OSHA Inspection: CALUMET LUBRICANTS CO., L.P.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $5,000 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.23(a)(2): Ladderway floor opening(s) or platform(s) were not provide
d with swinging gates or were not so offset that a person could not walk directl
y into the opening: a) The employer does not ensure that every ladderway floor o
pening or platform is guarded by a standard railing with the passage through the
railing either provided with a swinging gate or so offset that a person cannot
walk directly into the opening. An access ladder located on TWR- 401 was not equ
ipped with a swing gate, chain, or so offset to prevent personnel from falling t
hrough the opening. Measurements onsite showed an approximate distance of 11 fee
t from the first platform to ground level. Additional higher level platforms on
TWR-401 were also noted to not be equipped with a swing gate or chain. By not en
suring every ladderway
opening was protected, employees were exposed to fall hazards which can result i
n serious injury or death. This may be a system-wide occurrence that requires ev
aluation of all platforms and fixed ladders throughout the facility. This violat
ion was observed on or about December 20, 2010. b) The employer does not ensure
that every ladderway floor opening or platform is guarded by a standard railing
with the passage through the railing either provided with a swinging gate or so
offset that a person cannot walk directly into the opening. An access ladder loc
ated on D- 508F was not equipped with a swing gate, chain, or so offset to preve
nt personnel from falling through the opening. Measurements onsite showed an app
roximate distance of 22 feet from the platform to ground level. By not ensuring
every ladderway opening was protected, employees were exposed to fall hazards wh
ich can result in serious injury or death. This may be a system- wide occurrence
that requires evaluation of all platforms and fixed ladders
throughout the facility. This violation was observed on or about December 20, 20
10. c) The employer does not ensure that every ladderway floor opening or platfo
rm is guarded by a standard railing with the passage through the railing either
provided with a swinging gate or so offset that a person cannot walk directly in
to the opening. An access ladder located on TWR- 801 was not equipped with a swi
ng gate, chain, or so offset to prevent personnel from falling through the openi
ng. Height estimates onsite showed a distance greater than 30 feet from the plat
form to ground level. By not ensuring every ladderway opening was protected, emp
loyees were exposed to fall hazards which can result in serious injury or death.
This may be a system- wide occurrence that requires evaluation of all platforms
and fixed ladders throughout the facility. This violation was observed on or ab
out December 20, 2010. d) The employer does not ensure that every ladderway floo
r opening or platform is guarded by
a standard railing with the passage through the railing either provided with a s
winging gate or so offset that a person cannot walk directly into the opening. A
n access ladder located on TWR- 802 was not equipped with a swing gate, chain, o
r so offset to prevent personnel from falling through the opening. Measurements
onsite showed an approximate distance of 15 feet from the platform to ground lev
el. By not ensuring every ladderway opening was protected, employees were expose
d to fall hazards which can result in serious injury or death. This may be a sys
tem- wide occurrence that requires evaluation of all platforms and fixed ladders
throughout the facility. This violation was observed on or about December 20, 2
010. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of th
is citation, the employer must submit documentation showing that it is in compli
ance with the standard,including the steps that it is taking to ensure that empl
oyees are not being exposed to fall hazards.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.23(c)(1): Open sided floor(s) or platform(s), 4 feet or more above
the adjacent floor or ground level, were not guarded by standard railings (or th
e equivalent as specified in 29 CFR 1910.23(e)(3)(i) through (v), on all open si
des.: The employer does not ensure all platforms 4 feet or more above adjacent f
loor or ground level are guarded by a standard railing. A section of the midrail
approximately 36 inches in length was missing from the overhead platform of the
D-102 Crude Desalter creating a fall hazard of approximately (8) feet. This vio
lation was observed on or about October 1, 2010. Pursuant to 29 CFR 1903.19, wit
hin ten (10) calendar days of the abatement date, the employer must submit docum
entation showing that it is in compliance with the standard, including describin
g the steps that it is taking to ensure that employees are not being exposed to
a fall hazard.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,500 · Current $2,500

General-duty citation text

29 CFR 1910.27(c)(1): The perpendicular distance from the center line of rungs t
o the nearest permanent object on the climbing side of ladder(s) did not meet mi
nimum clearance
requirements: The employer does not ensure that the perpendicular distance from
a fixed ladder to the nearest permanent object is 30". An exchanger fan next to
the D-201 crude drum ladder was only 17" away, thus exposing employees to a stru
ck by hazard. The violation was observed on or about October 1, 2010. Pursuant t
o 29 CFR 1903.19, within (10) calendar days of the date of this citation, the em
ployer must submit documentation showing that it is in compliance with the stand
ard, including the steps that it is taking to ensure that employees are not bein
g exposed to the fall struck by hazard.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $5,000 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.27(d)(2): Fixed ladder(s), used to ascend to heights exceeding 20 fe
et and provided with cages or wells were not provided with a landing platform fo
r each 30 feet of height or fraction thereof: a) The employer does not provide l
anding platforms on fixed ladders that are
used to ascend to heights exceeding 20 feet (except on chimneys). Landing platfo
rms were not provided for each 30 feet of height or fraction thereof for a fixed
ladder located on T-801. As measured onsite, the T-801 fixed ladder was estimat
ed to reach heights greater than 50 feet without an offset landing platform. Alt
hough the fixed ladder on T-801 was equipped with a "hinged rest platform", per
OSHA letter of interpretation, dated 2/25/1983, it states 29 CFR 1910.27 (d)(2)
does not allow the use of hinged rest platforms in lieu of landing platforms. By
not providing landing platforms on fixed ladders exceeding 20 feet, employees w
ere exposed to fall hazards. This may be a system-wide occurrence that would req
uire the evaluation of all fixed ladders throughout the facility. b) The employe
r does not provide landing platforms on fixed ladders that are used to ascend to
heights exceeding 20 feet (except on chimneys). Landing platforms were not prov
ided for each
30 feet of height or fraction thereof for a fixed ladder located on T-206. As me
asured onsite, the T-206 fixed ladder was estimated to reach heights greater tha
n 50 feet without an offset landing platform. Although the fixed ladder on T-206
was equipped with a "hinged rest platform", per OSHA letter of interpretation,
dated 2/25/1983, it states 29 CFR 1910.27 (d)(2) does not allow the use of hinge
d rest platforms in lieu of landing platforms. By not providing landing platform
s on fixed ladders exceeding 20 feet, employees were exposed to fall hazards. Th
is may be a system-wide occurrence that would require the evaluation of all fixe
d ladders throughout the facility. Pursuant to 29 CFR 1903.19, within ten (10) c
alendar days of the date of this citation, the employer must submit documentatio
n showing that it is in compliance with the standard, including the steps that i
t is taking to ensure that employees are protected from unsafe fixed ladders.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $2,500 · Current $5,000

General-duty citation text

29 CFR 1910.37(a)(3): The employer did not ensure each exit route was maintained
free and unobstructed. The employer does not ensure that each exit and passagew
ay is free from obstructions. A 6 inch flare line runs directly in front of the
overhead passageway steps, creating a tripping hazard and obstructing the exit f
rom the platform. This violation was observed on or about October 10, 2010 at th
e D-102 Crude Desalter. Pursuant to 29 CFR 1903.19, within ten (10) calendar day
s of the abatement date, the employer must submit documentation showing that it
is compliance with the standard, including describing the steps that it is takin
g to ensure that employees are not being exposed to this tripping hazard.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $2,500 · Current $2,500

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,500 · Current $1,500

General-duty citation text

29 CFR 1910.101(b): Section 3.4.4, Compressed Gas Association Pamphlet P-1965, a
s adopted
by 29 CFR 1910.101(b): Compressed gas cylinder(s) in use or in storage were not
properly supported to prevent them from being knocked over: The employer does no
t ensure that employees are protected from the hazard of being struck by compres
sed gas cylinders in the event they are knocked over. One argon and two carbon d
ioxide (CO2) cylinders were stored unsecured. This violation was observed on or
about September 20, 2010 near the south wall of the maintenance shop. Pursuant t
o 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation,
the employer must submit documentation showing that it is in compliance with th
e standard, including the steps that it is taking to ensure that employees are n
ot being exposed to struck-by hazards during the movement and use of compressed
gas cylinders.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.253(b)(2)(ii): Assigned storage spaces for cylinders were not locate
d where cylinders could not be knocked over or damaged by passing or falling obj
ects, or subject to tampering by unauthorized persons:
a) The employer does not ensure that assigned storage spaces for cylinders were
not located where cylinders could not be knocked over. This violation was observ
ed on or about September 20, 2010, west of the pump shop where an oxygen cylinde
r was not secured to prevent falling and exposing employees to a struck-by hazar
d. b) The employer does not ensure that assigned storage spaces for cylinders we
re not located where cylinders could not be knocked over. This violation was obs
erved on or about September 20, 2010 at the compressed gas cylinder storage rack
south of the maintenance shop where two acetylene cylinders were not secured to
prevent falling and exposing employees to a struck-by hazard. Pursuant to 29 C.
F.R. 1903.19, within ten (10) calendar days of the date of this citation, the em
ployer must submit documentation showing that it is in compliance with the stand
ard,
including the steps that it is taking to ensure that employees are not being exp
osed to struck-by hazards during the movement and use of compressed gas cylinder
s.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.106(c)(4): Piping systems shall be substantially supported and prote
cted against physical damage and excessive stresses arising from settlement, vib
ration, expansion, or contraction: The employer does not ensure that equipment i
s fabricated in a suitable manner for the process application for which it will
be used. Field inspection of PSV-307, located in the 300 unit, identified unrest
rained discharge piping from PSV-307, through valve #2593,
continuing downward toward the flare header. By not adequately supporting the PS
V-307 discharge piping, a catastrophic piping failure may occur during a release
. This violation was observed on or about December 20, 2010. Pursuant to 29 CFR
1903.19, within ten (10) calendar days of the date of this citation, the employe
r must submit documentation showing that it is in compliance with the standard,
including the steps that it is taking to ensure that employees are not being exp
osed to highly hazardous chemicals.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $2,500 · Current $7,000

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $2,500 · Current $7,000

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): Process safety information pertaining to the equipm
ent did not include relief system design and design basis: The employer does not
have written process safety information (PSI) pertaining to relief system desig
n and design basis. The employer did not have complete written PSI related to PS
V-701. As described in the 2001 Calumet Lubricants Flare Study, conducted by Jac
ob and Associates LLC, PSV-701 was undersized and not adequate based upon the fi
re case relief scenario. As stated under the "Zone 8" summary, finding 1, "Relie
f valve PSV-701 needs to be changed; it is not adequate, the relief valve should
be changed to a 1.5 x G x 2.5." Calculations
in the relief study were based upon the larger "G" orifice size. Without a "G" o
rifice, per the flare study, the valve is too small. In 2008, nearly 7 years aft
er the flare study was completed, the employer responded to the change stating t
he "valve never installed because it was determined adequate protection was avai
lable with existing valve and equalization line to T-700." No MOC was conducted
to assess and document the operating change of keeping the smaller valve in serv
ice. No additional design data or calculations were provided to support keeping
the older, smaller valve in service. No adjustment to the flare study was made t
o show a smaller valve orifice was adequate. Field verification of PSV-701 indic
ated a valve size "1 x E x 5" was currently present on D-700. Consequently, sinc
e no evaluation was done, it is not known whether the PSI is accurate. This viol
ation was documented on or about December 20, 2010. Pursuant to 29 CFR 1903.19,
within ten (10) calendar days of the date of this
citation, the employer must submit documentation showing that it is in complianc
e with the standard, including the steps that it is taking to ensure that employ
ees are not being exposed to highly hazardous chemicals.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $2,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): Process safety information pertaining to the equipm
ent did not include the design codes and standards employed: The employer does n
ot include in its Process Safety Information (PSI), the codes and standards used
in the design of relief systems. Review of the Calumet Lubricants Company Flare
Study, dated 12/04/2001, does not identify which codes and standards are implem
ented and followed in the development of the 2001 Flare Study. This study, condu
cted by Jacob and Associates LLC, makes no reference to API, ASME, or other appl
icable standards used in the design and assessment of relief systems. Examples o
f applicable design codes include, but are not limited to, API 520 Parts 1 and 2
, API 521, API 526, API 537, ASME BPVC Section 8, etc. As a
result, Process Safety Information (PSI) is incomplete. Not maintaining codes an
d standards used in the design of relief systems can prevent the employer from i
dentifying, designing, and maintaining equipment within safe limits. This may be
a system-wide occurrence that requires evaluation of all equipment throughout t
he facility. This violation was documented on or about December 20. 2010. Pursua
nt to 29 CFR 1903.19, within ten (10) calendar days of the date of this citation
, the employer must submit documentation showing that it is in compliance with t
he standard, including the steps that it is taking to ensure that employees are
not being exposed to highly hazardous chemicals.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $21,000

