OSHA Inspection: B. P. AMOCO PLC

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not furnish employment and a place of employment which
were free from recognized hazards that were causing or likely to cause
death or serious physical harm to employees in that employees were
exposed to the hazard of inhalation of toxic substances at B P Toledo
Refinery under normal operating conditions or as a result of system
upset and/or equipment failure:
a) B P did not have a fixed monitoring system for hydrocarbons
on the M.O.V. deck of Reformer 1.
b) B P did not have an adequate or properly enforced confined
space entry permit system.
c) B P did not assure that start-up procedures were effective.
1) October 6, 1991, at Reformer 1, a fire occurred due to
inadequate start-up procedures in not having introduced
flow through the convection section tubes until after the
burners had been lit.
d) B P did not have an effective and properly implemented hot
work permit system for use in flammable and/or potentially
hazardous areas.
e) B P did not assure that relieving devices were properly
sized, installed, maintained, and tested.
1) Pressure relieving devices were not assured to be sized
for worst case scenarios, i.e. Sat Gas/Naptha Treater SV
#1410, SV #1414, SV #1435, SV #1470, Alky II SV #409, FCC
I SV #1272A.
2) Relieving devices were not inspected and tested on a
frequent interval as indicated by the B P Safety Relief
Valve Computer Program, i.e. Coker I SV #1213, Crude Vac
I SV #1126, North Tank Field (NTF) SV# 1993, SV #1998, LPG
SV #331.
3) The integrity of pressure relieving devices was not
assured by allowing operators to hammer on relieving devices
that had relieved and did not reseat, i.e. Reformer I area.
4) The discharge from each pressure reliving device did
not vent to a safe location, i.e. SV #1504 Regen Furnace
outlet which had a drain pipe that exited less that 6 ft.
from the ground which could direct part of the discharge
towards an operator.
f) B P did not establish an effective program of installation,
inspection, and maintenance of piping, valves, and fittings.
1) The piping inspections did not adequately determine the
corrosion rate, life expectancy, or the next test date.
For on-stream and newly installed piping and fittings, i.e.
Reformer I area piping and fittings as noted on the Pipescan
report.
2) Anomalous thickness data, such as increasing thickness
measurements were not resolved, i.e. Reformer I area piping
and fittings as noted in the Pipescan report.
3) Incorrect materials and/or devices were used, i.e. on
pipe flanges immediately adjacent of pump PR #5978 in the
Alky III unit, a flange connecting a 6 in. diameter pressure
line operating at 300 lbs. pressure at 50 degrees F., was
connected at the flange by B7 studs and nuts.  Six of the
studs were 5 in. long as required and the other two studs
were too short, thus not allowing the complete mating of
the internal and external threads, thereby reducing the
strength of the assemblies.  At  least two of the internal
threads on the nut were not seated.
4) Studs found in the material warehouse were not identified
as to grade as required.
g) B P did not assure that instrumentation, controls, and alarms
were installed and used.
1) October 10, 1991, a fire occurred at tank #705 located
at the Asphalt Plant Tank Area, this was due to a lack of
instrumentation and/or controls to prevent the draining
(pumping out of asphalt) of holding tanks to a level that
allowed the gas fired heaters to cause ignition of the
remaining asphalt.
h) B P did not assure protection of employees in occupied work
areas.
1) On November 8, 1991, a fire and an uncontrolled release
of isobutane occurred caused by contractor employees
attempting to reinstall a safety valve on the piping to
the Coalescer on #2 Alkylation Unit, B P employees were
working in #2 Alkylation Unit approximately 20 feet away.
The ventilation system for the #2 Alkylation Unit control
room consists of opening windows and running of the air
conditioner which could allow a flammable hydrocarbon
release (such as an uncontrolled release of isobutane which
occurred) in the area.  The isobutane could have been drawn
into the #2 Alkylation Unit control room where it may reach
a possible ignition source and could result in an unconfined
vapor cloud explosion.  #2 Alkylation Unit Control Room
did not have a positive ventilation system, to prevent
entrance of toxic vapor and/or gas into the control room.
Filtered air shall be monitored to ensure its continued
quality.
2) Reformer 1, Satellite Control Room #2 did not have a
positive ventilation system, to prevent entrance of toxic
vapor and/or gas into the control room.  Filtered air shall
be monitored to ensure its continued quality.
A feasible and useful method of correcting these hazards include
but is not limited to the following:
a) Install a fixed monitoring system to determine hydrocarbon
leakage on the MOV deck of Reformer 1.  This system should be
installed, calibrated and maintained so as to issue a warning
to employees before they enter the deck area.
b) Implement and enforce a confined space entry program.  This
program should include as a minimum the following:
1) A requirement that Gastec Combustible Gas Meters, or
other similar testing equipment used to ensure that area
