OSHA has cited a refinery for serious violations of safety and health hazards related to process safety management (PSM) following a fire and subsequent explosions at the company’s Refinery Complex in June 2019. The company faces $132,600 in penalties. OSHA’s inspection found deficiencies in the refinery’s PSM program, including failing to establish or implement written procedures, insufficient hazard analysis and inadequate inspection of process equipment for highly hazardous chemicals used in the process. Here is a breakdown of the citations:
Citation 1 Item I
Type of Violation: Serious; $13,260
29 CFR 1910.119(d)(1)(v): Process safety information pertaining to the hazards of the highly hazardous chemicals in the process did not contain the corrosivity data information:
a) HF Alkylation Unit 433: On or about 6/21/20 19, the employer did not compile written process safety information required by the standard such as, but not limited to, corrosion studies related to the long term corrosive effects of Sulfolane decomposition and its acidic by-products on carbon steel process equipment and piping in the 433 Unit.
Citation 1 Item 2
Type of Violation: Serious; $13,260
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices.
a) On or about June 21, 20 19, the employer failed to document that the Depropanizer Reflux Pumps (Pl4A/B) complies with the employer’s chosen RAGAGEP, API 751 Safe Operation of Hydrofluoric Acid Alkylation Units API Recommended Practice 751, Fourth Edition, May 2013, Section 3.3.3, when the pumps were not equipped with remotely operated emergency isolation valves on the discharge of pumps.
b) On or about June 21, 2019, the employer failed to document that the Depropanizer Reflux Pumps (Pl 4A/B) complies with the employer’s chosen RAGAGEP, API 751 section 3.3.3. when the pumps could not be stopped during an emergency by a safe accessible shutdown button (e.g., sufficient distance away from the pumps).
c) On or about 6/21/20 19, the employer failed to document that the Treater Feed Surge Drum (V-1), Deethanizer Feed Surge Drum (V-6) and associated pipe support structures for V-1, V-6 and P- 14A/B complies with employer’s chosen RAGAGEP, Sunoco Fire Protection Plan Review for High Complexity Projects Date: November 6, 2007, No. : 06-40 Section 4.6, 4.7 and 4.10.2; Foster Wheeler Process Plants Division Fireproofing Specification (Spec. 1070-84A I, June 26, 1972); PESs Fireproofing (EP 11-2- 1) Section 3.4, 3.5, 5. 1.2, 5.1.3, 5. 1.5; and API 2218 Fireproofing Practices in Petroleum and Petrochemical Processing Plants Sections 4.2.1.2. 4.2.1.3, 5. 1.2.1. 5.1.6. 6. 1.1, when VI and V-6, and associated pipe support structures were not equipped with fireproofing to prevent structural failure of vessel and piping containing highly hazardous chemicals. Lack of fireproofing on equipment and pipe supports is a hazardous condition that can result in the loss of strength and
collapse due to fire-related heat exposure.
Citation 1 Item 3
Type of Violation: Serious; $13,260
29 CFR 1910.119(e)(J)(iii) : The Process Hazard Analysis did not address engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.)
a) On or about June 21, 2019, the employer’s PHA did not address automatic activation of an emergency shutdown system such as the means to automatically shut down or isolate flammable releases adjacent to V-1, V-6, and P- I 4A/B upon detection of fire and gas leak, automatic activation of HF spray mitigation or firewater system, or other means such as a process deviation based on alarm set point (e.g. HF, flammable gas release, high pressure, high level etc.).
Citation 1 Item 4
Type of Violation: Serious; $13,260
29 CFR 191O.119(e)(3)(iv): The process hazard analysis did not address the consequences of failure of engineering and administrative controls:
a) HF Alkylation Unit 433: On or about June 21, 20 I 9, the employer’s PHA failed to address the consequences of failure of engineering controls such as the need for an independent active firewater protection system to protect V-1 and V-6 from flame impingement due to a jet fire. The existing elevated monitor (Monitor #1) which serves the HF spray mitigation system can only provide limited firewater to V-lN-6, but was unavailable during the fire/explosion event.
b) HF Alkylation Unit 433: On or about June 21, 2019, the employer’s PHA failed to address consequences of failure of engineering controls such as the need for fireproofing of V-1, V-6 and associated pipe supporting P-l 4A/B, where the un-fireproofed equipment and piping support structures, and the inadequate spacing between vessels resulted in fire spreading due to jet fire impingement.
Citation 1 Item 5
Type of Violation: Serious; $13,260
29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address the hazards related to facility siting:
a) HF Alkylation Unit 433: On or about June 21, 2019, the employer’s facility siting study did not evaluate consequences of boiling liquid expand ing vapor explosions (BLEVEs), fireballs and vapor cloud explosion impacts from BLEVEs onto equipment and piping located in Unit 433.
b) HF Alkylation Unit 433: On or about June 21,20 19, the employer’s facility siting study did not evaluate jet fire impacts (e.g., heat flux and dose) from a P-14A/B discharge piping release scenario onto V-1, and V-6.
c) HF Alkylation Unit 433: On or about June 2 1, 2019, the employer’s facility siting study did not address a suitable location and survivability of the HF Spray Mitigation Pump House such that its pumps are available for mitigating a release of HF and fire in the unit. The Mitigation Pump House was in close proximity to process area serving V-1, V-6, and P-14A/B and was damaged during fire, explosion and BLEVE event.