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that the equipment in t
he process complied with recognized and generally accepted good engineering prac
tices: a)The employer does not document that pressure safety valve PSV-217 compl
ies with RAGAGEP. The total backpressure on this valve exceeds approximately 23%
of the
valve's set pressure. As per API 520, Part 1, backpressure on conventional valve
s should not exceed 10 % of the set pressure. Documents provided by the employer
shows PSV-217 with a set pressure of 85 psig, with a total backpressure of 20.0
0 psig under the fire case scenario. Increased backpressure can result in valves
not performing as designed. This violation was documented on or about December
20, 2010. b)The employer does not document that pressure safety valve PSV-809 co
mplies with RAGAGEP. The total backpressure on this valve exceeds approximately
11% of the valve's set pressure. As per API 520, Part 1, backpressure on convent
ional valves should not exceed 10 % of the set pressure. Documents provided by t
he employer shows PSV-809 with a set pressure of 90 psig, with a total backpress
ure of 10.17 psig under the fire case scenario. Increased backpressure can resul
t in valves not performing as
designed. This violation was documented on or about December 20, 2010. c)The emp
loyer does not document that pressure safety valve PSV-810 complies with RAGAGEP
. The total backpressure on this valve exceeds approximately 16% of the valve's
set pressure. As per API 520, Part 1, backpressure on conventional valves should
not exceed 10 % of the set pressure. Documents provided by the employer shows P
SV-810 with a set pressure of 90 psig, with a total backpressure of 15.27 psig u
nder the fire case scenario. Increased backpressure can result in valves not per
forming as designed. This violation was documented on or about December 20, 2010
. d)The employer does not document that pressure safety valve PSV-1001 complies
with RAGAGEP. The total backpressure on this valve exceeds approximately 11% of
the valve's set pressure. As per API 520, Part 1, backpressure on conventional v
alves should not exceed 10 % of the set pressure. Documents provided by the empl
oyer
shows PSV-1001 with a set pressure of 75 psig, with a total backpressure of 8.48
psig under the fire case scenario. Increased backpressure can result in valves
not performing as designed. This violation was documented on or about December 2
0, 2010. e)The employer does not document that pressure safety valve PSV-1002 co
mplies with RAGAGEP. The total backpressure on this valve exceeds approximately
28% of the valve's set pressure. As per API 520, Part 1, backpressure on convent
ional valves should not exceed 10 % of the set pressure. Documents provided by t
he employer shows PSV-1002 with a set pressure of 50 psig, with a total backpres
sure of 14.17 psig under the fire case scenario. Increased backpressure can resu
lt in valves not performing as designed. This violation was documented on or abo
ut December 20, 2010. f)The employer does not document that pressure safety valv
e PSV-1003 complies with
RAGAGEP. The total backpressure on this valve exceeds approximately 23% of the v
alve's set pressure. As per API 520, Part 1, backpressure on conventional valves
should not exceed 10 % of the set pressure. Documents provided by the employer s
hows PSV-1003 with a set pressure of 75 psig, with a total backpressure of 17.45
psig under the fire case scenario. Increased backpressure can result in valves
not performing as designed. This violation was documented on or about December 2
0, 2010. g)The employer does not document that pressure safety valve PSV-1004 co
mplies with RAGAGEP. The total backpressure on this valve exceeds approximately
11% of the valve's set pressure. As per API 520, Part 1, backpressure on convent
ional valves should not exceed 10 % of the set pressure. Documents provided by t
he employer shows PSV-1004 with a set pressure of 75 psig, with a total backpres
sure of 8.96 psig under the fire case scenario. Increased backpressure can resul
t in valves not performing as
designed. This violation was documented on or about December 20, 2010. h)Calumet
does not comply with RAGAGEP, such as, but not limited to API 752, CCPS, and AI
ChE/Dow Fire and Explosion Index; in allowing employees to occupy inadequately p
rotected (i.e., not adequately protected by separation or building construction)
structures which are exposed to explosion, fire, toxic material, corrosive mate
rial, or high pressure hazards resulting from the release of highly hazardous ch
emicals from process equipment, in the Hydrotreater, 100, 400, and 1100 Units Th
e buildings located in unacceptable areas of the blast zone include the main off
ice, laboratory, and truck loading building. i)The employer does not document th
at process equipment complies with RAGAGEP. Pressure vessel D-101 was not re-rat
ed in accordance with API 510. The vessel is stamped at 75 psig at 250 F and was
re-rated to 75 psig at 650. The re-rating of D-210
was addressed by MOC 2010-60. The MOC only contains information addressing the m
etallurgy of the materials used in the vessels; indicating that they do not lose
their properties at the new design temperature of 650 F. However, other informa
tion required by API 510 and other codes has not been addressed. j)The employer
does not document that process equipment complies with RAGAGEP. Pressure vessel
D-210 was not re-rated in accordance with API 510. The vessel is stamped at 80 p
sig at 100 F and was re-rated to 80 psig at 650. The re-rating of D-210 was addr
essed by MOC 2010-61. The MOC only contains information addressing the metallurg
y of the materials used in the vessels; indicating that they do not lose their p
roperties at the new design temperature of 650 F. However, other information req
uired by API 510 and other codes has not been addressed. k)The employer does not
develop safe work practices to provide for the control
of hazards during operations such as lockout/tagout. Per Calumet Lubricants Co.
policy "Lockout & Tagout of Equipment", dated 5/03/2010, Section 13 Car Sealing,
Subsection 13.2, "Block valves upstream and downstream of PSV's require a car s
eal or car seal open (CSO) tag." This policy does not require a car seal or phys
ical locking barrier. Per ASME Boiler and Pressure Vessel Code, Division 1, it s
tates, intervening valves are allowed only when administrative controls are prov
ided to prevent unauthorized valve operation and the valves are provided with me
chanical locking elements. Examples ofmechanical locking elements per ASME inclu
de, but are not limited to, locks with or without chains, and plastic or metal s
traps. By not fully developing safe work practices, employees were not provided
with clear instructions about what methods must be used to isolate valves and/or
equipment. This violation was documented on or about December 20, 2010.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of this ci
tation, the employer must submit documentation showing that it is in compliance
with the standard, including the steps that it is taking to ensure that employee
s are not being exposed to highly hazardous chemicals.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(e)(3)(iii): The process hazard analysis did not address engineer
ing and administrative controls applicable to the hazards and their interrelatio
nships such as appropriate application of detection methodologies to provide ear
ly warning of releases: a)The employer does not conduct a process hazard analysi
s which addresses engineering and administrative controls (process monitoring an
d control instrumentation with alarms and detection hardware such as hydrocarbon
sensors) applicable to the hazards and their interrelationships with appropriat
e application of detection methodologies; and is also appropriate for the comple
xity of the process. Items such as alarms,
pressure relief devices, flares, hydrocarbon sensors, emergency procedures, emer
gency operating procedures, fire monitors were not addressed for many nodes in t
he process hazard analysis. There are almost always consequences of interest for
a change in a process parameter. For example: more flow into a vessel will usua
lly generate more pressure in the vessel, more level in the vessel, or more flow
out of the vessel. Also, reverse flow will usually be problem. Yet items such a
s these were addressed in the Hazop as "No consequences of interest." This viola
tion was documented on or about December 9, 2010 when it was noted that the 2007
What-if PHA for the 1100 Unit listed the consequences of the fire box being too
hot as "Overheating the tubes with possible equipment damage, whereas the HAZOP
PHA listed the consequence of the fire box being too hot as "No
Consequences of interest." The HAZOP contained 14 nodes. One of them, Heater H11
01, was reanalyzed as a What-if. The other 13 nodes did not benefit from this ex
panded approach. For them, most items are addressed as "No consequences of inter
est." Examples: Node 3.3, Feed Line Out, had "No Consequences of Interest for al
l items except leak/rupture. Node 5.2, Line in and Out Including Shell Side,, ha
d "No Consequences of Interest for all items except leak/rupture. Node 9.2, Wate
r Draw Line Out, had "No Consequences of Interest for all items except leak/rupt
ure. b)The employer failed to ensure that the process safety information concern
ing the technology of the process included a written evaluation of the consequen
ces of
deviations, including those affecting the safety and health of employees. A writ
ten evaluation of the consequences of deviation is not available for pressure ve
ssel E-403 A/B/C, 2.1 Line in Shell Side . The consequences of deviation lists "
no consequence of interest" for would include circumstances which could result i
n conditions such asmore flow, less flow, more pressure, and less pressure, the
potential hazards of these consequences (equipment failure, release of hydrocarb
ons, fire, explosion), and a list of the safeguards (e.g., alarms, operating pro
cedures, training, pressure safety valves, flare system, blast-resistant buildin
gs, etc.) available which protect employee safety and health. This may be a syst
em-wide occurrence that requires the development and evaluation of all consequen
ces of deviation throughout the facility. Pursuant to 29 CFR 1903.19, within ten
(10)calendar days of the abatement date, the employer must submit an abatement
plan describing the actions it is taking to ensure that the
abovementioned possibilities are considered in all future Process Hazard Analyse
s to protect employees.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the conse
quences of failure of engineering and administrative controls: a) The employer d
oes not ensure that the 400 Unit process hazard analysis (PHA), dated October 13
, 2009, addresses the consequences of failure of engineering and administrative
controls. "Node 5: T-401 and associated piping", lists "no consequence of intere
st" for items such as more flow, less flow, more pressure, and less pressure, wi
th no possible causes, safeguards or recommendations listed. The consequences of
failure from conditions such as high temperature, high pressure, low flow, high
flow, reverse flow will result in administrative controls (i.e., alarms, implem
entation of emergency operating procedures, manual closing of valves, training)
and engineering controls (relief valves, rupture discs, flare system, automatic
closing of valves)
being put into effect. The consequences of failure of these controls are not inc
luded in the PHA. More pressure and more flow can result in conditions leading t
o catastrophic equipment failure and the potential release of hydrocarbons. By n
ot evaluating the consequences of deviation, including those affecting the safet
y and health of employees, the employer was deprived of critical information use
d to ensure process stability and employee safety and health. This violation was
documented on or about December 20, 2010. b) The employer does not ensure that
the 400 Unit process hazard analysis (PHA), dated October 13, 2004, addresses th
e consequences of failure of engineering and administrative controls. "Node 5.4:
PSV to Flare", lists "no consequence of interest" for items such as more flow,
reverse flow, and more pressure, with no possible causes, safeguards or recommen
dations listed. The consequences of failure from conditions such as high tempera
ture, high pressure, low flow, high flow, reverse flow will result in administra
tive controls (i.e., alarms,
implementation of emergency operating procedures, manual closing of valves, trai
ning) and engineering controls (relief valves, rupture discs, flare system, auto
matic closing of valves) being put into effect. The consequences of failure of t
hese controls are not included in the PHA safeguards, or recommendations listed.
More pressure and more flow can result in conditions leading to catastrophic eq
uipment failure and the potential release of hydrocarbons. By not evaluating the
consequences of deviation, including those affecting the safety and health of e
mployees, the employer was deprived of critical information used to ensure proce
ss stability and employee safety and health. This violation was documented on or
about December 20, 2010. Pursuant to 29 CFR 1903.19, within ten (10) calendar d
ays of the date of this citation, the employer must submit documentation showing
that it is in compliance with the standard, including the steps that it is taki
ng to ensure that employees are not being
exposed to highly hazardous chemicals.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(v): The employer failed to perform a process hazard analys
is of the appropriate complexity of the process which identified, evaluated, and
controlled the hazards involved in facility siting The employer is not performi
ng a process hazard analysis which is of the appropriate complexity for the proc
ess and identifies, evaluates, and controls the hazards involved in facility sit
ing. The employer violated this standard when it was noted that several key ques
tions on the Process Hazard Analysis Facility Siting Checklists and Building Eva
luation Forms completed in 2008 and 2009 were completed incorrectly, without bas
is and consideration of a facility blast study.
The facility siting checklist was completed without the benefit of a Facility Si
ting Analysis report (completed September 10, 2010), which indicates blast overp
ressures as high 14.7 psi, resulting in serious injuries and fatalities at the r
efinery. This exposes employees to fire and explosion hazards. Pursuant to 29 CF
R 1903.19, within ten (10) calendar days of the abatement date, the employer mus
t submit an abatement plan describing the actions it is taking to ensure that th
e abovementioned possibilities are considered in all future Process Hazard Analy
ses to protect employees.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(e)(6): The employer did not ensure after the initial process haz
ard analysis that the process hazard analysis was updated and revalidated at lea
st every five (5) years by a team meeting the requirements of 20 CFR 1910.119(e)
(4) to assure that the process hazard analysis was consistent with the current p
rocess:
a)The employer does not consider in its 1100 Crude Unit PHA update/revalidation,
the throughput increase and any potential effects the increase might have on th
e adequacy of the current process, including the existing relief system. As prov
ided by the employer, throughput design changes were made in 2002 for the 1100 C
rude Unit to increase throughput to 3600 Barrels Per Day (BPD). The employer sta
ted that in place of an MOC, a PHA would be conducted. Review of the 1100 Crude
Unit PHA, dated 4/16/2002, did not identify where throughput was assessed. Data
supporting evidence of evaluation, consultation with the refinery's engineering/
technical staff, and whether the existing/current engineering analysis of the re
lief system is adequate for the new unit throughput is not in the PHA. Documents
provided by the employer stated that "Calumet Lubricants Co. has reviewed the d
esign to the piping associated with all Pressure Safety Valves (PSV's)...", but
does not address throughput changes. A detailed review of the
relief system and associated capacity is critical during any change to ensure th
e current system can appropriately function with increased throughput. This viol
ation was documented on or about December 20, 2010. b) The employer does not con
sider in its 700 Unit PHA update/revalidation, the throughput increase and any p
otential effects the increase might have on the adequacy of the current process,
including the existing relief system. As provided by the employer, throughput d
esign changes were made in 2003 for the 700 Unit to increase throughput to 5200
Barrels Per Day (BPD). The employer stated that in place of an MOC, a PHA would
be conducted. Review of the 700 Unit PHA, dated 10/27/2004, does not identify wh
ere throughput was assessed. Data supporting evidence of evaluation, consultatio
n with the refinery's engineering/technical staff, and whether the existing/curr
ent engineering analysis of the relief system is adequate for the new unit throu
ghput is not
in the PHA. Documents provided by the employer stated that "Calumet Lubricants C
o. has reviewed the design to the piping associated with all Pressure Safety Val
ves (PSV's)...", but does not address throughput changes. A detailed review of t
he relief system and associated capacity is critical during any change to ensure
the current system can appropriately function with increased throughput. This v
iolation was documented on or about December 20. 2010. Pursuant to 29 CFR 1903.1
9, within ten (10) calendar days of the date of this citation, the employer must
submit documentation showing that it is in compliance with the standard, includ
ing the steps that it is taking to ensure that employees are not being exposed t
o highly hazardous chemicals.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,500 · Current $7,000