was safe for entry be calibrated by a trained, qualified
person with a captive test gas of known concentration at
intervals not to exceed 30 days or as often as recommended
by the equipment manufacturer.
2.  Establish an entry permit which records all information
related to the work including materials tested for; any
sampling results; any isolation measures taken such as
lockout, tagout, equipment, and procedures used for purging,
inerting, ventilation or flushing; rescue equipment
available; communication procedures, personal protective
equipment used and a complete evaluation of all hazards
to ensure a safe entry.
3.  Institute a procedure for the determination of
contaminants to be tested for in each confined space entry
by a competent person.
4.  Establish a periodic schedule for the reevaluation of
hazards to ensure that conditions have not changed.
5.  Evaluation of the confined space entry program to ensure
conformance to American National Standards Institute (ANSI)
Z117.1 1989.
c) Provide a written start-up procedure for units, assure that
employees are trained in these procedures and confirm that super-
visors and operators follow these procedures.
d) Revise the currently used hot work permit procedure and to
update the permit form.  The new procedure and permit should
include as a minimum the following:
1.  Listing of the work and the extent and location of the
work area.
2.  Listing of an exact description of the equipment
involved and the task to be performed.
3.  Identify any sampling equipment used to determine that
work may proceed in the area and the results obtained from
such testing.
4.  Require the signature of all employees involved in the
approval of the permit.
5.  Assure that all employees are thoroughly trained in
the procedure.
6.  Arrange for a periodic review of the procedure and
update it as necessary.
7.  Assure that the procedure is fully implemented and
enforced.
e) Institute an effective program to assure that relieving
devices are properly sized, installed, and maintained.
1.  Properly size relieving devices in accordance with ASME
Boiler & Pressure Vessel Code and API 520 Sizing, Selection,
and Installation of Pressure-Relieving Devices in Refineries
and API 521 Guide for Pressure-Relieving and De-pressuring
systems.
2.  Follow the established criteria for inspection and
testing of safety relief valves which has been established
by the company.
3.  Assure integrity of pressure relieving devices by
prohibiting operators from hammering on them when they
believed that they had failed to reseat and were leaking.
4.  Inspect pressure relieving devices to make sure that
they discharge to an area which could not be occupied by
employees.
f) Institute an effective program for the installation,
inspection and maintenance of piping, valves and fittings.
1.  Ensure that corrosion rates and determination of
retirement thickness of piping is performed and [periodic
piping inspections are done in accordance with ANSI B31.1
Power Piping, ANSI B31.3 Petroleum Refinery Piping, and
API 574 Inspection of Piping, Tubing Valves, and Fittings.
2.  Determine the resolution of anomalous data which shows
information such as increasing wall thicknesses.
3.  Assure that only properly marked studs are obtained.
Studs meeting the B7 requirements must be so marked so as
to assure that they are not confused with studs that do
not meet these requirements.
4.  Establish an effective program of quality control to
ensure that the proper materials are ordered, received,
stored, and installed.
5.  Closely inspect all piping systems after work is done
and prior to use and accept and place into service only
those systems found to be properly installed and assembled.
Training of inspectors should assure that they are qualified
to make these assessments.
g) Evaluate that all necessary instrumentation, controls and
alarms are installed and are properly used or provide alternative
means to perform the function that the alarms would perform.
1.  Install high temperature alarms and fail-safe controls
to prevent asphalt from being heated above 350 - 375 degrees
Farenheit in the Asphalt Holding Tank #705.
2.  Install low level alarms and fail-safe controls on the
Asphalt Storage and Holding Tanks to assure that the level
of the tanks do not fall to a level so as to allow the gas
fired heaters to cause ignition of the remaining asphalt.
3.  Record levels of products that are moved into and out
of tanks to assure that operators are aware as to the amount
that the tanks contain.
4.  Prior to transferring product calculate the safe
remaining capacity and record this capacity.
5.  Assure that all operators are trained in the established
operating procedures to control liquid Asphalt levels and
temperatures and to assure that operational limits of tank
capacity and temperatures are maintained.
h) Protect employees in occupied work areas.
1.  Design and construct a ventilation system for critical
occupancy buildings, so that the air intake would not draw
flammable vapors from near by process area should a vapor
release occur (such as a positive pressure ventilation
system).
2.  Install flammable gas detectors immediately downstream
of the air intake for critical occupancy buildings which
when activated would initiate the shutdown of the air intake
system.

