OSHA Inspection: BIG WEST OIL, LLC

Issued

2010-11-09 00:00:00

Abate by

2011-07-21 00:00:00

Penalty

Initial $3500.00 · Current $3500.00

General-duty citation text

29 CFR 1910.23(a)(2): Every ladderway floor opening or platform shall be
guarded by a
standard railing with standard toeboard on all exposed sides (except at
entrance to opening),
with the passage through the railing either provided with a swinging gate
or so offset that a
person cannot walk directly into the opening.
(A) On 9/9/10, a safety inspection was accomplished by the Compliance
Officer at Big West
Oil LLC, 333 W.Center St., North Salt Lake. During the inspection, the
Compliance Officer
observed in the HF Alkylation and HDS unit of the refinery that the ladder
landings were not
protected by a fixed barrier or gates to prevent employees from walking
through the
openings. The Compliance Officer measured the heights of the opened end
platforms to the
lower level, by counting the ladder rungs, and the heights ranged from 6
ft. to 20 ft.
Management stated that they have the materials to install the barriers.
Without the barriers in
place, employees could sustain serious injuries from 20 ft. falls to the
lower
level.

Issued

2010-11-09 00:00:00

Abate by

2011-07-21 00:00:00

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D) Information pertaining to the equipment in the
process shall
include relief system design and design basis.
A) Information pertaining to the equipment in the process did not include
design calculations
for relief system design and design basis for pressure safety valve,
PSV-5510, which protects
Amine Absorber, T-1310, at Big West Oil, 333 W Center Street, North Salt
Lake, UT
84054. This violation was identified during an interview with Technical
Manager on August
17, 2010. The Technical Manager stated that the calculations for the over
pressure relief
scenarios for pressure safety valve, PSV-5510, did not exist. The
Technical Manager
submitted document, BWO UOSH-092-0003, which states that calculations for
overpressure
relief scenarios were not available. The PSI must be complete and accurate
to enable the
employees involved in operating the process to avoid exposure to highly
hazardous
chemicals. Not maintaining process safety information, such as but not
limited to calculations
for relief system design, prevents the employer from ensuring the adequacy
of the relief
system and could result in employee's exposure to hazardous chemicals.
This may be a
system-wide occurrence that requires evaluation of all procedures
throughout the facility.
B) Information pertaining to the equipment in the process did not include
design calculations
for relief system design and design basis for pressure safety valve,
PSV-5590, which protects
Amine Reboiler, E-1390, at Big West Oil, 333 W Center Street, North Salt
Lake, UT
84054. This violation was identified during an interview with the
Technical Manager, on
August 17, 2010. The Technical Manager told the Compliance Officer that
the calculations
for the over pressure relief scenarios for pressure safety valve PSV-5590,
did not exist. The
Technical Manager submitted document, BWO UOSH-092-0003, which states that
calculations for overpressure relief scenarios were not available. The PSI
must
be complete
and accurate to enable the employees involved in operating the process to
avoid exposure to
highly hazardous chemicals. Not maintaining process safety information,
such as but not
limited to calculations for relief system design, prevents the employer
from ensuring the
adequacy of the relief system and could result in employee exposures to
hazardous
chemicals. This may be a system-wide occurrence that requires evaluation
of all procedures
throughout the facility.
C) Information pertaining to the equipment in the process did not include
design calculations
for relief system design and design basis for pressure safety valve,
PSV-3307, which
protects Acid Storage Tank, D-304, at Big West Oil, 333 W Center Street,
North Salt Lake,
UT 84054. This violation was identified during an interview with Technical
Manager, on
August 17, 2010. The Technical Manager told the Compliance Officer that
the calculations
for the over pressure relief scenarios for pressure safety valve PSV-3307,
did not exist. The
Technical Manager submitted document, BWO UOSH-092-0003, which states that
calculations for overpressure relief scenarios were not available. The PSI
must be complete
and accurate to enable the employees involved in operating the process to
avoid exposure to
highly hazardous chemicals. Not maintaining process safety information,
such as but not
limited to calculations for relief system design, prevents the employer
from ensuring the
adequacy of the relief system and could result in employee exposures to
hazardous
chemicals. This may be a system-wide occurrence that requires evaluation
of all procedures
throughout the facility.t

