The Wyoming Department of Workforce Services (DWS) (WY-OSHA) has cited a refinery for seven (7) violations stemming from a September 2013 incident. An OSHA inspection following the September 27, 2013 explosion and subsequent fire resulted in seven citations and proposed penalties totaling $201,000. No injuries occurred as a result of the incident. WY-OSHA monetary penalties go entirely to the local school district where the violations occurred. The OSHA investigation found that an explosion and subsequent fire occurred in the #4 Hydro-Desulphurization (4HDS) Unit within the Hydrocracker Complex on Friday, September 27, 2013, at 10:10 p.m. Hydrogen embrittlement of a carbon steel control valve in the 4HDS Unit caused a leak of hydrogen which ignited. Hydrogen embrittlement is the process by which various metals become fatigued, brittle and fracture following exposure to hydrogen. The source of ignition is unknown. As a result, the control valve had deteriorated from the inside-out and caused the leak and subsequent explosion. The following citations were issued by OSHA as a result of the September 27th incident:
PLEASE NOTE: these citations are NOT the final settlement and some are BEFORE the employer’s informal conference. They are shared as a learning tool to show what types of issues OSHA and EPA are finding in their PSM/RMP inspections. I have scrubbed all company information from these postings as this is NOT about any one company, but rather a trend of issues that continue to be found by OSHA and EPA.
Willful Violations
During the inspection, OSHA found conditions that merit two willful violations. Violations in the willful category total $140,000 in fines. The inspection found:
- Citation 2-1: Adequate quality assurance review, which helps ensure the proper use of materials in construction and appropriate installation procedures, had not been performed for the flow control valve assembly. The valve was found to be carbon steel and was not suitable for the 4HDS unit.
- Citation 2-2: Required inspection and testing of a corrosion-prone piping loop within the 4HDS unit had not been adequately performed. Repeat citation.
Repeat Serious Violations
The inspection found a condition that merits one repeat serious violation. This violation carries a $35,000 fine.
- Citation 3-1: A process hazard analysis, a careful review of what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals, had not been performed to specifically address the consequences of failure of engineering and administrative controls within the required time period on the 4HDS Unit.
Serious Violations
The inspection found conditions that merit four serious violations. Violations in the serious category total $26,000 in fines.
- Citation 1-1: Adequate emergency response radio communication protocols were not properly in place at the time of the incident.
- Citation 4-1: A process hazard analysis, a careful review of what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals, had not been performed to specifically address the hazards present in the 4HDS process within the required time period.
- Citation 4-2: A pre-start up safety review, a full evaluation of initial start up procedures and normal operating procedures to ensure a safe transfer into the normal operating mode, was not adequately performed within the required time period.
- Citation 4-3: Initial air quality monitoring was not conducted immediately following the explosion.