General-duty citation text

29 CFR 1910.119(h)(2)(vi): The employer did not maintain a contract employee inj
ury and
illness log related to contractor's work in process areas: The employer does not
maintain OSHA 300 injury and illness logs for contractors working in the refine
ry process areas. This violation was documented on or about September 22, 2010.
Pursuant to 1903.19, within ten (10) calendar days of the date of this citation,
the employer must submit documentation showing that it is in compliance with th
e standard, including the steps that it is taking to ensure that contractor safe
ty and illness information is maintained.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written proc
edures to maintain the on-going mechanical integrity of process equipment: a)The
employer does not establish and implement written procedures to ensure the on-g
oing integrity of process equipment. Specifically PSV-306 and PSV-1403 had the w
rong spring. The mechanical integrity program does not include procedures which
would prevent the installation of pressure safety valves which contain incorrect
parts.
During a review of Pressure Safety Valves (PSV), PSV-306 and PSV-403 were identi
fied as containing incorrect parts, specifically PSV-306 had the wrong spring. A
s a result, both valves failed a leak test. Calumet Lubricants Co. "Mechanical I
ntegrity Requirements", dated 12/03/2008, contains subsections related to inspec
tion and testing of PSVs, but does not address procedures for ensuring that corr
ect internal components are installed in all PSVs. The result is deficient equip
ment was in service within the refinery. Incorrect internal parts in PSV can res
ult in the PSV not functioning as designed which could result in catastrophic eq
uipment failures. b)The employer does not establish and implement adequate writt
en procedures. Mechanical The mechanical integrity program does not include proc
edures which would prevent the installation of pressure safety valves containing
the wrong parts. During
CSHO a review of Pressure Safety Valves (PSV's) covered by the Mechanical Integr
ity Program, PSV-507 and PSV-512 were identified as containing incorrect parts,
specifically the wrong upper washer, spring, lower washer, and disc holder. Alth
ough the Calumet Lubricants Co. "Mechanical Integrity Requirements", dated 12/03
/2008, contains subsections related to inspection and testing of PSV's and ruptu
re disks, the policies and procedures do not contain procedures for ensuring tha
t correct internal components are installed in all PSV's. As a result, PSV's are
in service with incorrect internal components. By not establishing and implemen
ting a comprehensive mechanical integrity program, deficient equipment was in se
rvice within refining units. Incorrect internal parts in PSV's can result in the
PSV not functioning as designed. Such an event can lead to catastrophic equipme
nt failures.
c)The employer is not implementing adequate procedures to ensure the on-going in
tegrity of process equipment. The employer's written Mechanical Integrity proced
ure 3.2(g) states "Run nut to 1" of stud shows past the nut." This procedure has
not been implemented in the 1100 Unit resulting in the presence of "short bolts
" in the following process equipment. Line 2" HL-1100-027-1A1A on the LCV-1123 c
ircuit on the flange connecting the Valtek Valve to the line. Line 4" HL-1100-01
7-1A1A on the TCV-1100B circuit on the flange connecting the Valtek Valve to the
line. Line 4" HL-1100-017-1A1A on the LCV-1123 circuit on the flange connecting
the horizontally-orientated Valtek Valve to the line.Line 2" HL-1100-024-A2-1-2
on the FCV-1114 circuit on the flange connecting the vertically-orientated Valt
ek Valve to the line. Line 3" HL-1100-023-A2-1-2 on the 1102 circuit on the flan
ge connecting the vertically-orientated Valtek Valve to the line.
"Short Bolts" are bolts that are not in accordance with Mechanical Integrity Pro
gram 3.2(g), "Run nut to 1" of stud shows past the nut". This violation was obse
rved on or about October 01, 2010. d)The employer does not establish and impleme
nt written procedures to ensure the identification and resolution of anomalous i
nspection data as part of its on-going mechanical integrity program. The followi
ng anomalous data was identified: Piping Circuits Missing, incorrectly recorded
or incorrect location of TML ports: C-001, C- 001A, C-003, C-004, C-006, C-008,
C-011, C-012, C-013, C-016, C-018, C- 024, C-025, C-030, C-031, C-032, C-034, C-
037, C-038, C-039, C-040, 11-004, 11-016; 400-12, 400-18, 400-19, 400-20, 400-21
1100-1, 1100-1A, 1100-3, 1100-13, 1100-15, 1100-18, 1100-19, 1100-23 TML ports
are missing on the insulated portion of the piping. HT018, HT009, 400-005, 400-0
21, 400-022, 400-033
UT data not recorded on the pipe or in the database: C-001, C-001A, C-004, C- 03
0, C-037. Incorrectly recorded UT data: C-016, C-018, C-028 No isometric drawing
or incorrect isometric (different than 2000 isometric) drawing, or TML points m
issing on the drawing C-004, C-005/005A, C-007, C- 010, C-011, C-013, C-014, C-0
15, C-016, C-018, C-023, C-031, C-032, C-033, C-034, C-037, C-038, 11-004, 11-01
6; 400-011, 400-20, 1100-02, 1100-3, 1100- 5, 1100-15, 1100-20 Thickness Measure
ment Locations not tested 11-001 -two of five established TML have UT data 11-00
4 -one of six established TML has UT data. 11-016 -one of two established TMLs h
as UT data. 400-20 -eight of twenty TML established have UT data. 400-21 -six of
thirty-eight TML established have UT data. 400-22 -one of twenty-five TML estab
lished has UT data. 400-23 -two of nineteen TML established have UT data.
400-24 -no UT data has been collected for this circuit.400-24 -no UT data has be
en collected for this circuit. 400-25 -only six of twenty-three TML established
have UT data. 400-32 -only six of twenty-eight TML established have UT data. 400
-33 -No UT data has been collected for this circuit. Thickness Monitoring Locati
ons which are not reproducible D-1001: The pressure vessel has been painted so t
he current TML are not reproducible. D-210: The pressure vessel has been painted
so the current TML are not reproducible. R-401: Only one inspection was conduct
ed between 1995 and 2008 and the 2008 inspection has different TML points than t
he July 1995 UT inspection. Thickness measurements that increase over time UT te
st data is entered into the UlraPipe system. When the thickness of pipe is found
to be larger than the previous measurement; the UltraPipe program enters an "RR
" notation adjacent to the test result to notify the
user that the value is a potential error (metal pipe cannot grow in thickness).
It is then incumbent upon the user to resolve this value (i.e., re-take the meas
urement, calibrate the equipment, establish a new baseline, etc.). Calumet has n
ot implemented a written program to resolve thickness monitoring results that ar
e greater than those obtained during the previous inspection. e)Calumet is not i
mplementing a program to ensure appropriate corrosion rates are established for
piping in accordance with the Calumet "Inspection Procedure for Piping Systems".
Section 5.2 requires that "initially the ultrasonic thickness measurements shal
l be repeated every two years to confirm the corrosion rate. For most of the pip
ing vessels in Units 100, 400, and 1100, the thickness monitoring inspections ar
e not conducted every two years in accordance with the program. This is particul
arly critical for this facility since in many instances they cannot reproduce ol
d TML or the old TML have been abandoned and replaced with new TML; and hence no
corrosion rate have
been established for many piping circuits. No baseline UT data was collected and
no corrosion rates have been established for piping circuit such as but not lim
ited to the following. 11-001 H-1101 to T-1101 11-004 P-1101 A/B Discharge to T-
1101 11-016 D-1101 Relief FH-1 to FH-20400-008 f)Calumet has not established and
implemented a written program that ensures that historical UT measurements whic
h are at or beyond their retirement date are resolved or reconciled. Piping and
pressure vessels operated beyond their thickness retirement date have a greater
chance of rupture resulting in flammable vapor clouds and the potential for fire
and explosion.
TC-1 Crude Tower (T-101) 1994 Alltech Inspection Report TML pointInspection Date
Expected Life (years)TML Retire Date N-221/944.14 years2/98 S-21/941.36 years5/9
5 Crude Unit Piping 1994 Alltech Inspection Report TML pointInspection DateExpec
ted Life (years)TML Retire Date C016-1501/940 years1/94 C016-1701/940 years1/94
Naphtha Piping 1990 Walter Rossler Company Inspection Report Naptha Piping Circu
its- Naptha 01 to Naptha-051 Calumet Inspection Program D-210: TML is beyond its
retirement date of April 28, 2010. D-102: TML is beyond its retirement date of
April 28, 2010. There is a November 2005 recommendation by the Calumet inspectio
n team to replace D-
102 (aka-Desalter). RX-301: TML point #18 has exceeded its calculated retirement
date. RX-302: TML point #19 has exceeded its calculated retirement date, 5/2/20
09. g)Calumet did not comply with RAGAGEP, such as but not limited to NFPA 496,
by failing to implement a preventative maintenance schedule/ program for the pos
itive pressure control system located in the refinery control room. During this
inspection OSHA found the positive pressure control system present in the refine
ry control room was not operational and there is no preventative maintenance pro
gram in place which addresses this equipment. Indicators (functional magnehelic
gauge and audible alarm) of a functioning positive pressure control system were
not operational. Pressurization is used to keep a positive pressure in a buildin
g for the purpose of keeping harmful or
hazardous vapors from entering.Pursuant to 29 CFR 1903.19, within ten (10) calen
dar days of the date of this citation, the employer must submit documentation sh
owing that it is in compliance with the standard, including the steps that it is
taking to ensure that employees are not being exposed to highly hazardous chemi
cals.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(j)(4)(i): Inspections and tests were not performed on process eq
uipment to maintain its mechanical integrity: a)The employer did not require Cha
rter Chambers, LLC to perform inspections and tests on process equipment to main
tain its mechanical integrity. As per the "Pressure Relief Valve Test & Inspecti
on Report", dated 1/26/2010, PSV-2(900) was not subjected to an "as received pop
test." As a result, the pop test was not performed. This violation was document
ed on or about December 20, 2010.
b)The employer did not require Charter Chambers, LLC to perform inspections and
tests on process equipment to maintain its mechanical integrity. As per the "Pre
ssure Relief Valve Test & Inspection Report", dated 8/24/2010, PSV-1403 was not
subjected to an "as received pop test." As a result, the pop test was not perfor
med. This violation was documented on or about December 20, 2010. c)The employer
did not require Charter Chambers, LLC to perform inspections and tests on proce
ss equipment to maintain its mechanical integrity. As per the "Pressure Relief V
alve Test & Inspection Report", dated 8/24/2010, PSV-1404 was not subjected to a
n "as received pop test." As a result, the pop test was not performed. This viol
ation was documented on or about December 20, 2010. d)The employer is not conduc
ting inspection and testing of underground piping systems.
Calumet failed to complete visual and UT piping inspections for any of its under
ground piping systems as specified by consensus standards, such as but not limit
ed to API 570. API 570 recommends a visual inspection of Class I and Class II pi
ping every 5 years, and UT testing of Class I piping every 5 years and Class II
piping every 10 years. Calumet did not inspect underground piping until OSHA was
onsite. The following underground piping circuits did not have a visual inspect
ion within the specified time frame: 1. D1501 to P1501 A/B flare drum liquid to
pump 2. D1506 to sump at truck loading dock (piping was not coated and wrapped 3
. D1505 to P1517 knockout drum adjacent to treater to pump suction. The employer
violated this standard on or about October 9, 2010, when it was determined that
Calumet Lubricants failed to conduct inspectionss and testing of its undergroun
d piping.
e)The employer is not conducting inspection and testing of insulated piping. Cal
umet failed to complete piping inspections for any of the insulated piping as sp
ecified by consensus standards, such as but not limited to API 570. The employer
has not effectively implemented its mechanical integrity program, Section 9.3 a
nd 14, Corrosion Under Insulation (CUI). During this, inspection it was determin
ed that Calumet did not conduct corrosion under insulation (CUI) inspections for
all piping circuits located in the 100, 400, and 1100 Units. The employer viola
ted this standard on or about October 9, 2010, when it was determined that Calum
et Lubricants failed to conduct inspectionss and testing of its insulated piping
. f)The employer is not conducting inspection and testing of deadleg piping. Cal
umet failed to complete piping inspection and testing for deadleg piping, as spe
cified by consensus
standards, such as but not limited to API 570. The employer has not effectively
implemented its mechanical integrity program, Section 3.1(b), 9.2, and 14, "Dead
legs". During this, inspection it was determined that Calumet did not conduct in
spections of deadleg piping for piping circuits located in the 100, 400, and 110
0 Units. Deadleg piping was identified on piping circuits such as, but limited t
o the following: 400-001, 400-004, 400-005, 400-006, 400-009, 400-010, 400-013,
400-022, 400-023, 400-028,400-031, 400-032, 400-033. The employer violated this
standard on or about October 9, 2010, when it was determined that Calumet Lubric
ants failed to conduct inspectionss and testing of its deadleg piping. g)The emp
loyer did not ensure that critical valves were inspected at a frequency consiste
nt
with applicable manufacturers' recommendations and good engineering practices. T
he employer violated this standard on or about January 5, 2011 when an investiga
tion discovered there was no documentation to indicate the following critical va
lves were inspected or tested: FSV-113(900), FSV-114(900), FSV-115(900), FSV-307
(900), FSV- 309(900), FSV-310(900), FSV-311(900), and VGV 1402. The employer vio
lated this standard on or about October 9, 2010, when in response to a request f
or documents Calumet Lubricants-Cotton Valley did not provide information relate
d to the inspection of its underground piping or piping is insulated at the refi
nery. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of t
his citation, the employer must submit documentation showing that it is in compl
iance with the standard, including the steps that it is taking to ensure that em
ployees are not being
exposed to highly hazardous chemicals. The employer must include in the abatemen
t plan information describing the actions it is taking to ensure that an asbesto
s survey will be completed. The violation must be abated no later than 60 days f
rom the receipt of this citation.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