Issued

2010-11-09 00:00:00

Abate by

2011-07-21 00:00:00

General-duty citation text

29 CFR 1910.119(d)(3)(ii) The employer shall document that equipment
complies with
recognized and generally accepted good engineering practices.
A) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the
employer did not
document that pressure safety valve PSV-5590 complies with RAGAGEP. The
inlet line
pressure drop (ILPD) for PSV-5590 is 6.4which exceeds the 3of the
opening set
pressure as described in the RAGAGEP. PSV-5590 was identified as having an
ILPD greater
than 3by the employer (BWO UOSH-092-0003). The inlet line pressure drop
is associated
with pressure losses as the relieving fluid; vapor or two-phase flow
passes through all the
piping and fittings (ells, valves, etc.) from the vessel to the pressure
safety valve (PSV). If
relieving flow is choked by the inlet line losses, the protected vessel
could catastrophically
fail. ILPD is a phenomenon where a PSV can open at its set pressure as
designed. Due to the
ILPD, the PSV closes quickly due to the decrease in pressure caused by the
ILPD and not
the actual pressure in the equipment which initially caused the pressure
to exceed the set
pressure of the PSV. After the PSV closes due to the ILPD, it will open
again due to the
actual pressure in the equipment is higher than the set pressure. This
continual opening and
closing of the PSV is termed chattering. This chattering can occur many
times.
As a result
the capacity of the PSV is reduced and the chattering can cause, in the
worst case, the relief
system equipment to catastrophically fail with an ensuing loss of
containment of hazardous
chemicals. Equipment that is not documented in complying with recognized
and generally
accepted good engineering practices prevents the employer from ensuring
the adequacy of
process equipment and may result in employee exposures to hazardous
chemicals. This may
be a system-wide occurrence that requires evaluation of all procedures
throughout the
facility.
B) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the
employer did not
document that pressure safety valve PSV-3307 in the Alky Unit complies
with RAGAGEP.
The total backpressure on this valve exceeded approximately 50of the
valve's set pressure.
The employer provided the following requested information regarding
balanced-bellows PSV-
3307 in the Alky Unit (BWO UOSH-092-0003).
1.Set Pressure = 175 psig
2.superimposed back pressure at outlet of relief device PSV-3307 is
typically less than
5psig
3.built-up backpressure after relief device PSV-3307 opens = 100 psig
Total backpressure (superimposed plus built-up) equals 105 psig and this
is 60of the
valve's set pressure (175 psig). RAGAGEP recommends that total
backpressure should not
exceed approximately 50of the valve's set pressure. This guidance is
offered in Section
3.3.3.2.1 of the 2000 API 520 which states: "Balanced valves can typically
be applied where
the total backpressure (superimposed plus built-up) does not exceed
approximately 50of
the set pressure".
Reduced flow capacity through the valve may occur as high backpressure
will tend to
produce a closing force on the unbalanced portion of the valve's disc and
may result in
employee exposures to hazardous chemicals. This may be a system-wide
occurrence
that
requires evaluation of all procedures throughout the facility.
(C) The employer did not comply with Recognized and Generally Accepted Good
Engineering Practices (RAGAGEP) when developing their facility siting
study. The facility
siting study is develop to determine if the employees inside permanent or
temporary
structures were protected (i.e., protected by adequate separation or
building construction)
structures that were exposed to explosion, fire, toxic material, corrosive
materials such as
HF or high pressure hazards as a result of an HHC release from process
equipment. At the
time of inspection, May 2010 to September 2010, Big West Oil LLC (BWO),
333 W. Center
St., North Salt Lake City, UT 84054, the Compliance Officer observed that
employer did not
conduct a refinery-wide facility siting study for its occupied permanent
and temporary
buildings in accordance with RAGAGAP, API 752 and API 753.  The Compliance
Audit
report of March 2009, BWO-UOSH-039B-0014, stated that the refinery did not
have a
facility siting study and recommended a study should be done. A facility
siting study, BWO-
UOSH-052-0001, was submitted to UOSH and found that it was not in
compliance with
RAGAGAP.  Another study was contracted on June 2010 to ABS Consulting.
The BWO
PSM Coordinator stated that the contractor had done their field work at
the refinery in the
first week of August 2010, but their final report of the study was not
available at the end of
this inspection. As a result, employees and contractors were exposed to
hazardous condition
which could result in serious injuries or death in the event of a
catastrophic event. This may
be a system-wide occurrence that requires evaluation of permanent and
temporary structures
throughout the facility.

