A refinery has been cited for five safety and health violations, including one willful and one repeat, with proposed penalties totaling $126,900. OSHA found deficiencies in the employer’s PSM program and other workplace hazards. The inspection, which began in January, was a follow-up to a 2010 inspection initiated under the agency’s Petroleum Refinery PSM NEP. The one willful violation involve failing to ensure relief valves were properly sized and of adequate capacity to provide relief, for units such as, but not limited to, Crude Unit #1. The repeat violation involves failing to ensure process safety information included the relief system design for a Crude Unit. Three serious violations were cited for failing to ensure intervening block valves, upstream and downstream of relief devices, were locked in the open position; ensure process hazard analysis recommendations for facility siting were resolved in a timely manner; and ensure energy control procedures were written to specifically relieve stored energy. Here is a breakdown of the citations:
Process Safety Information
Citation 1 Item 1a
Type of Violation: Serious; $7,000
29 CFR 1910 .119(d)(3)(ii): The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices.
The employer does not ensure it documented that equipment in the process complied with recognized and generally accepted good engineering practices. The violation occurred in the# 1 Crude Unit on or about January 23, 2013 and times prior to where the employer failed to ensure administrative controls were in place to manage intervening block valve(s)to/from relief devices to ensure they were open during operation in accordance with ASME Boiler and Pressure Vessel Code, Division 1, Section VIII. Identified relief devices and equipment include but are not limited to:
a. PSV-8504 (#1 Desalter)
b. PSV-8505 (#2 Desalter)
c. PSV-8502 (Atmospheric Tower)
d. PSV-8503/8511 (Vacuum Tower)
e. PSV-8512 (V-7325-Vacuum Seal Drum).
This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
Operating Procedures
Citation 1 Item 1b
Type of Violation: Serious; Grouped
29 CFR 1910.119(f)(1): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information.
The employer does not ensure written operating procedures are developed and implemented that provided clear instructions for safely conducting activities involved in each process. The violation occurred in the #1 Crude Unit on or about January 23, 2013 and times prior to where the employer failed to ensure written operating procedures were developed and implemented to provide clear instructions for the use of chains, locks, or car-seals to ensure the intervening block valves to/from relief devices were open during operation following a shutdown/turn around. Identified relief devices and equipment include but are not limited to:
a. PSV-8504 (#1 Desalter)
b. PSV-8505 (#2 Desalter)
c. PSV-8502 (Atmospheric Tower)
d. PSV-8503/8511 (Vacuum Tower) e. PSV-8512 (V-7325-Vacuum Seal Drum).
This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
Process Hazards Analysis
Citation 1 Item 2a
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(5): The employer did not establish a system to assure that the recommendations were resolved in a timely manner and that the resolution was documented.
The employer does not ensure that a system was established to assure the 2012 PHA recommendations were resolved in a timely manner and the resolution was documented.
a. employer failed to ensure that facility siting recommendations for proper control room ventilation were resolved in a timely manner. This condition exposed employees to inhalation, fire, and explosion hazards.
b. employer failed to ensure that facility siting recommendations for installation of blast mitigation glass were resolved in a timely manner and resolution was documented. This condition exposed employees to inhalation, fire, and explosion hazards.
c. employer failed to ensure that facility siting recommendations for equipment outside the control room to be rated for flammable area was resolved in a timely manner and resolved in a timely manner. This condition exposed employees to inhalation, fire, and explosion hazards.
d. employer failed to ensure that recommendation #5 for verification of relief valve capacity was resolved in a timely manner and resolution documented. This condition exposed employees to inhalation, fire, and explosion hazards.
e. employer failed to ensure that recommendation #6 for verification of relief valve #1 and #2 relief valves and associated piping are sized properly was resolved in a timely manner and resolution documented. This condition exposed employees to inhalation, fire, and explosion hazards.
f. employer failed to ensure that recommendation #7 for verification of requirements for over pressure protection of equipment including vessels associated with the vacuum tower was resolved in a timely manner and resolution documented. This condition exposed employees to inhalation, fire, and explosion hazards.
Mechanical Integrity
Citation I Item 2b
Type of Violation: Serious; $0
29 CFR 1910.119(m)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) in a safe and timely manner when necessary means where taken to assure safe operation.
The employer does not correct deficiencies in equipment that were outside acceptable limits in a safe and timely manner when necessary means where taken to assure safe operation. The violation occurred on or about January 30, 2013 in Crude Unit #1 where the employer failed to correct deficiencies in equipment that were outside acceptable limits in a safe and timely manner when necessary means were taken to assure safe operation. An identified equipment-containing structure includes but is not limited to Crude #1 Unit control room. This condition exposed employees to fire and explosion hazards.
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Citation 1 Item 3
Type of Violation: Serious; $4,400
29 CPR 1910.147(c)(4)(ii): The energy control procedures did not clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, including, but not limited to items (a) through (d) of this section.
The employer does not ensure energy control procedures clearly and specifically outline the scope, purpose, authorization, rules, and techniques to utilize for the control of hazardous energy. The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure energy control procedures were written to specifically outline the valves to be operated (opened/closed) and steps to needed to relieve stored energy. Identified procedures include but not limited to the removal of Jordan Valve (TK 323) and South Naphtha Crude Exchanger. This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
Process Safety Information
Citation 2 Item 1a
Type of Violation: Willful; $70,000
29 CFR 1910.119(d)(3)(ii): The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices.
The employer does not ensure it documented that equipment in the process complied with recognized and generally accepted good engineering practices (RAGAGEP).