1910.119(j)(4)(ii): The inspections and testing procedures did not follow recogn
ized and generally accepted good engineering practices: a.The employer's inspect
ions and testing procedures for collecting thickness measurements do not follow
recognized and generally accepted good engineering practices such as API 510 (20
06), Section 5.6.2.1; which specifies that the thickness for all major component
s (shells, heads, cone sections) and a representative sample of vessel nozzles s
hould be measured and recorded. Calumet is not performing the proper inspections
on the following pressure vessels: 1. T-802: Ultrasonic thickness (UT) measurem
ents have not been performed.
2. T-101: UT measurements have not been performed. 3. E-302: UT measurements hav
e not been performed. 4. T-401: UT measurements have not been performed. 5. RX-3
02: UT measurements have not been performed. 6. RX-305: UT measurements have not
been performed. 7. D-302: UT measurements have not been performed. 8. E-301A: U
T measurements have not been performed. b.The employer's inspections and testing
procedures for classifying piping systems containing flammable liquids and gase
s do not follow recognized and generally accepted good engineering practices suc
h as API 570. API 570 classifies piping which contains C3, C4, and C5 liquids an
d gases as Class 1 piping. Calumet
Lubricant's inspection records classify all piping in the 400 Unit as Class II p
iping. Examples of piping circuits, which should be classified as Class I becaus
e they contain methane, ethane, C3, C4, or C5 liquids and gases are, such as but
not limited to the following: 1. 400-08; D-210 Vent to PSV-217 Class II 2" and
3" Piping 2. 400-09; D-210 Vapors Class II 1" Piping 3. 400-10; T-401 Overhead t
o E-401 Class II 6" Piping 4. 400-11; T-401 Overhead to D-401 Class II 6" Piping
5. 400-12; Reflux to T-401 Class II 2" and 3" Piping 6. 400-13; P401A/B Dischar
ge Class II 1" and 2" Piping 7. 400-14; D-401 to P401A/B Suction Class II 3" Pip
ing 8. 400-15; E-401 to D-401 Class II 4" Piping
9. 400-16; Makeup Gas to T-401 Class II 1" Piping 10. 400-17; D-401 Vapor to Fue
l Drum Class II 2" Piping 11. 400-18; T-401 to R401SS Class II 6" Piping 12. 400
-19; R401SS to T-401 Class II 10" Piping 13. 400-20; T-401 Outlet to LCV-401 Loo
p Class II 2" and 3" Piping 14. 400-21; T-401 Outlet to E-404 TS Class II 4" Pip
ing Calumet is not correctly classifying piping located in the 400 Unit. API 570
recommends UT inspection of Class I piping every 5 years and Class II piping ev
ery 10 years. Therefore, incorrectly classifying piping circuits will result in
longer periods between inspection cycles; potentially resulting in a catastrophi
c event should a pipe become too thin and rupture.
c.The employer is not conducting audits of its internal inspection program to de
termine if it is meeting the requirements of the inspection code. During this in
spection, deficiencies such as: missing or incorrect TML locations, missing or i
ncorrectly entered TML values, TML that are not reproducible, and inaccurate iso
metric drawings were identified. API 570, Section 5.13 indicates that an interna
l audit be conducted periodically to determine the following: 1. The requirement
s and principles of this inspection code API 570 are being met; 2. All-owner use
r responsibilities are being properly discharged; 3. Intervalsand extent of insp
ections are adequate for covered piping systems; 4. All general types of inspect
ions and surveillance are being adequately applied; 5. Inspection data analysis,
evaluation, and recording are adequate;
6. All repairs, re-ratings, and alterations comply with this code. d.The employe
r's inspection and testing procedures for its Risk Based Inspection (RBI)Program
is not in accordance with API 580 (2009). The Calumet Lubricants RBI program do
es not include or consider the following: 1. As per API 580, Section 16, RBI ass
essments should be team-based and include a team leader, inspector, corrosion sp
ecialist, process specialist, operations personnel, maintenance personnel, safet
y and environmental manager, and management; 2. As per API 580 Section 7 the RBI
assessment should have clear goals and objectives; 3. As per API 580, Section 6
.6.2 is a logical and structured process for planning and evaluating inspection
activities for pressure equipment; 4. As per API 580, Section 7.3.4 the first st
ep in the application of RBI is
screening of entire process units to rank relative risk. The screening points ou
t areas that are higher in priority and suggests which process to begin with; 5.
As per API 580 an RBI plan should be completed. The Calumet Lubricants RBI prog
ram has not been incorporated into, delineated or included in the Calumet Mechan
ical Integrity/Quality Assurance Manual. Calumet Lubricants does not have an RBI
program meeting the criteria of API 580. Pursuant to 29 CFR 1903.19, within ten
(10) calendar days of the abatement date, the employer must submit documentatio
n showing that it is in compliance with the standard, including the steps that i
t is taking to ensure that all inspection and testing procedures follow recogniz
ed and generally accepted good engineering practices:g