Issued

2010-11-09 00:00:00

Abate by

2011-07-21 00:00:00

Penalty

Initial $3500.00 · Current $3500.00

General-duty citation text

Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) to
maintain
the on-going integrity of vessels, relief valves and piping. BWO
Reliability Manual for
Mechanical Integrity and Equipment Reliability (BWO UOSH-016A-0003)
indicates that
written MI procedures are detailed in Appendix A. Appendix A offered only
insufficient and
abbreviated written MI tasks such as:
29 CFR 1910.119(j)(2) The employer shall establish and implement written
"Task #510 for vessels has nine lines of text with brief inspection task
descriptions
such as: "visually inspect vessel", "perform thickness testing of shell,
head and nozzle"
"check trays", "check liners for cracks, bypassing, bulging or corrosion"
(BWO UOSH-
016A-0021).
"Task # 610 for piping has seven lines of text with brief inspection task
descriptions
such as: "visually inspect all piping" and "review NDT reports" (BWO
procedures to
UOSH-016A-0021).
"Task # 640 for relief valves has five lines of text with brief inspection
task
maintain the on-going integrity of process equipment.
A) On or about July 9, 2010, at Big West Oil, 333 W Center Street, North
Salt Lake, UT
84054, OSHA engineer observed a broken thermocouple connection on Reheater
No. 2, in
the Sulfur Recovery Unit (SRU). The exchanger is symbolically represented
as E-1103 on
SRU P&ID drawing No. 21 (BWO UOSH-010B10-0006). The thermocouple is
descriptions such as: "observe for leakage", "remove valves for
inspection" and "test and
repair boiler relief valves".
Serious injury or death to an employee from exposure to hazardous
chemicals could occur in
the event of equipment failure if the employer does not establish and
implement written
procedures to maintain the on-going integrity of process equipment. This
may be a system
represented
wide occurrence that requires evaluation of all procedures throughout the
facility. Written
procedures would be sufficient if the following were addressed:
1.how and when procedure will be used
2.who will use the  procedure
3.does the procedure impact safety or environmental issues
4.does procedure address sequencing of tasks
5.is procedure written as a command
6.is there enough specificity in the procedure so there is no guessing or
interpretation
required
G) 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. BWO Reliability Manual for
Mechanical
Integrity and Equipment Reliability (BWO UOSH-016A-0003 and 0004) lists
"Good
Engineering Practices" employed by BWO. The employer failed to include API
579 Fitness
for Service (FFS) on this list to demonstrate the structural integrity of
an in-service
component that may contain a flaw or damage. The guidelines provided in
this API 579
Standard 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. BWO's
MI Program does not reference API 579. Serious injury or death to an
employee from
exposure to hazardous chemicals could occur in the event of equipment
failure if the
employer does not establish and implement written procedures to maintain
the on-going
integrity of process equipment. This may be a system wide occurrence that
requires
evaluation of all procedures throughout the facility.
as TE-1827 A&B on SRU P&ID drawing No. 21 (BWO UOSH-010B10-0006). The
escort
and Sulfur Recovery Unit Engineer was not able to provide a definitive
answer regarding the
status of the broken thermocouple and there were no explanatory tags hung
on the broken
thermocouple and could result in serious injury from hazardous chemicals
exposures.
The employer did not implement their own written BWO procedure to maintain
the on-
going integrity of process equipment. Section 8.1 of BWO's Mechanical
Integrity Program
for Controls (BWO UOSH-016B-0010) calls for "equipment included in this
program found
to be outside acceptable limits shall be corrected/repaired as soon as
practically possible".
B) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the
employer did not
establish and implement adequate written procedures to maintain the
on-going integrity of
process equipment, not limited to a procedure for
corrosion-under-insulation
inspection. In
response to UOSH document requests regarding Mechanical Integrity,
documents submitted
by the employer demonstrated that there was a paucity of written MI
policies and procedures.
For example, on September 21, 2010, in response to Document Request #16,
for any and all
policies, procedures, or statements regarding a requirement to inspect for
corrosion under
insulation, the PSM Engineer referred the Compliance Officer to documents
BWO UOSH-
18A and BWO UOSH-018B. The Compliance Officer reviewed these documents
along with
those submitted in response to request for MI procedures for piping:
UOSH-004, UOSH-
016A, UOSH-016B, and UOSH-81 (note from employer stated:  BWO
UOSH-018A-0025
and UOSH-16--specifically, some of the mechanical integrity procedures
pertaining to piping
inspections can be found at pages 1-6, 23, and 25), UOSH-127 (piping
specifications),
UOSH-130, and the Auditing Report Form (BWO UOSH-115). None of these
documents
identified procedures to complete an inspection for
corrosion-under-insulation with regard to
piping. Procedures to inspect for corrosion under insulation must be
established and
implemented to enable the employer to maintain the on-going integrity of
process piping and
to avoid a release of the piping and potential employee exposures to
hazardous chemicals
contained by the process piping. This may be a system-wide occurrence that
requires
evaluation of all procedures throughout the facility.
C) The employer did not establish and implement written procedures to
maintain the on-
going integrity of process equipment, such as but not limited to
procedures for inspecting
relief devices. This violation was identified during the inspection at Big
West Oil, 333 W
Center Street, North Salt Lake, UT 84054, on September 1, 2010, when the
Compliance
Officer reviewed the documents submitted in response to requests for the
corporate and
refinery mechanical integrity (MI) program procedures (BWO UOSH-16) and
all
MI
procedures (program and task specific instructions) related to the
inspection, testing,
servicing, repair, alteration of pressure vessels, piping and relief
system equipment (BWO
UOSH-18) which did not establish site-specific procedures with details for
inspecting, testing,maintaining, and repairing relief devices. Not
establishing written procedures to maintain the
on-going integrity of relief devices prevents the employer from preventing
hazardous
chemical exposures to employees. This may be a system-wide occurrence that
requires
evaluation of all procedures throughout the facility.
D) The employer did not establish and implement written procedures to
maintain the on-
going integrity of process equipment, such as but not limited to
procedures for establishing
thickness measurement locations (TML) for injection points and nearby
piping. During the
inspection at Big West Oil, 333 W Center Street, North Salt Lake, on
September 21, 2010,
the Compliance Officer reviewed the documents submitted in response to
requests
for the
corporate and refinery mechanical integrity (MI) program procedures (BWO
UOSH-16) and
all MI procedures (program and task specific instructions) related to the
inspection, testing,
servicing, repair, alteration of piping (BWO UOSH-16, BWO UOSH-18, BWO
UOSH-081,
BWO UOSH-130) submitted in response to requests for MI procedures. These
documents did
not establish procedures to establish TML for injection points and nearby
piping. Procedures
to establish TML for injection points and nearby piping must be
established and implemented
to enable the employer to maintain the on-going integrity of process
piping and to avoid a
release of the piping and potential employee exposures to hazardous
chemicals contained by
the process piping.
E) 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 pressure relief valves. BWO Reliability Manual
for Mechanical
Integrity and Equipment Reliability (BWO UOSH-016A-0003) indicates that
written MI
procedures are detailed in Appendix A. Appendix A offered inadequate
written MI
procedures for pressure safety valves. For example Task #640 titled
"Maintenance and
Inspection Tasks for Relief Valves" (BWO UOSH-016A-0024) offered only the
follow
written procedures for pressure safety valves:
"Operators should observe for leakage daily
"Maintenance/Engineering determines if pressure safety valve will be
checked during
next turnaround.
"Maintenance remove/reinstall valves for inspection and repair
"Maintenance insures documentation is up to date
"Test and repair boiler relief valves annually
The employer must write and implement policies and procedures based on
RAGAGEPs for
the following applicable activities: design, inspection, repair,
preventive
maintenance,
alteration, rerating, and fitness for service. These policies and
procedures must apply to the
following process equipment; pressure vessels, storage tanks, piping,
pressure relief valves,
relief vent systems, instrumentation, controls, and pumps. Serious injury
or death to an
employee from exposure to hazardous chemicals could occur in the event of
equipment
failure if the employer does not establish and implement written
procedures to maintain the
on-going integrity of process equipment. This may be a system wide
occurrence that requires
evaluation of all procedures throughout the facility. As an example,
written policies and
procedures for maintaining the MI of pressure safety valves would include
but not be limitedto:
1.Inspection requirements:
a.Written procedure for external visual inspection
b.Written procedure for periodic check of positions of upstream and
downstream block
valves
c.Written procedure for as-received pop testing and interpretation of
results
d.Written procedure for visual inspection of inlet and outlet piping for
fouling and
plugging whenever valve is removed
e.Written description of inspection interval at fixed period based on
inspection codes or
determined by results of as-received pop testing
2.Design Requirements:
a.Written procedure for component materials
b.Written procedure for sizing design basis and calculations
c.Written procedure for  inspection and testing of new/rebuilt valves
3.Repair/Replace Requirements:
a.Written procedure for ASME VR stamp for repairs
b.Written procedure for vendor qualifications
c.Written procedure for employer documentation
d.Written procedure for removing valve on-line (identify other pathways)
e.Written procedures for craft skill procedures for tasks encountered such
as gasket
installation, bolt tightening, etc.
F) The employer did not establish and implement policies and procedures
which incorporate