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
%%
employer did not furnish employment and a place of employment which were
free from recognized hazards that were causing or likely to cause death
or serious physical harm to employees in that employees were exposed to
the hazards of fires and explosions at BP Toledo Refinery under normal
operating conditions or as a result of system upset and/or equipment
failure.
a)  BP did not have a fixed monitoring system for hydrocarbons on
the M.O.V. deck of Reformer 1.
b)  BP did not assure that start-up procedures were effective.
1.  October 6, 1991, at Reformer 1 a fire occurred due to
inadequate start-up procedures in not have introduced flow
through the convection section tubes until after the burners
had been lit.
c)  BP did not have an effective and properly implemented hot
work permit system for use in flammable and/or potentially
hazardous areas.
d)  BP did not assure that relieving devices were properly sized,
installed, maintained and tested.
1)  Pressure relieving devices were not assured to be sized for
worst case scenarios, i.e. Sat Gas/Naphtha Treater SV #1410, SV
#1414, SV #1435, SV #1470, Alky II SV #409, FCC I SV #1272A.
2)  Relieving devices were not inspected and tested on a
frequent interval as indicated by the BP Safety Relife ValVe
Computer Program, i.e. Coker I SV #1213, Crude Vac I SV #1126,
North Tank Field (NTF) SV #1993, SV #1998, LPG SV #331.
3)  The integrity of pressure relieving devices was not assured
by allowing operators to hammer on relieving devices that had
relieved and not reseat, i.e. Reformer I area.

Issued

Mar 23, 1992

Abate by

Apr 7, 1992

Penalty

Initial $2,500 · Current $2,000 Reduced

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $5,000 · Current $5,000

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $1,500 · Current $2,000

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $5,000 · Current $4,000 Reduced

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $2,500 · Current $2,500

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $5,000 · Current $4,000 Reduced

Issued

Mar 23, 1992

Abate by

Mar 25, 1992

Penalty

Initial $1,500 · Current $1,500

Issued

Mar 23, 1992

Abate by

Mar 27, 1992

Penalty

Initial $2,500 · Current $2,500

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $5,000 · Current $4,000 Reduced

Issued

Mar 23, 1992

Abate by

Mar 27, 1992

Penalty

Initial $5,000 · Current $4,000 Reduced

Issued

Mar 23, 1992

Abate by

Mar 27, 1992

Penalty

Initial $5,000 · Current $4,000 Reduced

Issued

Mar 23, 1992

Abate by

Mar 27, 1992

Issued

Mar 23, 1992

Abate by

Mar 27, 1992

Issued

Mar 23, 1992

Abate by

May 28, 1992

Penalty

Initial $2,500 · Current $2,500

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $5,000 · Current $4,000 Reduced