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

1910.1910.119(j)(4)(iii): The frequency of inspections and tests of process equi
pment conducted by the employer is not consistent with good engineering practice
s.
This violation was observed on or about October 4, 2010 when in response to a re
quest for documents; Calumet Lubricants, Cotton Valley Louisiana, provided infor
mation related to the inspection of its piping and pressure vessels at the refin
ery. a)Calumet is not completing visual inspections of its pressure vessels loca
ted in Units 100, 300, 400, 800, and 1100 within the timeframes specified by con
sensus standards, such as but not limited, to API 510. API 510 recommends a visu
al inspection of all pressure vessels a minimum of every 5 years and a UT/intern
al inspection at least every 10 years. The following pressure vessels have not b
een inspected in accordance with RAGAGEP, such as but not limited to API 510. Ca
lumet is not completing inspections of pressure vessels as required by the equip
ment manufacturer.
Pressure Vessels Unit 400 Pressure Vessels 1.T-401: Thickness measurements (UT-u
ltrasonic thickness) A UT inspection was not performed by the required date of S
eptember 15, 2010 for two TML (6" and 1" nozzle) in accordance with API 510 and
the UltraPipe assessment calculated by Calumet. 2.FB-403: was manufactured in 19
99. There is no baseline UT information available for FB-403 and no UT data has
ever been collected. Corrosion rates have not been calculated as per Calumet Lub
ricants, Sections 5.1 and 5.2, Frequency of Inspections, and in accordance with
API 510. A UT inspection was not performed by the required date of September 201
0. Moore model 5400 fans: The required manufacturer's inspections have not been
performed to include an annual inspection of the system pressure, nuts and bolts
, resilient mounts, and blade tips. Cooling Products, Inc.: The required manufac
turer's inspections have not been performed to include: once each month the pitc
h and angle and setting of the fan blades should be carefully checked; once ever
y
60 days the motor bearings should be checked and lubricated if necessary. 3.R-40
1: was manufactured in 1954. A UT inspection was not performed every ten years i
n accordance with API 510 and theUltraPipe assessment calculated by Calumet Lubr
icants. Only one inspection was conducted between 1995 and 2008 and the 2008 ins
pection has different TML points than the July 1995 UT inspection. No corrosion
rate has been calculated as in accordance with API 510. 4.D-210: The manufacture
date for D-210 is unknown and this pressure vessel was put into service by Calu
met prior to 1995. A UT inspection was not performed for two specific TMLs by th
e required dates of June 6, 2009 and June 28, 2010 in accordance with API 510 an
d the UltraPipe assessment calculated by Calumet Lubricants. One TML is beyond i
ts retirement date of April 28, 2010. Unit 100 Pressure Vessels 1.T-101: The man
ufacture date for T-101 is unknown. Previous internal inspection and UT inspecti
on were conducted in 2005. Corrosion rates have not been calculated as per Calum
et Lubricants, Sections 5.1 and
5.2, Frequency of Inspections, and in accordance with API 510. A UT inspection w
as not performed for four specific TMLs by the required date of November 29, 200
8 in accordance with API 510 and the UltraPipe assessment calculated by Calumet
Lubricants. No inspections have been conducted in accordance with the API 510 ti
meframe requirements for the nozzles and man-ways. 2.D-102: was manufactured in
1926. A UT inspection was not performed by the required dates of July 25, 2007,
March 17, 2008 and November 6, 2008 for twelve TMLs in accordance with API 510 a
nd the calculated UltraPipe assessment conducted by Calumet Lubricants. One TML
is beyond its retirement date of April 28, 2010. There is a November 2005 recomm
endation by the Calumet inspection team to replace D-102 (aka-Desalter). 3.E-102
: A UT inspection was not performed for six TMLs by the required date of Novembe
r 20, 2010 in accordance with API 510. Unit 800 Pressure Vessels 1.T-801: was ma
nufactured in 1956. There is no baseline UT information available for T-801 and
the design maximum allowable working pressure (MAWP) of the vessel is not known.
The previous internal
inspection and UT inspections were conducted in 2005. Corrosion rates have not b
een calculated as per Calumet Lubricants, Sections 5.1 and 5.2, Frequency of Ins
pections, and in accordance with API 510. A UT inspection was not performed by t
he required date of February 15, 2010. 2.D-301: The manufacture date for D-301 i
s unknown but was put into service by Calumet prior to 1997. There is no baselin
e UT or external visual inspection information available for D-301. The previous
internal inspection was conducted in 2008 and UT inspection was conducted in 20
03. A UT inspection was not performed by the required date of July 24, 2010 in a
ccordance with the inspection dates calculated by UltraPipe and the RBI assessme
nt conducted by Calumet. 3.E-301A: The last UT inspection was conducted in June
2003. Only 7 of 18 TML were actually tested; missing UT data on the shell. A UT
inspection was not performed by the required date of June 1, 2010 in accordance
with the inspection dates calculated by UltraPipe and the RBI assessment conduct
ed by Calumet. 4.E-302A: was manufactured in 1953. The last UT inspection was co
nducted in July 2003 and this is the only recorded UT inspection. Only 10 of 18
TML were actually tested; and UT data is missing on the shell. A UT inspection w
as not performed by the required date of July 23, 2010 in accordance with the in
spection dates calculated by
UltraPipe and the RBI assessment conducted by Calumet. 5.E-302B: was manufacture
d in 1953. A UT inspection was not performed for specific TML by the required da
te of June 1, 2009 or July 24, 2010 in accordance with the inspection dates calc
ulated by UltraPipe and the RBI assessment conducted by Calumet. 6.RX-301: UT in
spections were not performed for specific TML by the required dates of November
7, 2008, September 28, 2009, and April 30, 2010 in accordance with the inspectio
n dates calculated by UltraPipe and the RBI assessment conducted by Calumet. RX-
301 is missing UT data on the shell, top head and bottom head. TML point #18 has
exceeded its calculated retirement date. 7.RX-302: UT inspections were not perf
ormed for specific TML by the required dates of November 7, 2008 and January 9,
2009 in accordance with the inspection dates calculated by UltraPipe and the RBI
assessment conducted by Calumet. RX-302 is missing UT data on the shell, top he
ad, 10" outlet, and 1.5" drain. TML point #19 has exceeded its calculated retire
ment date, 5/2/2009. 8.RX-305: UT inspections were not performed by the required
dates of November 7, 2008 and March 24, 2010 in accordance with the
inspection dates calculated by UltraPipe and the RBI assessment conducted by Cal
umet. RX-305 is missing UT data on the shell, top head and bottom head. 9.D-302:
was manufactured in 1958. UT inspection was not performed by the required date
of July 23, 2010 in accordance with the inspection dates calculated by UltraPipe
by Calumet. UT data is missing on the shell, the bottom/top and head. External
visual inspection of D-302 has been not conducted every five years and an intern
al visual has not been performed every ten years. 10.FB-302, FB-303, FB203B: hav
e not had an external visual inspection every five years as is required by API 5
10, 6.4. 11.E-302A: was manufactured in 1953 and the only record of inspection i
s in 2003. A UT inspection was not performed by the required date of July 23, 20
10, in accordance with the inspection dates calculated by UltraPipe and used by
Calumet Lubricants. 12.V-103: has not had an external visual inspection every fi
ve years as is required by API 510, 6.4. Relief System Pressure Vessels
1.D-1501(knockout drum): was manufactured in 1947. D-1501 has not had an externa
l visual inspection every five years as is required by API 510, 6.4. There has b
een no UT inspection on this vessel since August 1984; hence, no internal or thi
ckness measurement inspections have been conducted in the past ten years. 2.D-15
05 (knockout drum): was manufactured in 1970. D-1505 has not had an external vis
ual inspection every five years as is required by API 510, 6.4. There has been n
o UT inspection on this vessel since August 1976; hence, no internal or thicknes
s measurement inspections have been conducted in the past ten years. b)Calumet i
s not completing visual inspections of its piping systems located in the 100, 40
0, 1100, Treater and hydrotreater units within the timeframes specified by conse
nsus standards, such as but not limited to, API 570. API 570 indicates that a vi
sual inspection of Class I and Class II piping be performed every 5 years. API 5
70 also states that thickness measurements be performed every 5 years for Class
I piping and every 10 years for Class II piping. The following piping circuits d
id not
have a visual and/or thickness measurements in accordance with API 570. Hydrotre
ater Unit-Piping Circuits 1.HT030 Compressed gas HRG to E303 Class II 6"Piping:
Thickness measurements- UT (UT-ultrasonic thickness) inspections were not perfor
med by the required date of June 1, 2010 in accordance with UltraPipe and the RB
I assessment calculated by Calumet. Calumet hasnot performed a visual inspection
of this piping circuit every five years as is required by API 510, Table 6-1. 2
.HT030A Compressed gas HRG to FB-301 Class II 6"Piping: UT inspections were not
performed by the required date of June 1, 2010 in accordance with the RBI assess
ment conducted by Calumet. Calumet has not performed a visual inspection of this
piping circuit every five years as is required by API 510, Table 6-1. 3.HT029 C
ompressed gas RX304 to RX305 Class II 6" Piping: UT inspections were not perform
ed by the required date of June 1, 2010 in accordance with the RBI assessment co
nducted by Calumet. TMLs have not been established for TML points 1, 2, 6, and 7
. Calumet has not performed a visual inspection of this piping circuit every fiv
e years
as is required by API 510, Table 6-1. 4.HT019 RX-305 Bottoms to D-301 Class II 4
" and 6" Piping: UT inspections were not performed by the required date of June
1, 2010 in accordance with the RBI assessment conducted by Calumet. Calumet has
not performed a visual inspection of this piping circuit every five years as is
required by API 510, Table 6-1. 5.HT018 Compressed gas E302 to FB-301 Class II 4
" Piping: UT inspections were not performed by the required date of June 1, 2010
in accordance with the RBI assessment conducted by Calumet. Calumet has not per
formed a visual inspection of this piping circuit every five years as is require
d by API 510, Table 6-1. TML ports are missing on the insulated portion of the p
iping. 6.HT015 D301-D303 Class II 3" Piping: UT inspections were not performed b
y the required date of 6/1/10 in accordance with the RBI assessment conducted by
Calumet. Calumet has not performed a visual inspection of this piping circuit e
very five years as is required by API 510, Table 6-1. 7.HT009 E304- H301 Class I
I 3" Piping: UT inspections were not performed by the required date of June 1, 2
010 in accordance with the
RBI assessment conducted by Calumet. Calumet has not performed a visual inspecti
on of this piping circuit every five years as is required by API 510, Table 6-1.
TML ports are missing on the insulated portion of the piping. 8.HT007A HT-006-E
304C Class II 2" Piping: UT inspections were not performed by the required date
of June 1, 2010 in accordance with the RBI assessment conducted by Calumet. Calu
met has not performed a visual inspection of this piping circuit every five year
s as is required byAPI 510, Table 6-1. 9.HT007 P301A/B-E301D Class II 3" Piping:
UT inspections were not performed by the required date of June 1, 2010 in accor
dance with the RBI assessment conducted by Calumet. Calumet has not performed a
visual inspection of this piping circuit every five years as is required by API
510, Table 6-1. 10.HT004 D301-P-304A/B Class II 3" Piping: UT inspections were n
ot performed by the required date of June 1, 2010 in accordance with the RBI ass
essment conducted by Calumet. Calumet has not performed a visual inspection of t
his piping circuit every five years as is required by API 510, Table 6-1.
11.HT003A P-304A/B Discharge-D304 Class II 3" Piping: UT inspections were not pe
rformed by the required date of June 1, 2010 in accordance with the RBI assessme
nt conducted by Calumet. Calumet has not performed a visual inspection of this p
iping circuit every five years as is required by API 510, Table 6-1. 12.HT002A P
304A/B-E-302A/B Class II 3" Piping: UT inspections were not performed by the req
uired date of 6/1/10 in accordance with the RBI assessment conducted by Calumet.
Calumet has not performed a visual inspection of this piping circuit every five
years as is required by API 510, Table 6-1. Treater Unit Piping 1.T-050 caustic
from D509D-D-509B/C Class II 3/4" Piping: UT inspections were not performed by
the required date of March 10, 2009 in accordance with the UltraPipe assessment
conducted by Calumet. 2.T-051 caustic from D509A-D-509D Class II 2" Piping: UT i
nspections were not performed by the required date of March 10, 2009 in accordan
ce with the UltraPipe assessment conducted by Calumet. 400 Unit Piping
Calumet has not performed a visual inspection of piping circuits 400-01 to 400-3
3 every five years as is required by API 570, Table 6-1. The following piping ci
rcuits were not inspected: 1.400-01; D-210 to Tank 41 Class II Piping 2.400-02;
D-210-Tank 41 Class II 2" Piping 3.400-03; D-210-T-800 Class II 1.5" Piping 4.40
0-04; D-210 from D101/1101 Class II 2" and 3" Piping 5.400-05; D-210 to P204A/B
Class II 2" and 3" Piping 6.400-06; P204A/B Discharge to H-202 Class II 2" Pipin
g 7.400-07; 2"-HL-400-004-1A1A Class II 2" Piping 8.400-08; D-210 Vent to PSV-21
7 Class II 2" and 3" Piping 9.400-09; D-210 Vapors Class II 1" Piping 10.400-10;
T-401 Overhead to E-401 Class II 6" Piping:Calumet has not
performed a visual inspection of this piping circuit every five years as is requ
ired by API 570, Table 6-1. Also, baseline UT data was not collected on an injec
tion point (which was leaking) and UT inspections of injection points on this pi
peline circuit were not collected every three years in accordance with API 570,
Table 6-1. 11.400-11; T-401 Overhead to D-401 Class II 6" Piping 12.400-12; Refl
ux to T-401 Class II 2" and 3" Piping 13.400-13; P401A/B Discharge Class II 1" a
nd 2" Piping 14.400-14; D-401 to P401A/B Suction Class II 3" Piping 15.400-15; E
-401 to D-401 Class II 4" Piping 16.400-16; Makeup Gas to T-401 Class II 1" Pipi
ng 17.400-17; D-401 Vapor to Fuel Drum Class II 2" Piping 18.400-18; T-401 to R4
01SS Class II 6" Piping 19.400-19; R401SS to T-401 Class II 10" Piping
20.400-20; T-401 Outlet to LCV-401 Loop Class II 2" and 3" Piping:Calumet has no
t performed a visual inspection of this piping circuit every five years as is re
quired by API 570, Table 6-1. Also, only eight of twenty TMLs established has UT
data; therefore UT measurements are not collected in accordance with API 570. 2
1.400-21; T-401 Outlet to E-404 TS Class II 4" Piping:Calumet has notperformed a
visual inspection of this piping circuit every five years as is required by API
510, Table 6-1. Also, only six of thirty-eight TMLs established has UT data; th
erefore UT measurements are not collected in accordance with API 570. 22.400-22;
T-401 to E-403A/B/C Class II 3", 4" and 6" Piping:Calumet has not performed a v
isual inspection of this piping circuit every five years as is required by API 5
10, Table 6-1. Also, only one of twenty- five TMLs established has UT data; ther
efore UT measurements are not collected in accordance with API 570. 23.400-23; T
-401 Outlet to E-403A/B/C Class II 3" Piping:Calumet has not performed a visual
inspection of this piping circuit every five years as is required by API 510, Ta
ble 6-1. Also, only two of nineteen TMLs established has UT data; therefore UT m
easurements are not collected
in accordance with API 570. 24.400-24; E-403A/B/C to E-404 Class II 3" Piping:Ca
lumet has not performed a visual inspection of this piping circuit every five ye
ars as is required by API 510, Table 6-1. Also, no UT data has been collected fo
r this circuit; therefore UT measurements are not collected in accordance with A
PI 570. 25.400-25; E-403A/B/C to E-404 Class II 3" Piping:Calumet has not perfor
med a visual inspection of this piping circuit every five years as is required b
y API 510, Table 6-1. Also, only six of twenty-three TMLs established has UT dat
a; therefore UT measurements are not collected in accordance with API 570. 26.40
0-26; E-404 to Inlet/Outlet Class II 3" Piping 27.400-27; E-404 to Inlet/Outlet
Class II 3" Piping 28.400-28; FB-403 Outlet to Manifold Class II 3" Piping 29.40
0-29; FB-403 Outlet to Manifold Class II 3" Piping 30.400-30; FB-403 Outlet to M
anifold Class II 2" Piping
31.400-31; E-204 Bypass to T-401 Class II 3"and "4 Piping 32.400-32; E-204 SS In
/Out Class II 3"and 4" Piping:Calumet has not performed a visual inspection of t
his piping circuit every five years as is required by API 570, Table 6-1. Also,
only six of twenty-eight TMLs established has UT data; therefore UT measurements
are not collected in accordance with API 570.33.400-33; H202 Hot Oil to T-401 C
lass II 4" Piping:Calumet has not performed a visual inspection of this piping c
ircuit every five years as is required by API 570, Table 6-1. Also, no UT data h
as been collected for this circuit; therefore UT measurements are not collected
in accordance with API 570. 100 Unit Piping Calumet has not performed a visual i
nspection of piping circuit C-001 to C- 004; C-007 to C-020; and C-022 to C-040
every five years as is required by API 570, Table 6-1. The following piping circ
uits were not inspected: Some UT inspections conducted provided UT data which wa
s either anomalous or unreliable. These TMLs are then placed in a 5-10 year cycl
e without retesting to determine an accurate reading. Consequently, the data col
lected
for these TML do not meet the frequency of testing requirements in accordance wi
th API 570. 1.C-001 P-101 A/B to E-101A Class II 4" Piping 2.C-001A E-101 A/B to
E-102 Class II 4" Piping 3.C-002 E-101A Shell side to E-101B Shell side Class I
I 12" Piping 4.C-003 T-101 to E-101A/B Class II 12" Piping:Baseline UT data was
not collected on injection points and UT inspections of injection points on this
pipeline circuit were not collected every three years in accordance with API 57
0, Table 6-1. A UT inspection was not performed for TML 6 by the required date o
f 11/16/2005 in accordance with API 570 and the calculated UltraPipe assessment
conducted by Calumet. 5.C-004 H-101 to T-101 Class II 4" and 8" Piping:Calumet h
as not performed a visual inspection of this piping circuit every five years as
is required by API 570, Table 6-1. A UT inspection was not performed for TML 4 b
y the required date of 11/17/2005 in accordance with API 570 and the calculated
UltraPipe assessment conducted by Calumet.
6.C-007 E-102 to T-101/B Class II 2" Piping 7.C-008 T-101C to T-101 Class II 4"
Piping:Calumet has not performed a visual inspection of this piping circuit ever
y five years as is required by API 570, Table 6-1. A UT inspection was not perfo
rmed for TML 4 by the required date of 11/14/2005 in accordance with API 570 and
the calculated UltraPipe assessment conducted by Calumet. 8.C-009 T-101B to T-1
01 Class II 4" Piping:Calumet has not performed a visual inspection of this pipi
ng circuit every five years as is required by API 570, Table 6-1. 9.C-010 T-101A
to T-101 Class II 4" Piping:Calumet has not performed a visual inspection of th
is piping circuit every five years as is required by API 570, Table 6-1. 10.C-01
1 T-101C to E-105 Shell side Class II 2" Piping:Calumet has not performed a visu
al inspection of this piping circuit every five years as is required by API 570,
Table 6-1. 11.C-012 T-101 to T-101C Class II 3" Piping:Calumet has not performe
d a visual inspection of this piping circuit every five years as is required by
API 570, Table 6-1. A UT inspection was not performed for TML
1,7,8 by the required date of 11/14/2005. 12.C-013 T-101 to T-101A Class II 3" P
iping:Calumet has not performed a visual inspection of this piping circuit every
five years as is required by API 570, Table 6-1. A UT inspection was not perfor
med for TML 1, 4, 5 by the required date of 11/14/2005. 13.C-014 T-101 to T-101B
Class II 3" Piping:Calumet has not performed a visual inspection of this piping
circuit every five years as is required by API 570, Table 6-1. A UT inspection
was not performed for TML 1, 2, 3 by the required date of 11/14/2005. 14.C-015 T
-101A to FB-101 Class II 3" Piping 15.C-016 P-101 Discharge to Tank 39 Class II
2" Piping 16.C-017 FB-7 to P-101A Class II 2" Piping 17.C-018 E-102 Shell side t
o FB-7 Class II 2" Piping 18.C-019 FB-101B-1/2 to P-106 Class II 2" Piping:Calum
et has not performed a visual inspection of this piping circuit every five years
as is required by API 570, Table 6-1.
19.C-020 E-105 Shell side to FB-101C Class II 2" Piping:Calumet has not performe
d a visual inspection of this piping circuit every five years as is required by
API 570, Table 6-1. 20.C-022 P-101C Discharge to Tank 39 Class II 2" Piping:Calu
met has not performed a visual inspection of this piping circuit every five year
s as is required by API 570, Table 6-1..21. C-023 Natural Gas to H-101 3"and 4"
Class II 2" Piping 22.C-024 H-101 Heater Inlet from E-707 and E-715 Class II 6"
Piping: Calumet has not performed a visual inspection of this piping circuit eve
ry five years as is required by API 570, Table 6-1. 23.C-025 FB-101C Fin Fan to
D-103 and 29 Tank Class II 2" Piping 24.C-026 P101-B to 39 and 29 Tanks Class II
2" Piping 25.C-027 D-101 and P-104A/B Class II 4" and 6" Piping:Calumet has not
performed a visual inspection of this piping circuit every five years as is req
uired by API 570, Table 6-1. 26.C-028 P-104A/B Discharge Class II 4" Piping:Calu
met has not
performed a visual inspection of this piping circuit every five years as is requ
ired by API 570, Table 6-1. 27.C-029 P-104A/B to T-101 Reflux Class II 4" Piping
28.C-030 E-105 to D-102 Desalter Class II 4" Piping 29.C-031 D-101 to Fuel Gas
Class II 2" Piping:Calumet has not performed a visual inspection of this piping
circuit every five years as is required by API 570, Table 6-1. A UT inspection w
as not performed for TML 1, and 2 by the required date of 11/14/2005. No UT insp
ection has been performed for TML 4, 5, 6, 7 in accordance with API 570. 30.C-03
2 T-101 to P-103 A/B Suction Class II 4" Piping:Calumet has not performed a visu
al inspection of this piping circuit every five years as is required by API 570,
Table 6-1. 31.C-033 P-103 A/B Discharge to D-700 Class II 3" Piping:Calumet has
not performed a visual inspection of this piping circuit every five years as is
required by API 570, Table 6-1. A UT inspection was not performed for TML 1, an
d 2 by the required date of 11/14/2005. 32.C-034 P-103 A/B Discharge Class II 3"
Piping:Calumet has not
performed a visual inspection of this piping circuit every five years as is requ
ired by API 570, Table 6-1. A UT inspection was not performed for TML 3 and 4 by
the required date of 11/14/2005. 34.C-035 FB-101 to D-101 and E-103 Class II 6"
Piping 35.C-036 D-102 to 700 Charge Drum Class II 6" Piping:Calumet has not per
formed a visual inspection of this piping circuit every five years asis required
by API 570, Table 6-1. A UT inspection was not performed for TML 2 by the requi
red date of 11/14/2005 and TML 4 by the required date 1/18/2009. 36.C-037 D-102
to E-102 and E-105 Class II 4" Piping:Calumet has not performed a visual inspect
ion of this piping circuit every five years as is required by API 570, Table 6-1
. A UT inspection was not performed for TML 1 and 3 by the required date of 11/1
4/2005. 37.C-038 E-105 to D-102 Class II 4" Piping:Calumet has not performed a v
isual inspection of this piping circuit every five years as is required by API 5
70, Table 6-1. 38.C-039 Crude Pumparound from SK-37 to SK-37:Calumet has not per
formed a visual inspection of this piping circuit every five years as
is required by API 570, Table 6-1. 39.C-040 E-102 to E-105 Class II 4" Piping 4"
1100 Unit Piping Calumet has not performed a visual inspection of piping circui
t 1100-01 to 1100-26 every five years as is required by API 570, Table 6-1. The
following piping circuits were not inspected: 1.11-001 H-1101 to T-1101 Class II
6" Piping:Calumet has not performed a visual inspection of this piping circuit
every five years as is required by API 510, Table 6-1. Only two of five establis
hed TMLs has UT data; therefore UT measurements have not been collected every 10
years in accordance with API 570 and the Calumet RBI assessment. No baseline UT
data was collected and no corrosion rate for this piping circuit has been estab
lished in accordance with API 570, Section 7.1.2. TML ports are missing on the i
nsulated portion of the piping. 2.11-001A H-1101 Outlet to T-1101 Class II 6" Pi
ping 3.11-002 T-1101 to T-1102 Class II 8" Piping
4.11-003 P-1101 A/B Suction from T-1102 Class II 8" Piping 5.11-004 P-1101 A/B D
ischarge to T-1101 Class II 8" Piping:Calumet has not performed a visual inspect
ion of this piping circuit every five years as is required by API 570, Table 6-1
. Only one of six established TMLs has UT data; therefore UT measurements have n
ot been collected every 10 years in accordance with API 570 and the Calumet RBI
assessment. No baseline UT data was collected and no corrosionrate has been esta
blished for the TMLs not tested in accordance with API 570, Section 7.1.2. TML p
orts are not accurately reflected on the isometric drawing. 6.11-005 T-1102 Over
head to E-1102 Class II 4" and 8" Piping 7.11-006 T-1102 to D-1102 Class II 4" a
nd 8" Piping 8.11-007 Feed to T-1102A from T-1102 Class II 3" Piping 9.11-008 T-
1102A from T-1102 Class II 3" Piping 10.11-009 T-1102A to E-1102 Class II 2" Pip
ing
11.11-011 T-1101 Bottom Outlet Class II 2" Piping 12.11-012 H-1101 Inlet from E-
707 Class II 3" Piping 13.11-013 FB-1101 & E-1101 to D-1101 Class II 4" Piping 1
4.11-014 FB-1101 Outlet to TCV-110A Class II 4" Piping 15.11-015 E-1101 Outlet t
o FB-1101 Class II 4" Piping 16.11-016 D-1101 Relief Class II 2" Piping:Calumet
has not performed a visual inspection of this piping circuit every five years as
is required by API 510, Table 6-1. Only one of two established TMLs has UT data
; therefore UT measurements have not been collected every 10 years in accordance
with API 570 and the Calumet RBI assessment. No baseline UT data was collected
and no corrosion rate has been established for the TMLs not tested in accordance
with API 570, Section 7.1.2. TML ports are not accurately reflected on the isom
etric drawing. 17.11-017 P-1102 A/B Suction Class II 2" and 3"Piping 18.11-018 F
B-1102 Outlet to Storage Class II 2" Piping
19.11-019 FB-1102 Outlet to Storage Class II 2" Piping 20.11-020 D-1101 Outlet t
o Blue Drum 1 Class II 1" Piping 21.11-021 Inlet to E-1101 Class II 4" Piping 22
.11-022 E-1101 Tube Side to E-1102 Class II 4" Piping 23.11-023 E-1102 Inlet Tub
e Side Class II 4" Piping24.11-024 E-1102 to FB-1103 Class II 4" Piping 25.11-02
5 FB-1103 to Storage Class II 2" Piping 26.11-026 H-203 Inlet/Outlet Class II 2"
Piping Relief System Piping Circuits 1.Calumet has not performed a visual inspe
ction or UT inspection of the flare system piping circuits FH-1 to FH-20 as is r
equired by API 570, Table 6-1. Pursuant to 29 CFR 1903.19(d), within 10 days, th
e employer must submit an abatement
plan describing the actions it is taking to ensure that an a visual inspection i
s completed. The violation must be abated no later than 60 days from the receipt
of this citation.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment th
at were outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a)The employer doe
s not correct deficiencies in equipment that are outside acceptable limits (defi
ned by the process safety information in paragraph (d) of this section) before f
urther use or in a safe and timely manner when necessary means are taken to assu
re safe operation. As described in the 2001 Calumet Lubricants Flare Study, cond
ucted by Jacob and Associates LLC, the "Tower T-803 Fin Fan Failure" scenario in
dicated that PSV-809, protecting T-803, set at 90 psig, size 4 x P x 6, would re
lieve at
the rate of 68933 lbs/hr. The current flare system in service onsite is designed
for a maximum flow of 50,695 lbs/hr. As a result, should T-803 experience a fin
fan failure (loss of cooling), the potential relieving flow would overpower the
existing flare. As per P&ID SOL-A- 021A, PSV-809 is currently in service with a
consolidated valve, style 1905PC-2, size 4 x P x 6, serial number TM03316. By n
ot correcting deficiencies in equipment that are outside acceptable limits befor
e further use or in a safe and timely manner, employees are exposed to potential
equipment failures which can result in serious injury or death. This may be a s
ystem-wide occurrence which would require the re-evaluation of all PSV's and fla
re equipment design throughout the facility. This violation was documented on or
about December 20, 2010. b)The employer does not correct deficiencies in equipm
ent that are outside acceptable limits
(defined by the process safety information in paragraph (d) of this section) bef
ore further use or in a safe and timely manner when necessary means are taken to
assure safe operation. As described in the 2001 Calumet Lubricants Flare Study,
conducted by Jacob and Associates LLC, the "Tower T-700 Fin Fan Failure" scenar
io indicated that PSV-702, protecting T-700, set at 115 psig, size 4 x M x 6, wo
uld relieve at the rate of 117753 lbs/hr. The current flare system in service on
site is designed for a maximum flow of 50,695 lbs/hr. As a result, should T-700
experience a fin fan failure (loss of cooling), the potential relieving flow wou
ld overpower the existing flare. As per P&ID 700-A-003, PSV-702 is currently in
service with a consolidated valve, style 1905MT-1, size 4 x M x 6, serial number
TG-58158. By not correcting deficiencies in equipment that are outside acceptab
le limits before further use or in a safe and timely manner, employees are expos
ed to potential equipment failures which can result in serious
injury or death. This may be a system-wide occurrence which would require the re
-evaluation of all PSV's and flare equipment design throughout the facility. Thi
s violation was documented on or about December 20, 2010. c)The employer does no
t correct deficiencies in equipment that are outside acceptable limits (defined
by the process safety information in paragraph (d) of this section) before furth
er use or in a safe and timely manner when necessary means are taken to assure s
afe operation. As described in the 2001 Calumet Lubricants Flare Study, conducte
d by Jacob and Associates LLC, PSV-701 was undersized and not adequate based upo
n the fire case relief scenario. As stated under the "Zone 8" summary, finding 1
, "Relief valve PSV-701 needs to be changed; it is not adequate, the relief valv
e should be changed to a 1.5 x G x 2.5." Calculations in the relief study were b
ased upon the larger"G" orifice size. Without a "G" orifice, per the flare study
,
the valve is too small. In 2008, nearly 7 years after the flare study was comple
ted, the employer responded to the change stating the "valve never installed bec
ause it was determined adequate protection was available with existing valve and
equalization line to T-700." No additional design data or calculations were pro
vided to support keeping the older, smaller valve in service. No adjustment to t
he flare study was made to show a smaller valve orifice was adequate. Field veri
fication of PSV-701 indicated a valve size "1 x E x 5" was currently present on
D-700. By not correcting deficiencies in equipment that are outside acceptable l
imits before further use or in a safe and timely manner, employees are exposed t
o potential equipment failures which can result in serious injury or death. This
may be a system- wide occurrence which would require the re-evaluation of all P
SV's and flare equipment design throughout the facility. This violation was docu
mented on or about December 20,
2010. d)Calumet is not ensuring that employees occupy buildings (containing cont
rol equipment) which are adequately protected (i.e., adequately protected by sep
aration or building construction) thereby exposing them to explosion, fire, toxi
c material, corrosive material, or high pressure hazards resulting from the rele
ase of highly hazardous chemicals from process equipment, in the 100, 400, and 1
100 Units. The building located in an unacceptable blast zone area is the facili
ty control room. The control room is subject to potential overpressures of 14.7
psi. This building also does not comply with current RAGAGEP, such as but not li
mited to API 752. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of t
he date of this citation, the employer must submit documentation showing that it
is in compliance with the standard, including the steps that it is taking to en
sure that employees are not being
exposed to highly hazardous chemicals.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 C.F.R. 1910.119(l)(1) The employer did not establish and implement written pr
ocedures to manage changes (except for "replacements in kind") to process chemic
als,
technology, equipment, and procedures; and, changes to facilities that affect a
covered process: a)The employer does not establish and implement written procedu
res when there are changes in process equipment. Calumet did not establish writt
en procedures to manage change when they operated a pressure vessel T-101 (leaki
ng light hydrocarbons) which had a small hole present at the top of the vessel;
and then continued to operate the pressure vessel with a temporary weld patch. C
rude Tower, T-101 is designed to operate as-built, and any change from the origi
nal design (operating the Tower with a hole and/or operating the tower with a te
mporary patch is a change from original design. Crude Tower, T-101 is designed t
o operate as-built, and any change from the original design (operating the Tower
with a hole and/or operating the tower with a temporary patch is a change from
original design.
The unit was operated with light hydrocarbons being released for at least two da
ys. This exposes employees to fire and explosion hazards. The violation was docu
mented on or about October 28, 2010. b)The employer does not complete MOCs for a
throughput increase and any potential effects the increase might have on the ad
equacy of the current process, including the existing relief system. As provided
by the employer, throughput design changes were made in 2002 for the 1100 Crude
Unit to increase throughput to 3600 Barrels Per Day (BPD). The employer stated
that in place of an MOC, a PHA would be conducted. Review of the 1100 Crude Unit
PHA, dated 4/16/2002, did not identify where throughput was assessed, nor was a
n MOC conducted. Data supporting evidence of evaluation, consultation with the r
efinery's engineering/technical staff, and whether the existing/current engineer
ing analysis of the relief system is adequate
for the new unit throughput is not in the PHA and not in an MOC. A detailed revi
ew of the relief system and associated capacity is critical during any change to
ensure the current system can appropriately function with increased throughput.
This violation was documented on or about December 20, 2010. Pursuant to 29 C.
F. R. 1903.19, within ten (10) calendar days of the abatement date, the employer
must submit documentation that it is in compliance with the standard, including
describing the steps it is taking to ensure MOCs are conducted for all changes
(except for "replacements in kind") to process chemicals, technology, equipment,
and procedures; and, changes to facilities that affect a covered process.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(l)(2)(ii): The written procedures to manage changes did not assu
re that the impact of the change on safety and health was addressed prior to any
change:
a) The employer does not address all potential safety and health impacts of the
change in the MOC procedure prior to the change. Review of MOC #2005-03, to allo
w the hydrotreater throughput to increase to 5100 BPD, does not include the asse
ssment of pressure relief systems. Per the MOC 2005-03 summary sheet, "PSV/Safet
y Systems/Shutdowns" is not checked off on the list and no supporting documentat
ion was provided demonstrating a review. No notes or indications on the MOC form
show that the relief system was assessed and determined to be sufficient with t
he throughput increase. By not fully evaluating all potential safety and health
impacts, the employer was potentially deprived of critical information used to d
etermine if the change is safe. This violation was documented on or about Decemb
er 20, 2010. b) The employer does not address all potential safety and health im
pacts of the change in the MOC procedure prior to the change. Review of MOC #200
2-13, 100/700 Unit feed
train, does not include the assessment of pressure relief systems. Per documents
provided, this MOC was conducted as a result of a throughput increase to 12000
BPD in the 100/700 Unit. Per the MOC 2002-13 summary sheet, "PSV/Safety Systems/
Shutdowns" is not checked off on the list and no supporting documentation was pr
ovided demonstrating a review. No notes or indications on the MOC form show that
the relief system was assessed and determined to be sufficient with the through
put increase. By not fully evaluating all potential safety and health impacts, t
he employer was potentially deprived of critical information used to determine i
f the change is safe. This violation was documented on or about December 20, 201
0. c) The employer does not address all potential safety and health impacts of t
he change in the MOC procedure prior to the change. Review of MOC #2002-49, T-70
0 Diesel Recovery Project, does not include the assessment of pressure relief sy
stems. Per documents provided,
this MOC was conducted as part of a redesign to enable Calumet Cotton Valley to
recover diesel put of the resid bottoms. Per the MOC 2002-49 summary sheet, "PSV
/Safety Systems/Shutdowns" is not checked off on the list and no supporting docu
mentation was provided demonstrating a review. No notes or indications on the MO
C form show that the relief system was assessed and determined to be sufficient
with the throughput increase. By not fully evaluating all potential safety and h
ealth impacts, the employer was potentially deprived of critical information use
d to determine if the change is safe. This violation was documented on or about
December 20, 2010. d) The employer does not address all potential safety and hea
lth impacts of the change in the MOC procedure prior to the change. Review of MO
C #2005-04, Solvents Unit Capacity Increase to 5100 BPD, does not include the as
sessment of pressure relief systems. Per documents provided, this MOC was conduc
ted as part of a redesign to increase throughput in
the Solvents Unit to 5100 BPD. Per the MOC 2005-04 summary sheet, "PSV/Safety Sy
stems/Shutdowns" is not checked off on the list and no supporting documentation
was provided demonstrating a review. No notes or indications on the MOC form sho
w that the relief system was assessed and determined to be sufficient with the t
hroughput increase. By not fully evaluating all potential safety and health impa
cts, the employer was potentially deprived ofcritical information used to determ
ine if the change is safe. This violation was documented on or about December 20
, 2010. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of
this citation, the employer must submit documentation showing that it is in com
pliance with the standard, including the steps that it is taking to ensure that
ensure that management of change documentation is completed and employees are no
t being exposed to highly hazardous chemicals.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(m)(1): The employer did not investigate each incident which
resulted in, or could reasonably have resulted in a catastrophic release of high
ly hazardous chemical in the workplace: The employer does not investigate each i
ncident which could reasonably have resulted in a catastrophic release of a high
ly hazardous chemical in the workplace. Calumet Lubricants did not conduct an in
cident investigation of an incident which occurred on May 4, 2010, involving pre
ssure vessel, T-101 (tower). The tower was shut down due to a hydrocarbon leak,
caused by a small hole in the metal at the top of the vessel. No incident report
was completed for this incident. The materials at the top of the tower included
light hydrocarbons, which are highly flammable; exposing employees to fire and
explosion hazards. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of
the abatement date, the
employer must submit an abatement plan describing the actions it is taking to en
sure that all incidents are investigated.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $5,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(o)(4): The employer did not promptly determine and document an a
ppropriate response to each of the findings of the compliance audit, and documen
t that deficiencies have been corrected: Calumet does not promptly determine and
document an appropriate response to recommendations contained in their complian
ce audits. a.The May 23, 1998; September 28, 1998; August 15, 2005; and December
8, 2008, Compliance Audits include recommendations to address compliance audit
findings in a timely manner. This audit item has not been resolved as some recom
mendations are still not resloved. Recommendations from the compliance audits to
: "develop consequences of deviations and steps to correct for all critical limi
ts and a recommendation to address lockout /tagout procedures that do not meet a
ll
requirements"; have not been addressed or the correction was not documented. b.T
he September 28, 1998, Compliance Audit includes a recommendation to "develop co
nsequences of deviations and steps to correct for all defined critical operating
limits. Calumet has still not listed the consequences of deviation and steps to
correct deviations for all operational parameters. Recommendations from a compl
iance audit indicate the Facility's Process Safety Management program has defici
encies that require correction. These deficiencies can lead to catastrophic even
ts which would expose employees to fire and explosion hazards. Pursuant to 29 CF
R 1903.19, within ten (10) calendar days of the abatement date, the employer mus
t submit an abatement plan describing the actions it is taking to ensure that th
ey promptly determine and document an appropriate response to each of the findin
gs of the
compliance audit, and document that deficiencies have been corrected.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,500 · Current $7,000