Issued

2010-11-09 00:00:00

Abate by

2011-07-21 00:00:00

General-duty citation text

29 CFR 1910.119(j)(4)(i) Inspections and tests shall be performed on
process equipment.
A) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the
employer did not
perform inspections and tests on process equipment to maintain its
mechanical integrity. The
employer did not perform "as-received" pop pressure tests for pressure
safety valves
including but not limited to the following:
1.PSV-3396 protecting T-304 in the Alky Unit. This valve was removed from
service in
2006 and sent to Furmanite for rebuild (BWO UOSH-092 0025). On 6/2/2006,
Furmanite
crossed out the "Pre-Test Results (as-found condition)" portion of the VR
Certification Card
and wrote "NA".
2.PSV-3396 protecting T-304 in the Alky Unit. This valve was removed from
service
in
2006 and sent to Furmanite for rebuild (BWO UOSH-092 0024). On 6/23/2006,
Furmanite
crossed out the "Pre-Test Results (as-found condition)" portion of the VR
Certification Card
and wrote "NA".
3.PSV-3423 protecting T-303 in the Alky Unit. This valve was removed from
service in
2008 and sent to Furmanite for rebuild (BWO UOSH-092 0008). On 9/18/2008,
Furmanite
crossed out the "Pre-Test Results (as-found condition)" portion of the VR
Certification Card
and wrote "NA".
4.PSV-5590 protecting E-1390 in the Amine Unit. This valve was removed from
service in 2006 and sent to Furmanite for rebuild (BWO UOSH-092 0035). On
10/3/2006,
Furmanite crossed out the "Pre-Test Results (as-found condition)" portion
of the VR
Certification Card and wrote "NA".
The employer did not instruct Furmanite to perform as-received
pop-pressure
tests. As-
received, pop pressure test for pressure safety valves is essential for
the refinery inspector 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. Serious injury or death could occur to an employee from
exposure to
hazardous chemicals in the event of equipment failure that may have been
prevented by
performing necessary tests on process equipment. This may be a system-wide
occurrence that
requires evaluation of all pressure safety valves throughout the facility.
B) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the
employer did not
perform external inspections of some pressure vessels as evidenced by the
lack of
documentation of these inspections for the period between 1992
(promulgation of OSHA
PSM Standard) and May 17, 2010 (opening date of this inspection). Unless
otherwise
established by a risk-based inspection (RBI) assessment, the RAGAGEP
requires external
inspection of pressure vessels at least every 5 years. These external
inspections check the
outside surface of the vessel, insulations systems, painting and coating
systems, supports and
check for leakage, hot spots, vibration, bulging, out-of-roundness,
sagging and distortion.
Through BWO Document request Nos. 94, 95, 96, 97 and 98, the records of 5
pressure
vessels was selected and reviewed. Review of pressure vessel records by
OSHA Engineerdiscovered the following external inspection deficiencies:
1.T-304 in the Alky Unit: There is one documented external inspection of
this vessel on
April 19, 2000 (BWO UOSH-096-0253). This was the only recorded external
inspection
between 1992 and present. Based on this one documented inspection, there
should have been
documented external inspections for this vessel also in 1995 and 2005. BWO
Inspector
indicated that external inspections were performed but not documented
during an interview
on August 19, 2010.
2.E-1390 in the Amine Unit: There are two documented external inspections
of this
vessel one on March 1, 2006 (BWO UOSH-095-0012) and the other on May 17,
2000 (BWO
UOSH-095-0005). These were the only recorded external inspections between
1992 and
present. Based on these two documented inspections, there should have been
documented
external inspections for this vessel also in 1995 and 2005. During an
interview on August 19,
2010, BWO Inspector indicated that external inspections were performed but
were not
documented.
3.D-304 in the Alky Unit: There are two documented external inspections of
this vessel
one on May 18, 2000 (BWO UOSH-098-0005) and the other on August 26, 2009
(BWO
UOSH-098-0008). These were the only recorded external inspections between
1992 and
present. Based on these two documented inspections, there should have been
documented
external inspections for this vessel also in 1995 and 2005. BWO Inspector,
indicated that
external inspections were performed but not documented during an interview
on August 19,
2010.
4.T-1310 in the Amine Unit: There is one documented external inspection of
this vessel
on May 17, 2000 (BWO UOSH-094-0009). This was the only recorded external
inspection
between 1992 and present. Based on this one documented inspection, there
should have been
documented external inspections for this vessel also in 1995 and 2005. BWO
Inspector
indicated that external inspections were performed but not documented
during an interview
on August 19, 2010.
Without adequate external inspections to detect anomalous surface
conditions, the vessel
could fail resulting in a catastrophic release and exposure to employees.
Serious injury or
death could occur to an employee from exposure to hazardous chemicals in
the event of
equipment failure that may have been prevented by performing necessary
inspections and
tests on process equipment. This may be a system-wide occurrence that
requires evaluation
of all pressure safety valves and pressure vessels throughout the facility.
Note:
2000 API Recommended Practice (RP) 576 Inspection of Pressure-Relieving
Devices:
1.Section 6.1 Reasons for Inspection; "inspecting pressure-relieving
devices is to ensure
that they will provide this protection".
2.Section 6.1 Reasons for Inspection; "pre-testing of the
pressure-relieving deviceshould be included in the shop
inspection/overhaul".
3.Section 6.2.8 Determining "As-Received" Pop Pressure; "This
"as-received" pop
pressure is used in determining the inspection interval".
4. Section 6.4.1.1; Frequency of Shop Inspection/overhaul;  Consistent
"as-received"
pop test results may allow for increasing the inspection interval while
erratic results may
require decreasing the inspection interval.
2006 API 510 Pressure Vessel Inspection Code:
1.Section 6.6 Pressure relieving devices should be inspected per API 576
2.Section 6.6.2.1 Pressure-relieving devices shall be tested and inspected
at intervals
that are frequent enough to verify that the valves perform reliably and
the inspection interval
is determined by the inspector
3.When a pressure relieving device is found to be stuck the inspection
interval shall be
reduced
2006 API 510 Pressure Vessel Inspection Code:
In-Service Inspection, Rating, Repair, and Alteration, Section 6.4.1
"Unless justified by a
RBI assessment, each aboveground vessel shall be given a visual external
inspection at an
interval that does not exceed the lesser of five years or the required
internal inspection.