Issued

Mar 23, 1992

Abate by

May 26, 1992

Penalty

Initial $5,000 · Current $4,000 Reduced

Issued

Mar 23, 1992

Abate by

Mar 25, 1992

Penalty

Initial $5,000 · Current $4,000 Reduced

Issued

Mar 23, 1992

Abate by

Mar 27, 1992

Penalty

Initial $2,500 · Current $2,500

Issued

Mar 23, 1992

Abate by

Mar 31, 1992

Penalty

Initial $5,000 · Current $4,000 Reduced

Issued

Mar 23, 1992

Abate by

Mar 27, 1992

Penalty

Initial $5,000 · Current $4,000 Reduced

Issued

Mar 23, 1992

Abate by

Mar 31, 1992

Penalty

Initial $5,000 · Current $4,000 Reduced

Issued

Mar 23, 1992

Abate by

Mar 31, 1992

Penalty

Initial $2,500 · Current $2,500

Issued

Mar 23, 1992

Abate by

Mar 27, 1992

Penalty

Initial $5,000 · Current $2,000 Reduced

Issued

Mar 23, 1992

Abate by

Mar 24, 1992

Penalty

Initial $2,000 · Current $2,000

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $1,500 · Current $1,500

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Issued

Mar 23, 1992

Abate by

Mar 27, 1992

Penalty

Initial $1,500 · Current $1,000 Reduced

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $1,500 · Current $2,500

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Issued

Mar 23, 1992

Abate by

Mar 26, 1992

Penalty

Initial $4,000 · Current $4,000

Issued

Mar 23, 1992

Abate by

Mar 26, 1992

Issued

Mar 23, 1992

Abate by

Mar 26, 1992

Issued

Mar 23, 1992

Abate by

Mar 26, 1992

Issued

Mar 23, 1992

Abate by

Mar 26, 1992

Issued

Mar 23, 1992

Abate by

Mar 26, 1992

Penalty

Initial $5,000 · Current $5,000

Issued

Mar 23, 1992

Abate by

Mar 26, 1992

Issued

Mar 23, 1992

Abate by

Mar 31, 1992

Penalty

Initial $35,000 · Current $35,000

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not furnish employment and a place of employment which
were free from recognized hazards that were causing or likely to cause
death or serious physical harm to employees in that employees were
exposed to:
Employees were exposed to death or dismemberment from the 3200
p.s.i. water spray cutting and boring nozzles of the coke cutting
stem.  This was due to the bypassing of the upper limit switch
which served to prevent the operation of the water when the head
was withdrawn out of the top of the drum at coker 1.  The lack of
a shut off switch for the water at the west coker drum in coker 1
increased the hazard.
Among other methods, one feasible and acceptable abatement method
to correct this hazard include, but not necessarily limited to
the following:
1)  Repair use and maintain in continued operation the upper limit
switch so as to prevent water pressure at the cutting head when the
head is withdrawn out of the top of the coke drum.
2)  Install water shut off at the control positionfor the west
coker drum cutting head in coker 1.

Issued

Mar 23, 1992

Abate by

Jun 26, 1992

Penalty

Initial $70,000 · Current $56,000 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not furnish employment and a place of employment which were
free from recognized hazards that were causing or likely to cause death
or serious physical harm to employees in that employees were exposed to
the hazard of burns, broken bones, crushing injuries, and/or death at
BP Toledo Refinery as a result  of system upset and/or equipment
failure.
BP did not establish an effective program of pressure vessel were
not performed.  Corrosion rates were not calculated to determine
inspection intervals, i.e. PR #1949 Recirculation Dry Drum and other
Reformer I vessels.
a)  Frequent inspections of pressure vessels were not
performed.  Corrosion rates were not calculated to determine
inspection intervals, i.e. PR #1949 Recirculation Dry Drum
and other Reformer I vessels.
b)  Inspection points for nondestructive test methods on
pressure vessels were not extablished, i.e. as indicated
by the inspection log for the Reformer I vessels.
c)  U1 reports were not maintained and each pressure vessel did
not have a nameplate or the nameplate was not readable, i.e.
Reformer I vessels such as PR #1126 Feed Surge drum, PR #1135
Debutinizer Reflux drum.
d)  Anamolous thickness data, such as increasing wall thickness
measurements, was not resolved, i.e. as indicated by the
inspection log for Reformer I vessels.
A feasible and useful method of correcting these hazards include but is
not limited to the following:
Establish an effective program of pressure vessel inspections including
but not limited to:
1)  Ensure that determination of probable corrosion rate and
specification of maximum period between inspections performed in
accordance with ASME Boiler & Pressure Vessel Code and ANSI/National
Board Inspection Code and API 510
Pressure Vessel Inspection Code.
2)  Determine and use of inspection points for non-destructive
testing.
3)  Ensure that each pressure vessel is provided with an original
U1 report and readable nameplate in accordance with ASME Boiler &
Pressure Vessel Code.
4)  The reconciliation of anomalous thickness data which reported
increase in wall thickness.

Issued

Mar 23, 1992

Abate by

Mar 31, 1992

Penalty

Initial $24,500 · Current $24,000 Reduced

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $35,000 · Current $35,000

Issued

Mar 23, 1992

Abate by

Mar 27, 1992

Issued

Mar 23, 1992

Abate by

Apr 24, 1992

Penalty

Initial $35,000 · Current $35,000

Issued

Mar 23, 1992

Abate by

Mar 26, 1992

Penalty

Initial $70,000 · Current $70,000

Issued

Mar 23, 1992

Abate by

Mar 26, 1992