Standard Cited: 19100119 J04 II Process safety management of highly hazardous chemicals.
This violation item has been deleted.
Inspection Nr: 312412356
Citation Type: Willful
Abatement Date: 06/03/2010
Initial Penalty: $56,000.00
Current Penalty: $56,000.00
Issuance Date: 04/28/2010
Nr Instances: 2
Nr Exposed: 24
Related Event Code (REC):
Report ID: 0854910
Contest Date: 05/27/2010
Final Order: 10/23/2013
|Type||Latest Event||Event Date||Penalty||Abatement Due Date||Citation Type||Failure to Abate Inspection|
|Penalty||F: Formal Settlement||10/23/2013||$56,000.00||06/03/2010||Willful|
Text For Citation: 01 Item/Group: 011 Hazard: REFINERY
29 CFR 1910.119(j)(4)(ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices. A. The employer did not ensure that inspection and testing procedures followed recognized and generally accepted good engineering practices (RAGAGEP). 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. During inspection of MDDW RTR-30101, documents provided by the employer detailed that only (1) Thickness Monitoring Location (TML), #43, was assessed on the outlet piping of the Reactor. Per documents provided by the employer, the last thickness test for TML #43 was in October 2007. Drawings indicated that TML #43 was located on the back side of the outlet elbow. As stated by management, Silver Eagle oversees the selection of TML's. Per API "In selecting or adjusting the number and locations of TMLs, the inspector should take into account the patterns of corrosion that would be expected and have been experienced in the process unit." In addition, API identifies "corrosion rates are normally increased at areas of increased velocity and/or turbulence" to include "elbows"; "Such components are normally areas where an inspector would locate additional TML's." In light of a turbulent discharge from RTR-30101 through an elbow section, Silver Eagle did not add additional TML's to assess flow accelerated corrosion. Field assessment of the failed piping section identified a definite pattern of corrosion through the elbow. By not assessing and adding additional TMLs per RAGAGEP, pipe thinning was not identified which resulted in a catastrophic failure and release exposing employees to hazardous conditions which can cause serious injury or death. This may be a system-wide occurrence that requires evaluation of all TML locations throughout the facility. B. The employer did not ensure that inspection and testing procedures followed recognized and generally accepted good engineering practices (RAGAGEP). 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 by the employer indicated that an internal inspection of the MDDW RTR-30101 had not been conducted since the vessel was placed into service on or about March 28, 1994. API 510 requires an internal inspection of pressure vessels within 10 years unless a risk based inspection program has been implemented to extend this inspection interval. Silver Eagle Refinery provided no documentation to indicate that a risk based study had been conducted for changing this internal inspection interval requirement and no records exist to indicate that this vessel had an internal inspection since placed into service approximately 15 years ago. In addition, at the time of installation, installation contractor AEC recommended the vessel have an internal inspection within 10 years as per the report to Sun Oil and KHI dated April 16, 1993: "It is recommended that an internal inspection be completed within the next 10 years." An internal inspection of the bottom nozzle would have likely provided vital information demonstrating thinning on the reactor's nozzle. By not ensuring inspection and testing procedures followed recognized and generally accepted good engineering practices (RAGAGEP), critical information obtained only through internal inspection was not available. 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 allequipment inspections throughout the facility.