Issued

2010-11-09 00:00:00

Abate by

2011-07-21 00:00:00

General-duty citation text

29 CFR 1910.119(j)(5) The employer shall correct deficiencies in equipment
that are outside
acceptable limits (defined by the process safety information in paragraph
(d)
of this section)
before further use or in a safe and timely manner when necessary means are
taken to assure
safe operation.
A) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the
employer did not
correct equipment deficiencies in a timely manner for six relief systems
in the Alky Unit.
Forty-two months will have lapsed between employer's acknowledgement of
the deficiency
and mitigation of the hazard. BWO Technical Manager stated these
deficiencies are
scheduled to be mitigated during the next Alky Unit turn-around (TAR) in
the fall of 2011.
This mitigation schedule was verbally conveyed to OSHA engineer from the
BWO Technical
Manager during an interview on September 29, 2010. The following Alky Unit
deficiencies
were reported in a Final South Flare Study by Ambitech in May of 2008 (BWO
UOSH-
008B-0995):
1.Change RV-3396 discharge piping from 8" to 12" diameter.
2.Change RV-3480 discharge piping from 6" to 10" diameter.
3.Change RV-3475 discharge piping from 3" to 4" diameter.
4.Change RV-3474 discharge piping from 3" to 4" diameter.
5.Change RV-3314 discharge piping from 4" to 6" diameter.
6.Change RV-310 discharge piping from 2" to 3" diameter.
7.Change RV-3396 discharge piping from 8" to 12" diameter.
The deficiencies were first identified in a draft South Flare Study to the
employer in
December of 2007. After employer review, the final South Flare Study was
issued by
Ambitech in May of 2008. No risk analysis has been performed to justify
the decision to
delay to replace the piping until fall of 2011. The mitigation effort
could be longer than 42
months if the ALKY TAR is delayed. The replacement of relief valve
discharge piping
(a.k.a. tailpipe piping) may require shut-down or an alternate path for
the relief discharge
must be found, although the employer recently (March 2010) upsized 100
lineal feet of sub-
header flare piping from 8" to 10" diameter as recommended in the same
Flare
Study.
Serious injury or death to an employee could occur in the event of a
failure of deficient
process equipment that may result in employee exposures to hazardous
chemicals. This may
be a system-wide occurrence that requires evaluation of all procedures
throughout the
facility.
B) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the
employer did not
correct equipment deficiencies in a timely manner for relocating the
existing South Flare
K.O. Drum and installing a new South Flare K.O. Drum. Forty-two months
will have lapsed
between employer's acknowledgement of the deficiency and mitigation of the
hazard. The
following Alky Unit deficiencies were reported in a Final South Flare
Study by Ambitech in
May of 2008 (BWO UOSH-008B-0997). These two deficiencies are scheduled to
be
mitigated during the next Alky Unit turn-around (TAR) in the fall of 2011
per BWO
Technical Manager. This mitigation schedule was verbally conveyed to OSHA
engineer from
BWO Technical Manager during an interview on September 29, 2010.
1.Add a new 10 ft. diameter X 24 ft. long South Flare KO Drum in parallel
to the
existing Drum (BWO UOSH-008B-0097).
2.Relocate existing South Flare KO Drum, pumps and flame front generator
175 to 225
ft. away from the base of the flare stack.
The deficiencies were first identified in a draft South Flare Study to the
employer in
December of 2007. After employer review, the final South Flare Study was
issued by
Ambitech in May of 2008(BWO UOSH-008B-0997). The employer has decided to
perform
this work during next TAR of the Alky Unit in the fall of 2011. No risk
analysis has been
performed to justify the decision to delay the replacement and relocation
of the South Flare
KO drum and flame front generator until fall of 2011. The HDS, MSCC, Crude
and LPG
Storage Unit also collected by the South Flare Unit so it is not clear why
this
work is tied to
the Alky Unit TAR. The mitigation effort could be longer than 42 months if
the Alky unit
TAR is delayed. The Final South Flare Study recommended moving the
existing South Flare
K.O. Drum 175 ft. to 225 ft. away from the flare stack. In its current
location the radiative
heat exchange between the flare flame and the K.O. Drum may ignite the
vapors and then
the liquids in the South Flare K.O. drum resulting in fire. Serious injury
or death of an
employee could result in the event of a fire. This may be a system-wide
occurrence that
requires evaluation of all procedures throughout the facility.
Note:  Section 4.4.2.3 of the 1997 API RP 521 Guide for Pressure-Relieving
and
Depressuring Systems  offers guidance for protecting humans and vessels
from the radiation
(heat) generated by a flare. It can be used to calculate the minimum
distance from the
midpoint of the flare flame to the object being considered.

