2013 California State Emphasis Program
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During a 4 Crude Unit
meeting with regulators
Chevron personnel
admitted they were
“thinking about” clamping
the leak.
So the question was asked,
“How many of these leak
seals do you have?”
“We’ve done about 2,000 in
last ten years”.
Refinery Regulators
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No, seriously; About 2,000
in the last ten years.
Are They legal?
No, Not Online Lawyers…
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Yes they are…and if used as a temporary
repair they can be quite safe.
 To
ensure California Refineries are
following Good Engineering
Practices when it comes to sealing
leaks in process piping.
Title 8: Section 6845 (a)……the
testing, inspection, and repair of all
piping systems shall comply with …
and API 570, Piping Inspection Code,
Second Edition, October 1998,
Addendum 3, August 2003; and
ASME B31.3-2002, Process Piping;
herein incorporated by reference.
“During turnaround or other
appropriate opportunities, temporary
leak sealing and leak dissipating
devices, including valves, shall be
removed and appropriate actions
taken to restore the original integrity
of the piping system.“
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All 15 Refineries in California will be
inspected
Review “Leaking Pipe” databases (if available)
Search database narrow field of inspection;
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high temperature (>600 deg)
Priority: high or emergency
Liquid in pipe that would burn or is toxic.
Not steam, not condensate. (water)
(*exception: control on a process?)
Select targets
Request specific dates of last turnarounds
 Clamps
(flange, valve)
 Pipe wraps
 Wire wraps
 Crimps
 Injection fittings
All are “non-welding” repairs
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A Wilmington Refinery
◦ Based on site visits to this location 37 different
Temporary Non-welding Repairs also known as leak
seals, clamps, TLRs, etc. were visually observed.
This employer has an effective MOC and
Turnaround repair program for temporary nonwelding repairs as of the date of our visits.
◦ No temporary non-welding repairs in place after
their MOC expired.
◦ No temporary non-welding repairs left in place
after the last turnaround in their respective units.
◦ One violation of 8 CCR 5189 was issued, but this
was for a recordkeeping violation regarding a
missing date in management of change documents.
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Same Wilmington Refinery
◦ The employer has a robust sulfidation corrosion
prevention program in place before our visit and
before the Chevron Richmond incident.
◦ Stop Work Authority
 Their head operators have the authority to shut a unit
down. The incident commander has the authority to
shut down. They have shut units down before and this
is confirmed in their incident investigation reports over
the last 5 years.
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A Carson Refinery
Temporary non welding repairs installed,
monitored and replaced by next turnaround
and before their MOC time periods run out;
Sulfidation corrosion prevention program
Actively looking for excess corrosion in areas of
crude distillate over 500 degrees F, and
identifying and removing A56 carbon steel and
replacing it with higher corrosion resistant
chromium alloyed steels.
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A Carson Refinery
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Stop Work Authority
continued…
◦ Head operators have the authority to
independently order shut down of a unit and have
done so in the past per a review of previous
incident reports.
◦ No violations observed concerning TLR’s.
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Some of the Other Refineries in
California
◦ Most temporary repairs were gone (86%)
◦ Some still there and awaiting first turnaround, i.e.
still under MOC
◦ Some still in place passed TA, awaiting next TA,
still under MOC
◦ Some were past life stated in the MOC
◦ Some given MOC of ten years.
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Title 8 §6845(a) citations:
◦ 9 leak seals past TA date (6 of these injection
fittings)
◦ Left in place 11 to 30 months past last TA
◦ Some in place 5 to 7 years past MOC replacement
date.
MOC Violations
◦ 3 repairs beyond own MOC dates
◦ One MOC given 8 years even though in the MOC
said maximum 5 years.
 OK,
Wake up… First question to
the group. Yes, it’s a PSM
Question…
If I have a carbon steel pipe with a leak in it and I use a
carbon steel patch to stop the leak, do I need to conduct
a management of change i.e. MOC?
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Answer number one…
◦ Since the patch is made of carbon steel and the
leaking pipe is made of carbon steel then they are
“like in kind” as defined in 5189(l) – Management of
Change or…
Answer number two…
o Since the integrity of the pipe may be compromised
an MOC should be initiated to review inspection and
testing data of leaking pipe, consider conducting a
PHA to determine consequences of actions, and
conduct a review operating procedures.
 AND THE ANSWER IS…Number 2
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At one small, not in the area refinery, the
compliance officers found 15 sections of pipe
with welded patches on them…
And NO paperwork to justify the safe use of
carbon steel patches.
◦ By no paperwork we mean no MOC, no inspection
or testing results, no PHA’s, no nothing…
Would that scare you if you worked at the
refinery?
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But we’re not done yet…
◦ Other deficiencies noted…
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Confined Space
Energy Control
Emergency Eyewash and Safety Shower
Machine Guarding
Respiratory Protection
Emergency Response (or lack thereof)
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I Don’t Know, What Do You Think?
ME? I think Refineries in
California…except one…So Far…Are
Doing a Really Good Job.
Questions???