General-duty citation text

29 CFR 1910.134(f)(2): The employer failed to ensure that employees using a tigh
t-fitting facepiece respirator were fit tested prior to initial use of the respi
rator, whenever a different respirator facepiece (size, style, model, or make) i
s used, and at least annually thereafter: The employer does not ensure that empl
oyee(s) required to use half-face respirators are fit tested at least annually.
The employer does not reschedule employee(s) who fail their annual fit test. Thi
s violation was documented on or about September 22, 2010. Pursuant to 29 CFR 19
03.19, within ten (10) calendar days of the date of this citation, the employer
must submit documentation showing that it is in compliance with the standard, in
cluding the steps that it is taking to ensure that employees are not being expos
ed to the hazard of inhaling airborne contaminants.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(f)(5): The employer did not ensure that employees using a tight-
fitting facepiece respirator pass a qualitative fit test (QLFT) or a quantitativ
e fit test (QNFT) that meets
the guidelines contained in Appendix A of the standard: The employer does not en
sure employee(s) who are required to use half-face respirators are clean shaven.
Paragraph nine of mandatory Appendix A of the standard prohibits fit tests on t
hose employee(s) with facial hair. The employer allowed four respirator users wi
th facial hair to be fit tested and use respiratory protection in the refinery.
This violation was documented on or about September 22, 2010. Pursuant to 29 CFR
1903.19, within ten (10) calendar days of the date of this citation, the employ
er must submit documentation showing that it is in compliance with the standard,
including the steps that it is taking to ensure that employees are not being ex
posed to the hazard of inhaling airborne contaminants.