Issued

2010-11-09 00:00:00

Abate by

2011-07-21 00:00:00

General-duty citation text

29 CFR 1910.119(j)(6)(i) In the construction of new plants and equipment,
the employer
shall assure that equipment as it is fabricated is suitable for the
process application for which
they will be used.
A) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the
employer did not
assure that equipment associated with construction was suitable for the
process application for
which it would be used. The employer recently replaced acid relief
neutralizer D-305 in the
Alky Unit. The original vessel was abandoned-in-place. As part of piping
demolition, the
supports/restraints for RV-3307 (protecting acid storage tank D-304)
discharge piping were
compromised by the installation and continued use of a screw-jack support
in lieu of utilizing
a nearby, permanent pipe support column. Serious injury or death to an
employee could
occur in the event that process equipment that was inadequately supported
fell and struck an
employee or in the event that inadequately supported equipment resulted in
a release of
hazardous chemicals which came into contact with employees. This may be a
system-wide
occurrence that requires evaluation of all procedures throughout the
facility.

Issued

2010-11-09 00:00:00

Abate by

2011-07-21 00:00:00

Penalty

Initial $3500.00 · Current $700.00 Reduced

General-duty citation text

29 CFR 1910.119(m)(5)  The employer shall establish a system to promptly
address and
resolve the incident report findings and recommendations. Resolutions and
corrective actions
shall be documented.
A. The employer did not establish and implement an incident investigation
system to
promptly address recommendations and resolve incident findings. This
violation was
identified during inspections of the facility from May 2010 to September
2010, Big West Oil
LLC., 333 West Center Street, North Salt Lake, UT, 84054.  UOSH reviewed
incident
reports dated 2009 to present as well as the incident tracking sheet (BWO
UOSH-036D). The
reports included recommendations but many were found to have no
documentation
indicating
the recommendations were resolved. Examples include, but are not limited
to,
recommendations associated with a flare piping failure on 03/28/2010.  The
employer did not
demonstrate that a system has been established to consistently ensure that
these
recommendations are addressed and resolved.  Critical causal factors were
left uncorrected
by not establishing and implementing a system to promptly address and
resolve incident
report findings/recommendations.  By not making the necessary corrections,
employees may
be exposed to hazardous conditions that could result in serious injury.
This may be a
system-wide occurrence that requires evaluation of all incident reports
and recommendations
throughout the facility.

Issued

2010-11-09 00:00:00

Abate by

2011-09-09 00:00:00

Penalty

Initial $3500.00 · Current $3500.00

General-duty citation text

29 CFR 1910.119(o)(1) Employers shall certify that they have evaluated
compliance with the
provisions of this section at least every three years to verify that the
procedures
and practices
developed under the standard are adequate and are being followed.
A) The employer at Big West Oil, 333 W Center Street, North Salt Lake, UT
84054, did not
verify that procedures and practices developed under the standard are
adequate and being
followed. In the March, 2009 Compliance Audit performed by Z Engineering
and
Environmental Services, Inc., the auditor failed to discover the lack of
written procedures to
maintain the on-going integrity of process equipment as required by
1910.119(j)(2) of the
PSM Standard. The auditor claimed: "BWO has a written PSM program that
addresses all
sections of the PSM rules" (BWO UOSH-039B-0004). This statement would
imply that the
auditor had found written procedures to maintain the on-going integrity of
process equipment
as required by 1910.119(j)(2) of the PSM Standard.
OSHA inspectors unsuccessfully made every effort to discover written
policies and
procedures based on RAGAGEPs for the activities of design, construction,
inspection,
repair,
alteration, rerating, and fitness for service as applied to pressure
vessels, piping, pressure
relief valves, relief vent systems, instrumentation, controls, and pumps.
Most of the
submitted written procedures from BWO related to preventive maintenance
and OSHA
concluded that there were inadequate written procedures for the other
elements of Mechanical
Integrity such as; design, construction, inspection, alteration, rerating,
and fitness for service
for covered equipment. Despite the audit being only a "snapshot", the
auditors should have
easily discovered the paucity of written procedures that could reduce the
potential of
employees exposures to hazardous chemicals.
The auditor incorrectly concluded that the employer could meet the intent
of 1910.119(j)(2)
of the PSM Standard by merely listing the applicable standards and codes
and that written
procedures were not required. The auditor writes: "The BWO Mechanical
Integrity
Equipment Reliability Program references standards and codes used for
construction,
manufacture and maintenance of refinery equipment. These standards appear
to represent
recognized and generally accepted good engineering practices" (BWO
UOSH-039B-0032).
This may be a system-wide occurrence that requires evaluation of all
incident reports and
recommendations throughout the facility.

