The CSB found that the Richmond refinery’s turnaround planning group rejected the
recommendations to 100 percent component inspect or replace the portion of the 4-sidecut piping
that ultimately failed24. The turnaround work scope and approval process is guided by
predetermined criteria in what Chevron calls a “Framing Document.” Turnaround work requests
are approved or denied by the turnaround planning group based on the document criteria. The
Framing Document sets the criteria for work items that can be automatically accepted as
turnaround work items during the planned turnaround. Less urgent items and those that may be
performed on the run (while the unit is operating) or during the next turnaround are not included
by default in the turnaround work scope. Inspection data for the 4-sidecut piping, where
measurements were historically taken on high-silicon fittings,25 indicated the 4-sidecut piping
could safely operate through 2016. Therefore, recommendations to replace the 8-inch 4-sidecut
piping during the 2007 and 2011 turnarounds were denied in accordance with the Framing
Document criteria. The Sulfidation Failure Prevention Initiative developed by the ETC
metallurgist experts was not considered a valid mandate for justifying turnaround work which
otherwise fell outside the acceptance criteria of the Framing Document.