Issued

Mar 14, 2011

Abate by

Mar 27, 2011

Penalty

Initial $2,500 · Current $7,000

General-duty citation text

29 CFR 1910.134(h)(3)(i)(B): The employer did not ensure that emergency use resp
irators were inspected at least monthly: Calumet is not inspecting the following
emergency use respirators located in
the control room on a monthly basis: Emergency escape respirators: MSA-1 LT29073
ISI-2 L13509 MSA-3 LT29029 MSA-4 LT29022 MSA-5 LT29021 North-6 LT05169 ISI Prin
ceton L13206 This violation was observed on or about December 6, 2010, when in r
esponse to a request for documents, Calumet Lubricants Co. at Cotton Valley fail
ed to provide written documents that
indicated that monthly inspections of its emergency use respirators were being p
erformed. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date
of this citation, the employer must submit documentation showing that it is in c
ompliance with the standard, including the steps that it is taking to ensure tha
t employees are being protected from respiratory hazards.ory

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(h)(3)(iii): The employer did not ensure that all self-contained
breathing apparatus were inspected monthly with a determination made that the re
gulator and warning device functioned properly: Calumet is not inspecting the se
lf-contained breathing apparatus located in the control room on a monthly basis
to include a check to determine that the regulator and warning devices function
properly. Calumet is not inspecting the Scott Carbon HP-60 (OP43695 and OP43748)
self- contained breathing apparatus with the SKA PAK 2216 (Y212458) escape bott
le on a monthly
basis. This violation was observed on or about December 6, 2010 when in response
to a request for documents Calumet Lubricants-Cotton Valley did not provide wri
tten documents certifying that any such an monthly inspection was being performe
d. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of this
citation, the employer must submit documentation showing that it is in complian
ce with the standard, including the steps that it is taking to ensure that emplo
yees are not being exposed to respiratory hazards.ory

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $2,500 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.146(c)(1): The employer did not evaluate the workplace to determine
if any spaces were permit-required confined spaces: Calumet Lubricants does not
perform an evaluation, location by location, of areas to determine the number an
d location of all confined spaces in the refinery. This violation was documented
on or about September 22, 2010.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of this ci
tation, the employer must submit documentation showing that it is in compliance
with the standard, including the steps that it is taking to ensure that employee
s are not being exposed to the hazards of confined space entry.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(c)(2): The employer did not inform exposed employees, by posting
danger signs or by any other equally effective means, of the existence and loca
tion of and the danger posed by the permit spaces: Calumet Lubricants does not i
nform exposed employees of the existence, location and dangers posed by permit s
paces by posting warning signs at all permit-required confined spaces in the ref
inery or use any other effective means to alert employees to the dangers posed b
y the permit- required spaces. This violation was documented on September 22, 20
10. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of thi
s citation, the
employer must submit documentation showing that it is in compliance with the sta
ndard, including the steps that it is taking to ensure that employees are not be
ing exposed to the hazards of confined space.ed

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.146(k)(1)(i): The employer did not correctly evaluate a prospective
rescuer's ability to respond in a timely manner, considering the hazard(s) ident
ified: The employer does not ensure that designated rescue personnel can respond
in a timely manner. Rescue personnel are not required to remain on site the ent
ire time confined space entry operations are in progress. Rescue personnel also
are not required to have emergency breathing air and/or retrieval devices set up
during entry of permit-required confined spaces. This violation was documented
on or about September 22, 2010. Pursuant to 29 CFR 1903.19, within ten (10) cale
ndar days of the date of this citation, the employer must submit documentation s
howing that it is in compliance with the standard, including the steps that it i
s taking to ensure that employees are not being
exposed to the hazards of confined space entry.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(k)(3)(i): Each authorized entrant did not use a chest or full bo
dy harness, with a retrieval line attached at the center of the entrant's back n
ear shoulder level, or above the entrant's head: The employer does not ensure ad
equate retrieval systems are used in the refinery to facilitate non-entry rescue
. The employer does not enforce the use of safety harnesses with attached retrie
val line on all entrants to permit-required confined spaces. This violation was
documented on or about September 22, 2010. Pursuant to 29 CFR 1903.19, within te
n (10) calendar days of the date of this citation, the employer must submit docu
mentation showing that it is in compliance with the standard, including the step
s that it is taking to ensure that employees are not being exposed to the hazard
s of confined space entry.

Issued

Mar 14, 2011

Abate by

Mar 27, 2011

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.147(c)(5)(i): Locks, tags, chains, wedges, key blocks, adapter pins,
self-locking
fasteners, or other hardware were not provided by the employer for isolating, se
curing, or blocking of machines or equipment from energy sources: The employer d
oes not ensure that all authorized employees are provided with lockout devices w
hen isolating refinery equipment from potential energy sources. Contract mainten
ance workers are not issued individual locks. These maintenance workers regularl
y perform servicing and maintenance of locked out refinery equipment. This viola
tion was documented on September 17, 2010. Pursuant to 29 CFR 1903.19, within te
n (10) calendar days of the date of this citation, the employer must submit docu
mentation showing that it is in compliance with the standard, including the step
s that it is taking to ensure that employees are not being exposed to potential
sources of hazardous energy.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.147(c)(6)(i): The employer did not conduct a periodic inspection of
the energy control procedure at least annually to ensure that the procedure and
the requirement of this standard were being followed: The employer does not ensu
re that periodic inspections of each energy control procedure are conducted at l
east annually by an authorized employee. The refinery contains numerous vessels
and pieces of equipment, all with different specific energy control procedures,
that require a separate periodic inspection. The periodic inspections were not c
onducted annually by an authorized employee to ensure that the procedure and the
requirements of the standard are being followed. This violation was documented
on September 22, 2010. Pursuant to 29 CFR 1903.19, within ten (10) calendar days
of the date of this
citation, the employer must submit documentation showing that it is in complianc
e with the standard, including the steps that it is taking to ensure that employ
ees are not being exposed to potential sources of hazardous energy.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.147(c)(7)(i): Employee training did not include all of the elements
listed under items (a) through (c) of this section: The employer does not ensure
that the same level of training is provided to all authorized employees perform
ing servicing or maintenance of machines or equipment. Contract maintenance empl
oyees who perform servicing or maintenance of machines or equipment do not recei
ve training in energy control procedures. This violation was documented on or ab
out September 17, 2010. Pursuant to 29 CFR 1903.19, within ten (10) calendar day
s of the date of this citation, the employer must submit documentation showing t
hat it is in compliance with the standard,
including the steps that it is taking to ensure that employees are not being exp
osed to potential sources of hazardous energy.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.147(f)(3)(i): A procedure was not utilized to afford the employees a
level of protection equivalent to that provided by the implementation of a pers
onal lockout
or tagout device when servicing and/or maintenance was performed by a crew, craf
t, department, or other group: The employer does not ensure that there is a proc
edure in place that affords an equal level of protection for all members of a cr
ew, craft, department or other group when performing servicing or maintenance of
machines or equipment. Regular maintenance employees (maintenance A) routinely
perform servicing and maintenance of locked out refinery equipment under one loc
k. When a lockout is performed involving more than one maintenance A employee, c
ontract maintenance employee and/or outside contractor employee only a single ma
intenance lock is used to protect them from the unexpected energization or start
up of the machinery or equipment. This violation was documented on or about Sep
tember 22, 2010. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of th
e date of this
citation, the employer must submit documemtation showing that it is in complianc
e with the standard, including the steps that it is taking to ensure that employ
ees are not being exposed to potential sources of hazardous energy.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(f)(4): During shift or personnel changes, specific procedures we
re not utilized to ensure the continuity of lockout or tagout protection, includ
ing a provision for the orderly transfer of lockout or tagout devices between of
f-going and oncoming employees, to minimize exposure to hazards from the unexpec
ted energization, or start-up of the machine or equipment, or the release of sto
red energy: The employer does not ensure that there are adequate written procedu
res in place for shift or personnel changes while lockout operations are being p
erformed. No provision is made for the orderly transfer of lockout protection be
tween off-going and oncoming employees or for employees leaving the refinery whi
le lockout operations are in progress. No provision is made
for oncoming employees to verify that machinery or equipment has been effectivel
y de- energized. This violation was documented on or about September 22, 2010. P
ursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of this cit
ation, the employer must submit documentation showing that it is in compliance w
ith the standard, including the steps that it is taking to ensure that emplouees
are not being exposed to potential sources of hazardous energy.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.179(j)(2)(iv): Monthly inspections of hoist chains, with signed repo
rts, were not performed: a) The employer does not ensure that crane hoist chains
are inspected on a monthly basis. A five-ton overhead crane in the maintenance
shop was used to move large pieces and/or equipment to work on. This violation w
as documented on September 20, 2010. b) The employer does not ensure that crane
hoist chains are inspected on a monthly basis. A one ton Duff Lynx overhead cran
e in the pump shop was used to position pumps
being repaired. This violation was documented on or about September 20, 2010. c)
The employer does not ensure that crane hoist chains are inspected on a monthly
basis. A one ton Dayton overhead crane in the outside storage area was used to
move stored materials. This violation was documented on or about September 20, 2
010 in the maintenance yard. Pursuant to 29 C.F.R. 1903.19, within ten (10) cale
ndar days of the date of this citation, the employer must submit documentation s
howing that it is in compliance with the standard, including the steps that it i
s taking to ensure that employees are not being exposed to struck-by hazards whi
le operating the overhead crane.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.212(a)(5): Fan blades, where the periphery of the blades was less th
an seven feet above the floor or working level, were unguarded or had guards wit
h openings larger than one- half inch: The employer does not ensure that the wal
l ventilation fan has a guard over the fan blades. The fan was approximately 3 f
oot by 3 foot and 5 feet off the floor at the bottom edge of the fan. The fan wa
s totally unguarded inside the building and from the outside the fan blades are
protected by a metal mesh with openings ranging from 2 inches by 6 inches to 4 i
nches by 6 inches. This violation was observed on or about September 20, 2010 on
the south wall of the maintenance shop.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this
citation, the employer must submit documentation showing that it is in complian
ce with the standard, including the steps that it is taking to ensure that emplo
yees are not exposed to the hazard of being struck by unguarded fan blades.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.219(d)(1): Pulley(s) with part(s) seven feet or less from the floor
or work platform were not guarded in accordance with the requirements specified
at 29 CFR 1910.219(m) & (o): The employer does not ensure employees are protecte
d from contact with unguarded pulleys. The unguarded pulley was on a motor power
ing a wall-mounted ventilation fan. Employee(s) were exposed to a caught-between
hazard. This violation was observed on or about September 20, 2010. Pursuant to
29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation,
the employer must submit documentation showing that it is in compliance with the
standard, including the steps that it is taking to ensure that employees are not
being exposed to unguarded pulleys.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.219(e)(3)(i): Vertical belt(s) were not enclosed by guard(s) conform
ing to the requirements specified in 29 CFR 1910.219(m) and (o): The employer do
es not ensure that employees are protected from contact with unguarded belts. Th
e unguarded belt was on a motor powering a wall-mounted ventilation fan. This co
ndition exposed employees to a caught-between hazard. This violation was observe
d on or about September 20, 2010. Pursuant to 29 C.F.R. 1903.19, within ten (10)
calendar days of the date of this citation, the employer must submit documentat
ion showing that it is in compliance with the standard, including the steps that
it is taking to ensure that employees are not being exposed to unguarded belts.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.219(b)(1): Flywheel(s) with parts seven feet or less above floor(s)
or platform(s) were not guarded in accordance with the requirements specified in
29 CFR 1910.219(b)(1)(i) through (b)(1)(iv): The employer does not ensure that
employees are protected from an inadequately
guarded flywheel. An Ingersol Rand backup recycle compressor (C-301), located on
the west side of the hydrotreater, had a 3" X 13" opening on the inside portion
of the expanded metal guard. This condition exposed employee to the hazard of c
oming in contact with rotating parts. This violation was observed on or about Se
ptember 20, 2010. Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days o
f the date of this citation, the employer must submit documentation showing that
it is in compliance with the standard, including the steps that it is taking to
ensure that employees are not being exposed to the hazards associated with rota
ting parts.ng

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,500 · Current $1,500

General-duty citation text

29 CFR 1910.242(b): Compressed air used for cleaning purposes was not reduced
to less than 30 p.s.i.: The employer does not ensure that compressed air used fo
r cleaning purposes has been reduced to less than 30 psi. An air nozzle rated at
140 psi was used to clean off stock when the drill press is in operation. Emplo
yee(s) were exposed to the hazard of having metal shavings blown into their eyes
. This violation was observed on or about September 20, 2010 on the north side o
f the maintenance shop. Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar
days of the date of this citation, the employer must submit documentation showin
g that it is in compliance with the standard, including the steps that it is tak
ing to ensure that compressed air is not used for cleaning purposes unless reduc
ed to less than 30 p.s.i. and then only with effective chip guarding and persona
l protective equipment.

