Text For Citation: 03 Item/Group: 007D Hazard: REFINERY

29 CFR 1910.119(d)(2)(i)[E] Information concerning the technology of the process shall include at least the following: An evaluation of the consequences of deviations, including those affecting the safety and health of employees. A. The employer did not ensure that information concerning the technology of the process included an evaluation of the consequences of deviations, including those affecting the safety and health of employees. 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 review of the #2 Crude Operating Manual, Operating Limits, Revision 2, Nov. 17, 2005, Section 3. Normal Operating Limits, the provided document did not list safety and health consequences for deviations from the listed limits. For example, the consequences listed include "products off specification", "no pump suction", and "operating problems", yet no safety and health consequences were listed. By not fully evaluating consequences of deviations, including those affecting the safety and health of employees, the employer was deprived of critical information used to ensure employee safety and health. 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 the development and evaluation of all consequences of deviations throughout the facility. B. The employer did not ensure that information concerning the technology of the process included an evaluation of the consequences of deviations, including those affecting the safety and health of employees. 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 review of the Naphtha HDS Unit Operating Guidelines, items listed as consequences of deviation for exceeding the safe operating limits are operational issues. No safety and health consequences are listed for exceeding these safe limits. By not fully evaluating consequences of deviations, including those affecting the safety and health of employees, the employer was deprived of critical information used to ensure employee safety and health. Exceeding safe operating limits without addressing safety and health consequences can result in equipment failure exposing employees to serious injury or death. 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 the development and evaluation of all consequences of deviations throughout the facility. C. The employer did not ensure that information concerning the technology of the process included an evaluation of the consequences of deviations, including those affecting the safety and health of employees. 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 review of the Reformer Unit Operating Guidelines, items listed as consequences of deviation for exceeding the safe operating limits are operational issues. No safety and health consequences are listed for exceeding these safe limits. By not fully evaluating consequences of deviations, including those affecting the safety and health of employees, the employer was deprived of critical information used to ensure employee safety and health. Exceeding safe operating limits without addressing safety and healthconsequences can result in equipment failure exposing employees to serious injury or death. 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 the development and evaluation of all consequences of deviations throughout the facility. D. The employer did not ensure that information concerning the technology of the process included an evaluation of the consequences of deviations, including those affecting the safety and health of employees. 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. As identified onsite, the upper safe temperature limit for MDDW reactor 30101 feed is listed at 800F, however the consequences of exceeding this limit are operational ("Increased coking in HDS bed, increased fuel gas consumption") and do not address safety and health concerns. Likewise it is noted that this 800F temperature limit for RTR-30101 is not consistent with the original design temperature limit of 750 F as listed on the manufacturer's U-1A form for the vessel constructed in 1966. Derating of the vessel to a pressure of 1000 psi at 800F was performed by Moose's Construction. The temperature safe limit for RTR-30101 of 800 F did not indicate that operating above this temperature exceeded the design limit for the vessel as determined in the re-rating for this vessel. By not fully evaluating consequences of deviations, including those affecting the safety and health of employees, the employer was deprived of critical information used to ensure employee safety and health. 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 the development and evaluation of all consequences of deviations throughout the facility.