OSHA Inspection: VALERO REFINING - TEXAS LP

Issued

Oct 2, 2018

Abate by

Nov 20, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(ii): Inspection and testing procedures did not follow recognized and generally accepted good engineering practices (RAGAGEP).   Instance a) On or about April 19, 2018 in the HF Alkylation at Valero Refinery located in Texas City, Texas, the employer did not follow its chosen RAGAGEP when it failed to perform a Fitness for Service assessment on the Main Fractionator piping (10"-PF1003-BCA) to determine if the piping could continue service or whether it needed to be replaced after inspections revealed that 090NE and 080NE CML's would reach their alert thicknesses by 2017. API 570 (2016), Section 7.7 requires employers to evaluate pressure containing parts (e.g. piping) for continued service or removal that are found to be degraded (e.g. corroded and/or thinning piping).  Additionally, API 574 (2016), Section 12.1.5 indicates that a remaining life assessment (e.g., Fitness-for-service evaluation) is needed when alert thicknesses have been reached.  Instance b) On or about April 19, 2018 in the HF Alkylation Unit at Valero Refinery located in Texas City, Texas, the employer did not follow its chosen RAGAGEP (API 570 and 574) when it failed to establish more than one CML which would have allowed for appropriate monitoring in the form of additional thickness measurements on the Main Fractionator 120 feet vertical straight run piping (10"-PF1003-BCA). The upstream and downstream piping to piping section, 10"-PF1003-BCA were replaced in 1995 due to corrosion. API 570 (2016), Section 5.6.2 requires that piping systems shall be monitored at appropriately placed CMLs and also states that piping circuits subject to higher corrosion rates or localized corrosion (e.g., piping section 10"-PF1003-BCA) will normally have more CMLs and be monitored more frequently. API 574 (2016) Section 7.4 indicates if an inspection of an area of piping indicates damage is occurring, the piping upstream and downstream of this area, along with associated equipment, should also be inspected.

Issued

Oct 2, 2018

Abate by

Nov 20, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits before further use.  This violation was most recently observed on or about April 19, 2018 in the HF Alkylation Unit at Valero Refinery located in Texas City, Texas when the employer did not correct deficiencies in equipment that were outside acceptable limits before further use when the Main Fractionator A-89 Feed piping (10"-PF1003-BCA) ruptured due to severe thinning on the metal wall thickness.