A. The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure a relief valve was provided to protect equipment from overpressure scenarios in accordance with RAGAGEP such as ASME Division I, Section VIII and API 520. Identified equipment requiring relief protection includes, but is not limited to, the following:
a. PSV-XXOl (E-2246, E-2207, E-2245, E-2209, E-2248, E-2211, E-2212, E-2213, E-2214, and E-2215)
b. PSV-XX02 (E-2202 and E-2228)
c. PSV-XX03/04 (E-2205 and E-2229)
d. PSV-XX05 (E-2211, E-2248, E-2230, E-2216, E-2217, and E-2218)
e. PSV-XX06/07/08 (E-2213, E-2212, E-2247, E-2243, E-2249, and E-2232)
f. PSV-XX?? (E-2261 and E-2262)
g. PSV-XX12 (E-2207, E-2208, E-2209, E-2210, and E-2204)
h. PSV-XX16 (E-2206)
i. PSV-XX21 (E-2214 and E-2215).
This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
B. The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure relief valves were properly sized for relieving capacity in accordance with RAGAGEP such as API 520. Identified relief valves include, but are not limited to, the following:
a. PSV-8504 (#1 Desalter)
b. PSV-8502 (Atmospheric Tower)
c. PSV-8503/8511 (Vacuum Tower).
This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
C. The violation occurred in the # 1 Crude Unit on or about January 23, 2013 and at times prior thereto when the employer failed to ensure relief valves relieving set pressure was at or below the maximum allowable working pressure of the vessel(s) it is protecting in accordance with RAGAGEP such as API 520 and ASME Division I, Section VIII. Identified relief valves include but not limited to:
a. PSV-8502 (Atmospheric Tower)
b. PSV-8503/8511 (Vacuum Tower).
This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
D. The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure relief valves discharged to a safe location in accordance with a RAGAGEP such as ASME Division I, Section VIII. Identified relief valves include but not limited to:
a. PSV-8504 (#1 Desalter)
b. PSV-8505 (#2 Desalter)
c. PSV-8512 (Vacuum Seal Drum).
This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
E. The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure relief valve discharge line/piping was sized to handle the relieving capacity of the relief valve in accordance with a RAGAGEP such as ASME Division I, Section VIII and/or API 520. Identified relief valves include but not limited to:
a. PSV-8504 (#1 Desalter)
b. PSV-8505 (#2 Desalter).
This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
Citation 2 Item 1b
Type of Violation: Willful; Grouped
29 CFR 1910.119(m)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (as defined by process information in 29 CFR 1910 .119( d) before further use or in a safe and timely manner.
The employer does not ensure deficiencies are corrected in equipment that is outside acceptable limits before further use or in a safe and timely manner.
A. The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure a relief valve was provided to protect equipment from overpressure scenarios in accordance with RAGAGEP such as ASME Division I, Section VIII and API 520. Identified equipment requiring relief protection include but not limited to:
a. PSV-XXOl (E-2246, E-2207, E-2245, E-2209, E-2248, E-2211, E-2212, E-2213, E-2214, and E-2215)
b. PSV-XX02 (E-2202 and E-2228)
c. PSV-XX03/04 (E-2205 and E-2229)
d. PSV-XX05 (E-2211, E-2248, E-2230, E-2216, E-2217, and E-2218)
e. PSV-XX06/07/08 (E-2213, E-2212, E-2247, E-2243, E-2249, and E-2232)
f. PSV-XX?? (E-2261 and E-2262)
g. PSV-XX12 (E-2207, E-2208, E-2209, E-2210, and E-2204)
h. PSV-XX16 (E-2206)
i. PSV-XX21 (E-2214 and E-2215).
This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
B. The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure relief valves were properly sized for relieving capacity in accordance with RAGAGEP such as API 520. Identified relief valves include but not limited to:
a. PSV-8504 (#1 Desalter)
b. PSV-8502 (Atmospheric Tower)
c. PSV-8503/8511 (Vacuum Tower).
This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
C. The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure relief valves relieving set pressure was at or below the maximum allowable working pressure of the vessel(s) it is protecting in accordance with RAGAGEP such as API 520 andASME Division I, Section VIII. Identified relief valves include but not limited to:
a. PSV-8502 (Atmospheric Tower)
b. PSV-8503/8511 (Vacuum Tower).
This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
D. The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure relief valves discharged to a safe location in accordance with a RAGAGEP such as ASME Division I, Section VIII. Identified relief valves include but not limited to:
a. PSV-8504 (#1 Desalter)
b. PSV-8505 (#2 Desalter)
c. PSV-8512 (Vacuum Seal Drum).
This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
E. The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure relief valve discharge line/piping was sized to handle the relieving capacity of the relief valve in accordance with a RAGAGEP such as ASME Division I, Section VIII and/or API 520. Identified relief valves include but not limited to:
a. PSV-8504 (#1 Desalter)
b. PSV-8505 (#2 Desalter).
This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gases.
Process Safety Information
Citation 3 Item 1
Type of Violation: Repeat; $38,500
29 CFR 1910.119( d)(3)(i)(D): Process safety information pertaining to the equipment in the process did not include the relief system design and design basis.
The employer does not ensure that the process safety information pertaining to the equipment in the process contains the relief design and design basis. The violation occurred on or about February 5, 2013 and times prior thereto in Crude Unit #1 where the employer failed to ensure that the process safety information included the relief system design and design basis. Identified relief devices include but are not limited to 01-PSV8505 and 01-PSV8508. This condition exposed employees to fire and explosion hazards.
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