Issued

2010-11-09 00:00:00

Abate by

2011-07-21 00:00:00

Penalty

Initial $3500.00 · Current $3500.00

General-duty citation text

29 CFR 1910.151(c):  Where the eyes or body of any person may be exposed
to injurious
corrosive materials, suitable facilities for quick drenching or flushing
of the eyes and body shall
be provided within the work area for immediate emergency use.
NOTE:  ANZI-Z358.1-2004:
6.4.2: It is the installer's responsibility to ensure that combination
units shall be in accessible
locations that require no more than 10 seconds to reach. The combination
units shall be located
on the same level as the hazard and the path of travel be free of
obstructions that may inhibit
the immediate use of the equipment.
4.2: The valve shall be resistant to corrosion.
(A)Big West Oil Refinery did not provide suitable facilities for quick
drenching or flushing
of the eyes and body when employees worked with highly corrosive
hydrofluoric acid (HF) in
the HF Alkylation Unit at Big West Oil LLC, 333 W. Center St., N. Salt
Lake.  On 7/7/10, the
Compliance Officer observed that the emergency shower's manual actuator of
the combination
emergency eye wash/shower, located on the east side of the unit, could not
be turned on as a
possible result of exposure to weather and to the corrosive HF. ANSI
Z358.1-2004, Sec 4.2,
states that the emergency shower's actuator shall be resistant to
corrosion. An employee's
exposure to the highly corrosive HF acid could result in serious eye and
skin acid burns.
Without immediate activation of the emergency eye wash/shower, employee's
burns could
worsen.
(B) Big West Oil Refinery did not provide suitable facilities for the
quick drenching or flushing
of the eyes and body when employees may be exposed to highly corrosive
hydrofluoric acid
(HF) in the HF Alkylation Unit at Big West Oil LLC, 333 W. Center St., N.
Salt Lake. On
7/7/10, the Compliance Officer observed that near the southeast corner of
HF Alkylation Unit,
the emergency eye wash/shower was located on a higher level requiring an
employee to travel
up three steps, an additional 15 ft., to reach the emergency eye/shower
unit. The location of the
combination emergency eye wash/shower station would not meet the
requirements of ANSI
Z358.1-2004, Sec. 7.4.2 in that the emergency eye wash/shower station was
not on the same
work level as the employees and the additional distance and time the
employee must travel would
exceed the maximum time of 10 seconds to reach and use the eye wash/shower
station.
Additionally, according to ANSI Z358.1-2004, Sec. 6.4.2, any employee
exposed to highly
corrosive chemical, such as HF, the eye wash/shower station should be
immediately adjacent
to the hazard. The employee's exposure to the highly corrosive HF acid
could result in serious
eye and skin burns. Without immediate attention, employee's burns could
worsen.e's

Issued

2010-11-09 00:00:00

Abate by

2010-11-12 00:00:00

Penalty

Initial $1400.00

General-duty citation text

29 CFR 1910.304(e)(1)(iv): Location in or on premises. Overcurrent devices
shall be readily
accessible to each employee or authorized building management personnel.
These overcurrent
devices may not be located where they will be exposed to physical damage
nor in the vicinity
of easily ignitable material.
(A) On 9/7/10, a safety inspection was accomplished by a UOSH compliance
officer at Big
West Oil LLC, 333 W. Center St., North Salt Lake. During the walk through
of the storage
building, the Compliance Officer observed items stored in front of an
overcurrent device in
the "old tool shop" making accessibility to the panel difficult.
Overcurrent devices need to be
readily accessible to employees in the event of an emergency. In the event
of an electrical
emergency, serious injuries could occur when an employee did not have the
ability to access
the blocked overcurrent device.rent