Citation 1 Item 6
Type of Violation: Serious; $13,260
29 CFR 1910.119(j)(2): The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment:
a) HF Alkylation Unit 433: On or about June 21, 2019, the employer failed to establish/develop mechanical integrity procedures that included information on the extent and type of positive material identification (PMI) that was required to ensure that the conduct of retroactive positive material identification (retroPMI) inspections/testing on PSM-covered process equipment at the PES refinery, including but not limited to, piping in the 433 Hydrofluoric Alkylation Unit, to maintain the integrity of process equipment in the unit.
b) HF Alkylation Unit 433: On or about .lune 2 1, 2019, the employer failed to implement its mechanical integrity procedures, Piping Inspection Procedure, PES-PH-INP-PRO -PRP-0 1.04, Appendix V, and Inspection of Process Piping Requirements, M.04.005 (Revision 10/20/20 15), Section 5.4.2.b, when it failed to correctly identify a piping dead leg (e.g., spare pump piping on the discharge of the Depropanizer Reflux Pump P-l 4B) in the 433 Hydrofluoric Alkylation Unit. The incorrectly identified
dead leg piping segment included an 8-inch piping elbow that catastrophically failed on June 21, 2019.
Citation 1 Item 7
Type of Violation: Serious; $13,260
29 CFR 1910.19(j)(4)(i): The employer did not perform inspection and tests on process equipment:
a) On or about June 21, 2019, the employer failed to conduct piping inspections and tests in the 433 Hydrofluoric (HF) Alkylation Unit on piping component s that were constructed /installed with older carbon steel materials that are more susceptible to HF acid corrosion. The employer did not conduct testing and inspections to determine whether the structural integrity of the following piping sections is suitable for continued service:
1. F series piping HC-250 l-14 (T-6 Overhead) untested /uninspected carbon steel elbow downstream from N0 130 CML 005 (See ISO 433-TML-N-01 Sh 0 1 of6)
2. F series piping HC2650-2 untested /uninspected carbon steel elbow downstream of V-11 Depropanizer Accumulator, D0510 CML 002 (See ISO 433-D-04 Sh O 1 of 4)
3. F series piping HC4510-6 untested /uninspected carbon steel elbow downstream of V-35A Defluorinator and M02 l O CML 080. (See ISO 433-M-02 Sh 03 of 3)
4. F series piping HC2736-6 (Propane Vapor from V-13A /B Propane Defluorinator to E-23), untested/uninspected carbon steel elbow downstream from LO2 l O CML 055 (See ISO 433-L-02 Sh 02 of 2)
5. F series piping HC4506-4 (Butane Liquid from E-39 Defluorinator Feed /Condenser to V-36 Flare KOH Treater), untested/uninspected carbon steel elbow downstream from M03 IO CML 011 (See ISO 433-M-03 Sh O 1 of 9)
6. F series piping HC2335-24 untested /uninspected carbon steel elbow downstream JO4 I 0 CML 005 which is downstream of the T-5 Isostripper (See ISO 433-.1-04 Sh O 1 of 1)
7. F series piping HC2539 – l 2 (Depropanizer Btms from/to T-6 thru E-17 A/B Rebo il er), untested/uninspected carbon steel elbow downstream from N02 IO CML 020 (See ISO 433-N -02 Sh 01 of 7)
This hazardous condition exposed employees to fire, explosion, toxics, and corrosives hazards. One feasible means of abatement is to implement the PES Hazard Alert, Industry Alert HF Alkylation Corrosion recommendation, refiners with HF alkylation facilities should consider conducting a onetime thickness measurement on all installed piping components in spooled sections of carbon steel piping systems in HF acid service, possibly including positive material identification, to determine
whether accelerated localized corrosion is occurring.
Abatement certification and documentation required within IO days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written
records.
Citation 1 Item 8
Type of Violation: Serious; $13,260
29 CFR 1910.119(j)(4)(ii): The employer’s inspection and testing procedures did not follow recognized and generally accepted good engineering practices.
a) HF Alkylation Unit 433: On or about June 21, 2019, the employer did not establish and implement inspection and testing procedures for Depropanizer Reflux Pumps (P- l 4A/B) in accordance with employer’s chosen RAGAGEPs, API 751 Safe Operation of Hydrofluoric Acid Alkylation Units APT Recommended Practice 751, Fourth Edition, May 2013, Section 3.4 and 3.5.
b) HF Alkylation Unit 433: On or about June 21, 2019, the employer did not establish and implement inspection, testing and preventative maintenance procedures for fire water systems including firewater pumps in accordance with employer’s chosen RAGAGEPs such as NFPA 25 Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems Section 8.2, and 8.5.
Citation 1 Item 9
Type of Violation: Serious; $13,260
29 CFR 1910.119(j)(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.
a) HF Alkylation Unit 433: On or about June 21, 20 19, the employer did not correct deficiencies in HF spray mitigation pumps (P-11 SOA & B) in a timely manner to assure pumps met the hydraulic curve at 150 percent during an emergency.
b) HF Alkylation Unit 433: On or about June 20, 2019, the employer did not correct deficiency in HF spray mitigation pump (P-1150B) when employees had to manually start P-1150B during the event due to a remote pump start failure.
Citation 1 Item 10
Type of Violation: Serious; $13,260
29 CFR 1910.119(l)(1): The employer did not establish or implement written procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process.
a) HF Alkylation Unit 433: Employees worked on and in the vicinity of equipment containing highly hazardous chemicals where the employer did not establish and implement written procedures for changing feed composition which contributed to the Deethanizer Charge Pump (P-5A) fire, exposing employees to fire, explosion, toxics, and corrosive hazards, which occurred on and at points up to the destructive event on 6/21/2019.
b) HF Alkylation Unit 433: Employees worked on and in the vicinity of equipment containing highly hazardous chemicals where the employer did not establish and implement written procedures for changing V-1 s high and high-high pressure control alarm set points which contributed to the Deethanizer Charge Pump (P-5A) fire, exposing employees to fire, explosion, toxics, and corrosive hazards, which occurred on and at points up to the destructive event on 6/21/2019.
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