Text For Citation: 01 Item/Group: 004 Hazard: REFINERY

29 CFR 1910.119(d): The employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process: -In the Alternative- 29 CFR 1910.119(d)(3)(i)(B): The process safety information pertaining to the equipment in the process did not include an accurate and updated piping and instrumentation diagram (P&ID). The employer did not complete a compilation of written process safety information before conducting any process hazard analysis required by the standard including information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process. This violation most recently observed at the Pasadena Refining Systems Inc. located at 111 Red Bluff Road, Pasadena, Texas on or about August 31, 2010, and at times thereafter, in the Fluid Catalytic Cracking Unit (FCCU) and the Alky 1 & 2 Units, exposing the employees to potential fire and explosion hazards. In the instances below, the employer utilized piping and instrumentation diagrams (P&IDs) with incomplete or inaccurate information to conduct process hazard analysis (PHA) of the FCC in 2009 and Alky 1 and 2 Units in 2008. The conditions described below also exist on subsequent revisions of the P&IDs. FCCU a)Wall thickness for T-56 is not accurate on P&ID F-5556 Rev 3 b)Wall thickness for H-2 is not accurate on P&ID F-5502 Rev 4 c)P&ID, 55F-5500 Rev 7 schematically showed PSV- 2347 on E-18 without a set pressure. d)P&ID, 55F-5500 Rev 7 indicated line, 8"-P-0377-15A coming as pump around (PA) from FE-4's. A review of the P&ID by CSHO found line, 8"-P-0377-15A coming from P-4A and P-4B in P&ID, 55F-5514 Rev 5. e)P&ID, 55F-5504 Rev 3 does not show the connecting P&ID drawings number for fuel gas, 70 # steam and instrument air. f)P&ID, 55F-5505 Rev 2 showed no specification data in the equipment title block for Air Preheater, H-1, B-2A, and B-2B. g)P&ID, 55F-5553 Rev 6, showed PSV-3309 on D-58 without a set pressure. The last revision for this document was 12/2009. h)Title Block detail for H-1 is missing from P&ID F-5505 Rev 2. i)Title Block detail for B-2A and B-2B is missing from P&ID F-5505 Rev 2. j)Title Block detail for E-8 is missing from P&ID F-5512 Rev 5. k)Title Block detail for D-59 is missing from P&ID F-5552 Rev 3. l)Wall thickness and corrosion allowance for R-1 are missing from P&ID F-5503 Rev 3. m)Wall thickness for R-2 is missing from P&ID F-5504 Rev 3. Alky 1 n)Wall thickness for D-7 is not accurate on P&ID F-7106 Rev 2. o)U-1 and R-1 for D-6 do not match. Inaccurate information on P&ID 7106 Rev 2 carried over from U-1. p)Drawing for continuation of 6"-P-212-F is not shown on P&ID F-7105 Rev 3, Same was noted to be missing on Rev 5 of same P&ID number. q)Drawing for continuation of ="-NI-504-15A is not shown on P&ID F-7105 Rev 3. Same was noted to be missing on Rev 5 of same P&ID number. r)P&ID, 71F-7102, Rev. 4 schematically showed the thermal relief valve on the tube side of E-103 as "PI" instead of "PSV". s)P&ID, 71F-7103, schematically represented that there is one acid rerun pump, P-103A, in Alky # 1. Field observations by CSHO on Wednesday, October 13, 2010 found two acid rerun pumps, P-103A and P-103B in Alky # 1(see photo). t)P&ID, 71F-7110 Rev. 3 incorrectly showed PSV- 1309 on T-3 as coming from P&ID, 71F-7103 instead of P&ID, 71F-7108. u)P&ID, 71F-7110 Rev. 3 showed PSV-1307 on T-1 as coming from P&ID, 71F- 7110 instead of P&ID, 71F-7105 Rev. 5 v)Title Block detail for D-2 is incomplete from P&ID F-7110 Rev 1. w)Title Block detail for D-7 is incomplete P&ID F-7106 Rev 2.x)Title Block detail for T-4 is incomplete from P&ID F-7110 Rev 1. y)Title Block detail for E-104 is incomplete from P&ID F-7103 Rev 4. z)Title Block detail for D-12 is incomplete from P&ID F-7104 Rev 3. aa)Title Block detail for D-14 is incomplete from P&ID F-7104 Rev 3. ab)Title Block detail for P-103A is incomplete from P&ID F-7103 Rev 4. Alky 2 ac)Wall thickness for E112A and E112B is not accurate on P&ID F-7207 Rev 2. ad)Title Block detail for E-106A and E-106B is incomplete from P&ID F-7204 Rev 4. ae)Title Block detail for E-107 is incomplete from P&ID F-7204 Rev 4. af)Title Block detail for E-108 is incomplete from P&ID F-7204 Rev 4. ag)Title Block detail for P-105A and P-105B is incomplete from P&ID F-7204 Rev 4. ah)Title Block detail for E-109A and E-109B is incomplete from P&ID F-7204 Rev 4. ai)Title Block detail for D-7 is incomplete from P&ID F-7205 Rev 3. aj)P&ID 72F-7204 Rev 4, in Alky # 2 schematically showed Depropanizer Feed Bottom Exchanger, E-108 in service. Field observations by CSHO on Wednesday, October 13, 2010 found that E-108 is not in service in the unit. ak)P&ID, 72F-7209 Rev 3 incorrectly showed PSV- 2305 on D-5 as PSV-105. P&ID, 72F-7209 incorrectly showed PSV-2304 on D-4 as coming from P&ID, 72F-7203 instead of P&ID, 72F-7202. P&ID, 72F-7209 also incorrectly shows PSV-2309 on T-3 in P&ID, 72F-7207, as PSV-109. Pursuant to 29 C.F.R. 1903.19, within ten (10) days of the abatement date of this citation, the employer must submit documentation showing that it is compliance with the standard, including describing the steps that it is taking to complete a compilation of written process safety information before conducting any process hazard analysis required by the standard.