Issued

2010-11-03 00:00:00

Abate by

2011-07-21 00:00:00

Penalty

Initial $3500.00 · Current $3500.00

General-duty citation text

PSV-5510.
29 CFR 1910. 1910.119 (d)(3)(i)(B) Information pertaining to the equipment
in the process
shall include piping and instrument diagrams (P&ID's).
A) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the
piping and
instrument diagrams were inaccurate or incomplete such as but not limited
to:
UOSH Document Request No. 10 asked for the P&ID drawings for all PSM
Covered
Units
including legends. For the Amine Unit, the employer provided universal
Legend Sheet #1
(BWO UOSH-010B09-0001). The symbols for ball and globe valves on this
legend does not
match the symbols used on the four Amine Unit Drawings:
i.Drawing No. 27, (BWO UOSH-010B09-0002)
ii.Drawing No. 28, (BWO UOSH-010B09-0003)
iii.Drawing No. 29, (BWO UOSH-010B09-0004)
iv.Drawing No. 30, (BWO UOSH-010B09-0005)
B) At Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, the
piping and
instrument diagrams were inaccurate or incomplete such as but not limited
to:
UOSH Document Request No. 10 asked for the P&ID drawings for all PSM
Covered Units
including legends. For the Sulfur recovery Unit, the employer provided
universal Legend
Sheet #1 (BWO UOSH-010B10-0001). This universal legend sheet does not show
the symbol
for piping segments used on Drawing No. 22, (BWO UOSH-010B10-0007). As
explained by
Big West Oil process engineer, the  symbol of a circle with an alphabetic
character in it was
an "arbitrary" symbol used by the consultant Ford, Bacon and Davis in lieu
of Big West
Oil's symbol for piping. The employer should have submitted the legend
assembled by Ford,
Bacon and Davis (FBD) at the time that the SR Unit was designed in 1992.
This SRU legend
(BWO UOSH-127B-0124) was included with pipe traveler material submitted.
C) On or about July 7, 2010, and OSHA engineer observed an amine drain
line connected to
a 1" nozzle for pressure gage PI 5590 on exchanger E-1390 in the Amine
Unit that was not
symbolically represented on  Drawing No. 30, (BWO UOSH-010B09-0005). This
amine
drain line included two isolation valves and a backflow preventer. Big
West Oil process
engineer who is responsible for the Amine Unit verbally indicated to OSHA
that his recent
P&ID surveys had found the same errors.
D) On or about July 7, 2010, OSHA engineer observed three, 1-in inch
isolation valves on
an amine drain line connected to the bottom of Liquid Gage LG-5590 on
exchanger E-1390
in the Amine Unit that was not symbolically represented on  Drawing No.
30, (BWO UOSH-
010B09-0005). The three valves were located downstream of  LG-5590 and
upstream of the
connection to 3/8 inch stainless steel amine drain tubing . Big West Oil
process engineer who
is responsible for the Amine Unit verbally indicated to OSHA that his
recent P&ID surveys
had found the same errors.
E) On or about July 7, 2010, OSHA engineer did not observe 2 one inch
nozzles connected
to  level transmitter LT-5590 in the head of exchanger E-1390 in the Amine
Unit as issymbolically represented on  Drawing No. 30, (BWO
UOSH-010B09-0005). Big West Oil
process engineer who is responsible for the Amine Unit verbally indicated
to OSHA that his
recent P&ID surveys had found the same errors.
F) On or about July 7, 2010, OSHA engineer observed a chain operated
isolation valve on
the 8 inch sour gas line feeding Amine Absorber T-1310 that was not
symbolically
represented on Drawing No. 28, (BWO UOSH-010B09-0003). The chain extends
to grade.
This is a serious omission as it may be crucial to know the presence of
the chain operator at
grade during an emergency operation. Big West Oil process engineer who is
responsible for
the Amine Unit verbally indicated to OSHA that his recent P&ID surveys had
found the
same errors.
G) On or about July 7, 2010, OSHA engineer observed a drain line with
isolation valve and
plug connected to the 8 inch sour gas line feeding Amine Absorber T-1310
that was not
symbolically represented on Drawing No. 28, (BWO UOSH-010B09-0003). Flying
J process
engineer who is responsible for the Amine Unit verbally indicated to OSHA
that his recent
P&ID surveys had found the same errors.
H) On or about July 9, 2010, OSHA engineer observed a drain line with
isolation valve and
plug connected to the 8 inch sour gas line feeding Amine Absorber T-1310
that was not
symbolically represented on Drawing No. 28, (BWO UOSH-010B09-0003).
I) On or about July 9, 2010, OSHA engineer observed a nozzle in the shell
of exchanger E-
1104 that was not symbolically represented on Drawing No. 21, (BWO
UOSH-010B10-
0006).
J) On or about July 9, 2010, OSHA engineer observed a nozzle in the shell
of exchanger E-
1103 that was not symbolically represented on Drawing No. 21, (BWO
UOSH-010B10-
0006).
K) On or about July 9, 2010, OSHA engineer did not find Temperature
Element TE-1820 in
Temperature Well TW-1820 on Exchanger E-1103 as symbolically represented
on
Drawing
No. 21, (BWO UOSH-010B10-0006). The temperature well had been abandoned.
TE-1820
had been moved to the 6 inch diameter piping exiting E-1103 for V-1104.
L) On or about July 9, 2010, OSHA engineer observed a valved drain line on
Specialty Item
No. 51 that was not symbolically represented on Drawing No. 18, (BWO
UOSH-010B10-
0004).
M) On or about July 9, 2010, OSHA engineer could not find Flow Element
FE-1504 in the
location symbolically represented on Drawing No. 18, (BWO
UOSH-010B10-0004). Big
West Oil process engineer who is responsible for the Sulfur Recovery Unit
indicated that the
flow turbine had been moved.
N) On or about July 9, 2010, OSHA engineer observed two solenoid-actuated
valves (BV-
1506 and BV-1512) that vent fuel gas to the atmosphere through a common
3/8 inch diameterstainless steel pipe. These valves relieve pressure in
the
line between two Maxxon safety
valves when they have tripped. Drawing No. 18, (BWO UOSH-010B10-0004)
symbolically
misrepresents that each valve is vented separately.
O) On or about July 9, 2010, OSHA engineer observed two solenoid-actuated
valves (BV-
1506 and BV-1512) that vent fuel gas to the atmosphere through a common
3/8 inch diameter
stainless steel tubing. These valves relieve pressure in the line between
two Maxxon safety
valves when they have tripped. Drawing No. 18, (BWO UOSH-010B10-0004)
symbolically
misrepresents that each valve is vented to atmosphere separately. In
addition, the common
vent-to-atmosphere tubing is fitted with a ball valve which also is not
symbolically
represented on the drawing.
P) On or about July 9, 2010, OSHA engineer could not find a strainer in
the location
symbolically represented on Drawing No. 18, (BWO UOSH-010B10-0004). The
strainer is
symbolically located just downstream of safety valve BV-1513.
Q) On or about July 9, 2010, OSHA engineer could not find a pressure gage
(PI-1537) in the
location symbolically represented on Drawing No. 18, (BWO
UOSH-010B10-0004). The
pressure gage is symbolically located downstream of safety valve BV-1513.
R) On or about July 9, 2010, OSHA engineer could not find a pressure gage
(PI-1539) and
corresponding isolation valve in the location symbolically represented on
Drawing No. 18,
(BWO UOSH-010B10-0004). The pressure gage and isolation valve symbolically
"T" into the
1 inch diameter plant fuel gas line just upstream of burner B-1101.
S) On or about August 12, 2010, OSHA engineer could not find pressure
safety valve PSV-
5510 which protects vessel T-1310 in the location symbolically represented
on Drawing No.
28, (BWO UOSH-010B09-0003) by matching the valve tag information with the
P&ID
information. The aluminum tag on the valve body is marked RV-510 instead
of