Respondent owned and operated the petroleum refining facility which produces, processes, stores, or handles more than the threshold quantities of flammable substances. Respondent’s hydrocracker unit (HCU) is a covered process under Program 3 of the RMP regulations.
On April 10, 2020, there was an incident at the facility. One of the facility’s covered processes was in operation when an operator determined that a Pressure Safety Valve (PSV) was not seated properly. After discussions with the control room and the arrival of a senior operator, the facility undertook a procedure to reseat the PSV. The procedure indicated that the pressure UPSTREAM of the PSV should be abated by closing an UPSTREAM valve. The PSV could then be reseated.
However…