A TX refinery has been cited for five (5) PSM violations. OSHA opened an inspection at the facility upon receiving a complaint that employees had been exposed to a leak of hydrofluoric acid at a flange in the alkylation unit while performing maintenance work. Proposed penalties total $66,500. Here is a breakdown…
P&ID’s Not up-to-date, 1910. 119(d)(3)(i)(B), Serious and $7K
- Process safety information pertaining to the equipment in the process did not include the piping and instrument diagrams (P&ID’S)
- The employer conducted the 2011 unit PHA without complete process safety information (PSI).
- On or about April 26, 2012, inside the Control Room in the East Plant Alkylation Unit, P&IDs used by operators for daily operations were inaccurate and not updated to reflect current equipment, piping and instrumentation for process related activities.
PHA not thorough enough, 1910.119(e)(1), Serious and $7K
- PHA was not appropriate to the complexity of the process and did not identify, evaluate, and address the control of the hazards involved in the process. The employer did not ensure the Alkylation unit PHA was appropriate to the complexity of the Alkylation unit processes. The September 2011, Alkylation Unit PHA failed to ‘analyze all appropriate hazards such as those associated with high temperature of the stream from the Depropanizer Feed Condenser to the Depropanizer Feed Settler.
SOP Annual certification, 1910. 119(f)(3), Serious and $7K
- The employer did not certify anually that the operating procedures are current and accurate. On or about April 26, 2012, and times prior there to, in the Alkylation Unit, the employer did not ensure the Alkylation Unit operators were operating the unit with operating procedures that were annually certified.
Correcting MI Deficiencies 1910.119(j)(5) Serious and $7K
- The employer did not correct deficiencies in equipment that were outside acceptable limits defined by the process safety information before further use or in a safe and timely manner when necessary means were taken to assure safe operation. On or about March 6, 2012, and times prior thereto, the employer failed to follow RAGAGEP, ASME section VIII, Division 2, 9.A.3, when the employer did not correct the inlet piping pressure drop deficiencies for two (2) pressure relief valves.
Management of Change 1910.119(1)(1) REPEAT and $38.5K
- The employer did not establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures in the Alkylation Unit when it increased the production capacity of alkylate from the original design capacity of 15,915 barrels per day (BPD) to the present production capacity of 26,800 barrels per day (BPD).
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