Text For Citation: 01 Item/Group: 012 Hazard: REFINERY

29 CFR 1910.119(l)(1): The employer did not establish and implement written proc edures to manage changes to process chemicals, technology, equipment, and proced ures; and, changes to facilities that affect a covered process: a.BP-Husky Refin ing, LLC - Oregon, Ohio: On or about September 10, 2009, the employer failed to ensure the management of change (MOC) procedure was implemented for changes or a dditions made to operating procedures and alarm set points on the DCS. The emplo yer permitted a project to take place outside of the MOC procedure in which appr oximately 47 changes or additions were made to operating procedures and 58 chang es or additions were made to alarm set points in multiple units across the refin ery, including the FCC and Alky Units. b.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer failed to ensure the established management of change (MOC) procedure h ad been conducted for changes to tube bundle metallurgy in the Vacuum Bottoms/Na ptha exchanger (PR-543676) in the Crude Vac 1 Unit. The metallurgy was changed t o 9-Cr and 5-Cr in January 1996; it was changed again to all 9-Cr tubes and carb on steel tube sheets in October 1998. c.BP-Husky Refining, LLC - Oregon, Ohio: O n or about September 10, 2009, the employer failed to ensure the management of c hange (MOC) procedure was implemented for changes made to the naphtha treater fu rnace, crude 1 furnace and the crude vac furnace fuel gas and pilot gas lines. T he furnaces' fuel and pilot gas lines were changed from 304 stainless steel to 3 16L stainless steel. d.BP-Husky Refining, LLC - Oregon, Ohio: On or about Octobe r 4, 2009, the employer did not conduct an MOC when replacing approximately 130 feet of 12 and 18 inch flare piping STD A106 Grade B with XS A106 Grade B carbon steel piping in piping circuits 13000 and 13010 in the Alky 1 unit. e.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 29, 2009, the employer did not conduct an MOC when continuing operations after a second leak was discovered on the flare line in th e Alky 1 unit and no temporary repair was made. f.BP-Husky Refining, LLC - Orego n, Ohio: The employer did not conduct an MOC when changing the maximum inspectio n interval for piping circuits from the TML level to the circuit level which per mitted some TML's to become overdue. g.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer failed to ensure the management of ch ange (MOC) procedure was followed for the decommissioning of the Steam Separator (PR11069). In accordance with 29 CFR 1903.19(d), abatement certification is required for th is violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in ad dition, documentation demonstrating that abatement is complete must be included with your certification. This documentation may include, but is not limited to, evidence of the purchaseor repair of the equipment, photographic or video eviden ce of abatement, or other written records.t,