piping. 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. Inspections and tests were not performed on process equipment to maintain its mechanical integrity. The employer historically did not perform thickness testing of Class I piping on the #2 Crude Unit, # 6"-BO-21007, Mistras circuit No. 125 between TWR-20250 and FF-20250. One thickness measurement was conducted in June 2009, but visual external inspections were not conducted in 2004, 1999 and 1994. Silver Eagle could not produce documents demonstrating inspections prior to 2009 had been conducted. Unless otherwise established by a risk-based inspection (RBI) assessment, Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) require piping thicknessmeasurements of Class 1 piping circuits at least every 5 years. These non destructive examinations for piping thickness must be performed to assure that the piping has sufficient thickness to provide both pressure containment and mechanical support. Piping inspections should be frequent enough to assure that all piping has sufficient thickness to provide both pressure containment and mechanical support. Without adequate thickness inspections to detect anomalous conditions, the piping could fail resulting in a catastrophic release. In the event of an equipment failure, employees could be exposed 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 all piping throughout the facility.