Issued

Mar 14, 2011

Abate by

Apr 28, 2011

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.1001(j)(2)(i): The employer did not determine the presence, location
, and quantity of ACM and/or PACM at the work site: Calumet has not completed an
asbestos survey to identify the presence, location and quantity of all asbestos
-containing materials.
The employer violated this standard on or about September 14, 2010 when in respo
nse to a request for documents Calumet failed to provide an asbestos survey of t
he facility. No written records were provided indicating what insulating and bui
lding materials contain asbestos, the percentage of asbestos present, the locati
on of these materials, and the quantity of asbestos-containing materials. Pursua
nt to 29 CFR 1903.19, within ten (10) calendar days of the date of this citation
, the employer must submit documentation showing that it is in compliance with t
he standard, including the steps that it is taking to ensure that employees are
not being exposed to airborne asbestos fibers.

Issued

Mar 14, 2011

Abate by

Apr 28, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1001(j)(4)(i): The employer does not affix warning labels to all raw
materials, mixtures, scrap, waste, debris, and other products containing asbest
os fibers, or to their containers. When a building owner or employer identifies
previously installed ACM and/or
PACM, labels or signs shall be affixed or posted so that employees will be notif
ied of what materials contain ACM and/or PACM. Calumet Lubricants has not attach
ed warning labels to thermal system insulation on all piping and vessels. Some p
ressure vessels have been attached labels, but other pressure vessels and piping
are not labeled. The employer violated this standard on or about September 14,
2010 at Calumet Lubricants-Cotton Valley where piping insulated with asbestos wa
s not labeled. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the
date of this citation, the employer must submit documentation showing that it is
in compliance with the standard, including the steps that it is taking to ensur
e that employees are not being exposed to airborne asbestos fibers.

Issued

Mar 14, 2011

Abate by

Apr 28, 2011

Penalty

Initial $1,500 · Current $1,500

General-duty citation text

29 CFR 1910.1028(e)(3)(iv): Monitoring for the STEL was not repeated as necessar
y
to evaluate exposures of employees subject to short term exposures: The employer
does not conduct benzene STEL sampling during refinery operations where tanks a
re opened, filled, unloaded or gauged or where process equipment is opened. Main
tenance employees break pipelines, fix valve and flange leaks, respond to proces
s spills, and enter confined spaces without benzene sampling being conducted. Th
e employer violated this standard on or about September 14, 2010, at Calumet Lub
ricants Co., located in Cotton Valley, Louisiana. Upon request, the employer fai
led to provide documents indicating the existence of a comprehensive benzene mon
itoring program for employees performing maintenance activities. Pursuant to 29
CFR 1903.19, within ten (10) calendar days of the date of this citation, the emp
lyer must submit documentation showing that it is in compliance with the standar
d, including
the steps that it is taking to ensure that employees receive appropriate benzene
monitoring.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(f)(5)(i): The employer did not ensure that each container
of hazardous chemicals in the workplace was labeled, tagged or marked with the i
dentity of the hazardous chemical(s) contained therein: a) The employer does not
ensure that containers of hazardous chemicals are labeled with the contents. An
unlableld parts washer in the pump shop contains a cleaning solvent. This viola
tion was observed on or about September 20, 2010. b) The employer does not ensur
e that containers of hazardous chemicals are clearly labeled as to content. Four
55 gallon drums in the old warehouse were not clearly labeled. Two of the drums
were upside down and on one drum the contents were handwritten. This violation
was observed on or about September 20, 2010. Pursuant to 29 C.F.R. 1903.19, with
in ten (10) calendar days of the date of this citation, the employer must submit
documentation showing that it is in compliance with the standard,
including the steps that it is taking to ensure that employees are not being exp
osed to hazardous chemicals.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(g)(2)(iii): Each material safety data sheet did not contain the
physical hazards of the hazardous chemical, including the potential for fire, e
xplosion, and reactivity: The employer violated this standard on or about Decemb
er 3, 2010 when it was noted that the Calumet MSDS for Product Hydrogen includes
conflicting and incorrect flammability information. The writing says "Explosion
Hazard. Highly Flammable Gas," but the NFPA diamond graphic has a zero in the f
ire hazard block. This exposes employees to fire and explosion hazards. Pursuant
to 29 CFR 1903.19(d), within 10 days of the abatement date, the employer must s
ubmit an abatement plan describing the actions it is taking to ensure that the M
aterial Safety Data Sheets accurately indicate the hazards of the chemical they
reference.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,000 · Current $1,000

General-duty citation text

29 CFR 1904.29(b)(1): A Log of recordable work-related injuries and illnesses (O
SHA Form 300 or equivalent), was not completed in the detail as required by the
regulation: At Calumet Lubricants Co., Cotton Valley, LA; On or about September
22, 2010, the Log of Work-Related Injuries and Illnesses (OSHA Form 300 or equiv
alent) was not completed as required by the regulation. a)Section B: "Employee's
Name" was not filled out for the only two entries on the OSHA 300 Log for the y
ear 2009.
b)Section E: "Where the event occurred" was not filled out for one entry and was
not completely in detail for the second entry on the OSHA 300 Log for the year
2009. This violation was documented on or about September 22, 2010. Pursuant to
29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation, t
he employer must submit documentation showing that it is in compliance with the
standard, including the steps that it is taking to ensure employee injuries are
properly recorded on the OSHA 300 Injury and Illness Log.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,000 · Current $1,000

General-duty citation text

29 CFR 1904.32(b)(3): The Summary of Work-Related Injuries and Illnesses (OSHA F
orm 300A or equivalent) was not properly certified: At Calumet Lubricants Co., C
otton Valley, LA; On or about September 22, 2010, the Summary of Work-Related In
juries and Illnesses (OSHA Form 300A) for the year 2009 was not signed and prope
rly certified as being true, accurate and complete by a company executive.
This violation was documented on or about September 22,2010. Pursuant to 29 C.F.
R. 1903.19, within ten (10) calendar days of the date of this citation, the empl
oyer must submit documentation showing that it is in compliance with the standar
d, including the steps that it is taking to ensure that OSHA forms are properly
completed and certified.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.106(g)(8): Conspicuous and legible signs prohibiting smoking were no
t posted within sight or customer service area(s): a) The employer does not ensu
re that "no smoking" signs are posted in the diesel refueling area. This violati
on was observed on or about 9-20-2010 in the maintenance yard where employees re
fuel vehicles and equipment from a 500 gallon diesel tank. b) The employer does
not ensure that "no smoking" signs are posted in the diesel refueling area.
This violation was observed on or about 9-21-2010 west of the warehouse where em
ployees refuel vehicles and equipment from a 2500 gallon diesel tank. Pursuant t
o 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation,
the employer must submit documentation showing that it is in compliance with th
e standard, including the steps that it is taking to ensure that employees are n
ot being exposed to the hazards of fire.ds

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.157(e)(2): Portable fire extinguishers were not visually inspected a
t least monthly: The employer violated this on or about September 27, 2010 when
a fire extinguisher outside the main entrance to the Administration Building was
observed to have not been inspected since the month of July. This exposed emplo
yees to fire and explosion hazards. Pursuant to 29 CFR 1903.19, within ten (10)
calendar days of the abatement date, the employer must submit documentation show
ing that it has completed monthly fire extinguisher inspections
for all fire extinguishers on its property.hers

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.157(e)(3): The employer did not assure that portable fire extinguish
ers are subjected to an annual maintenance check. The employer violated this on
or about January 12, 2011 when a fire extinguisher in the hall of the conference
room area upstairs in the Administration Building was observed to have not been
inspected since November of 2009. This exposed employees to fire and explosion
hazards. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the abatem
ent date, the employer must submit documentation showing that it has completed a
nnual maintenance checks for all fire extinguishers on its property.hers

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,000 · Current $1,000

General-duty citation text

29 CFR 1910.212(a)(1): One or more methods of machine guarding were not provided
to protect operator(s) and other employees from the hazard(s) created by point
of operation and/or rotating parts: The employer does not provide a guard over t
he rotating chuck of a Clausing
Colchester 17" metal lathe. The lathe is used on metal piping. This violation wa
s observed on or about September 20, 2010 on the north wall of the maintenance s
hop. Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of
this citation, the employer must submit documentation showing that it is in com
pliance with the standard, including steps that it is taking to ensure that empl
oyees are not being exposed to the hazard of being struck by caught by rotating
parts.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,000 · Current $1,000

General-duty citation text

29 CFR 1910.212(a)(3)(ii): The point of operation of machines whose operation ex
poses employees to injury, was not guarded. a) The employer does not provide a g
uard over the rotating drill bit of an Allen-Bradley (A-B) drill press, model no
. 6790-3, serial no. 33414. The drill press was used to cut holes in metal stock
. This violation was observed on or about September 20, 2010 on the north side o
f the maintenance shop.
b) The employer does not provide a guard over the rotating drill bit of a Wilton
drill press. The drill press was used to drill holes in metal plates. This viol
ation was observed on or about September 20, 2010 on the north wall of the pump
shop. Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date o
f this citation, the employer must submit documentation showing that it is in co
mpliance with the standard, including steps that it is taking to ensure that emp
loyees are not being exposed to point of operation hazards.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.215(a)(4): Work rest(s) on grinding machinery were not adjusted clos
ely to the wheel with a maximum opening of one eighth inch: The employer does no
t ensure employees are protected from an inadequately guarded grinder. A Baldor
3HP pedestal grinder, serial no. 375, had a work rest that was one inch from the
abrasive wheel. The grinder waOOOOOOOOVs used to remove rough edges from cut me
tal and angle iron. This violation was observed on or about September 20, 2010
on the east wall of the maintenance shop. Pursuant to 29 C.F.R. 1903.19, within
ten (10) calendar days of the date of this citation, the employer must submit do
cumentation showing that it is in compliance with the standard, including the st
eps that it is taking to ensure that employees are not being exposed to struck-b
y hazards.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.215(b)(9): The distance between the abrasive wheel periphery(s) and
the adjustable tongue or the end of the safety guard peripheral member at the to
p exceeded one fourth inch: The employer does not ensure employees are protected
from an inadequately guarded grinder. A Baldor 3HP pedestal grinder, serial no.
375, had a tongue guard that was 1 1/4 inch from the abrasive wheel. The grinde
r was used to remove rough edges from cut metal and/or angle iron. This violatio
n was observed on or about September 20, 2010 on the east wall of the maintenanc
e
shop. Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date o
f this citation, the employer must submit documentation showing that it is in co
mpliance with the standard, including the steps that it is taking to ensure that
employees are not being exposed to struck-by hazards.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,000 · Current $1,000

General-duty citation text

29 CFR 1910.303(b)(2): Listed or labeled electrical equipment was not used or in
stalled in accordance with instructions included in the listing or labeling: The
employer does not ensure listed or labeled electrical equipment is used in acco
rdance with manufacturer's instructions. A Surge Master power strip was permanen
tly attached to a metal work table as a power source for work tools. This violat
ion was observed on or about September 20, 2010 in the maintenance shop. Pursuan
t to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citati
on, the employer must submit documentation showing that it is in compliance with
the
standard, including the steps that it is taking to ensure that employees are not
being exposed to electrical hazards.al

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,000 · Current $1,000

General-duty citation text

29 CFR 1910.304(g)(5): The path to ground from circuits, equipment, and enclosur
es was not permanent and continuous: a) The employer does not ensure adequate pa
th to ground for electrical equipment. A ground prong was missing from a 30 inch
pedestal fan. This violation was observed on or about September 22, 2010 in the
maintenance shop. b) The employer does not ensure adequate path to ground for e
lectrical equipment. A ground prong was missing from a 4 foot by 4 foot portable
box fan. This violation was observed on or about September 22, 2010 in the main
tenance shop. Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of th
e date of this citation, the employer must submit documentation showing that it
is in compliance with the standard,
including the steps that it is taking to ensure that employees are not being exp
osed to electrical hazards.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,000 · Current $1,000

General-duty citation text

29 CFR 1910.305(b)(1)(ii): Unused openings in boxes, cabinets, or fittings were
not effectively closed: The employer does not ensure electrical fittings are eff
ectively closed. An electrical fitting for a 480 volt transformer had an opening
approximately 2 inches by 4 inches, exposing the inner conductors. This violati
on was observed on or about September 21, 2010 on the north side of the laborato
ry building. Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the
date of this citation, the employer must submit documentation showing that it i
s in compliance with the standard, including the steps that it is taking to ensu
re that employees are not being exposed to electrical hazards.

Issued

Mar 14, 2011

Abate by

Mar 31, 2011

Penalty

Initial $1,000 · Current $1,000

General-duty citation text

29 CFR 1910.305(b)(2)(i): In completed installations, each outlet box shall have
a cover, faceplate, or fixture canopy identified for the purpose.
a) The employer does not ensure electrical outlets have cover plates. An uncover
ed 110 volt duplex outlet was attached to a metal work table as a power source f
or work tools. This violation was observed on or about September 20, 2010 in the
maintenance shop. b) The employer does not ensure electrical junction boxes hav
e cover plates. An uncovered 110 volt junction box was attached to the north wal
l of the insulation shop adjacent to the air conditioner. This violation was obs
erved on or about September 20, 2010. c) The employer does not ensure electrical
outlets have cover plates. An uncovered 220 volt duplex outlet was used to powe
r the wall mounted air conditioner. This violation was observed on or about Sept
ember 21, 2010 on the north wall of the instrument shop. Pursuant to 29 C.F.R. 1
903.19, within ten (10) calendar days of the date of this citation, the employer
must submit documentation showing that it is in compliance with the
standard, including steps that it is taking to ensure that employees are not bei
ng exposed to electrical hazards.