On Sept. 2, 2014, OSHA initiated an inspection of a petroleum refinery after a fire occurred in a heater at the facility, used to process crude oil. The refinery sustained some minor damage but no injuries were reported. OSHA initiated the investigation under its National Emphasis Program for Process Safety Management at refineries. Here is the breakdown of the citations:
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.
Citation 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 1910.119(c)(2): The employer did not consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard.
a. On or about September 2, 2014, the employer did not ensure employee representatives were consulted when developing shut down procedures for the H-6104 process heater located in Plant 6.
Citation 1 Item 2a
Type of Violation: Serious; $7,000
29 CFR 191O.119(d)(3)(ii): The employer did not document that equipment complied with recognized and generally accepted good engineering practices.
a. On or about September 2, 2014, the process tubes in the convection section of process heater H-61 04 located in Plant 6 did not comply with recognized and generally accepted good engineering practices. The convection section tube walls were below the minimum retirement thickness when the heater caught fire.
Citation 1 Item 2b
Type of Violation: Serious; Grouped
29 CFR 191O.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.
a. On or about September 2, 2014, the employer did not ensure the mechanical integrity program was being implemented to maintain the ongoing integrity of process heater H-6104 located in Plant 6. The convection section of the process heater was initially scheduled to be replaced in 2013 but was later rescheduled to be replaced in fall of 2014 without evaluating the integrity of the equipment.
Citation 1 Item 3a
Type of Violation: Serious; $7,000
29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
a. The employer did not ensure the Company’s management of change program was implemented when it was determined the tubes in the convection section of process heater H-6104 which was scheduled to be replaced in 2013, was extended until Fall 2014. On September 2, 2014, there was a tube failure· in the convection section of the heater that lead to a fire inside of the heater which had to be extinguished by the facility’s fire department.
Citation 1 Item 3b
Type of Violation: Serious; Grouped
29 CFR 1910.119(l)(2)(ii): Management of change procedures did not ensure that the impact of the change on health and safety was addressed.
a. The employer did not ensure the company’s management of change program was implemented in determining if the removal of steam from the convection section of process heater H-6104 impacted the facility’s ability to extinguish process fires inside of the heater. In 2007 steam snuffing was removed from the convection section of process heater H-6104 and on September 2, 2014, there was a tube failure in convection section that lead to a fire inside of the heater which had to be extinguished by the facility’s fire department.
Citation 1 Item 3c
Type of Violation: Serious;
29 CFR 191O.119(l)(2)(iii): Management of change procedures did not ensure that the modifications to operating procedures was addressed.
a. On or about September 2, 2014, the employer did not ensure the company’s management of change prpgram was followed when developing new operational procedures designed to shut down process heater H-6104 with a suspected tube leak.
Citation 2 Item 1a
Type of Violation: Repeat; $38,500
29 CFR 1910.119(f)(1)(ii)(A): 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 infom1ation and did not address at least the consequences of deviation.
a. On or about September 2, 2014, the employer did not ensure operating procedures designed to shut down process heater H-6104 located in Plant 6, specified the consequences of deviation.
Business was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.119(f)(1)(ii)(B), which was contained in OSHA inspection number 858284, citation number 1, item number 2 and was affirmed as a final order on April 28, 2014, with respect to a workplace located at XXXXXXXXXXXXXX.
Citation 2 Item 1b
Type of Violation: Repeat; Grouped
29 CFR 191O.119(f)(1)(ii)(B): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and did not address at least the steps required to correct or avoid deviation.
a. On or about September 2, 2014, the employer did not ensure operating procedures designed to shut down process heater H-6104 located in Plant 6, specified the steps to take to correct or avoid deviation.
Business was previously cited for a violation of this occupational safety and health standard or its equivalent standard 191O.119(f)(1)(ii)(B), which was contained in OSHA inspection number 858284, citation number 1, item number 2 and was affirmed as a final order on April 28, 2014, with respect to a workplace located at XXXXXXX.
Citation 2 Item 1c
Type of Violation: Repeat; Grouped
29 CFR 1910.119(f)(1)(iii)(E): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and did not address any special or unique hazards.
a. On or about September 2, 2014, the employer did not ensure operating procedures designed to shut down process heater H-6 l 04 located in Plant 6, specified any unique or special hazards involved with the operation. During the reduction of heat in the process heater a fire occurred due to the presence o f heavy naphtha in the convection section from a tube leak.
Business was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.119(f)(1)(ii)(B), which was contained in OSHA inspection number 858284, citation number 1, item number 2 and was affirmed as a final order on April 28, 2014, with respect to a workplace located at XXXXXXXXXXXXXXXXXXXX.
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