OSHA Inspection: CLARK OIL & REFINING CORPORATION

Issued

Feb 15, 1991

Abate by

Jul 26, 1991

Penalty

Initial $900 · Current $900

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
employer did not furnish a place of employment which was 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
increased likelihood of fire, explosion, and/or toxic chemical release,
such as benzene, naptha, hydrogen sulfide, and hydrogen flouride, due to
the catastrophic failure of inadequately inspected and maintained
pressure vessels throughout the refinery. The employer failed to
establish, properly implement and manage an effective program of
pressure vessl safety, including maintenance, inspection, rating, repair
alteration and/or replacement. In addition, appropriate records for
informed decision making and documenting the vessel's actual condition
were not prepared, retained or made available for inspection. Employees
working throughout the refinery were exposed to these hazards on a
daily basis, including during the inspection which was conducted from
August 16, 1990 through January 10, 1991.
The following deficiencies in the company's pressure vessel inspection
and maintenance program were noted at the time of the inspections:
a) Vessel 12-v-1 Stage 1 Reactor, which hydrogenerates sulfur and
naptha in Isomax. Feed is designated to operate at 1675 psi and
850 F maximum.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) The inspection records indicate that fire damage had occurred to
the vessel's insulation; however, the integrity of the vessel was
not determined.
3) Visual inspections were performed without any other nondestructive
testing methods being used to determine the change in condition of
the vessel.
b) Vessel 12-V-3 Stage 1 Separator, which separate liquid treated
product from gas is designed to operate at 1575 psi and 250 F maximum
and is used in hydrogen and sulfur service.
Pressure Vessel Report indicated the following deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Heavy scaling was found throughout the interior of the vessel without
follow up to the cause.
c) Vessel 12-V-12 Debutanizer receiver, collects debutanizer overhead
liquid and is designed to operate at 255 psi and 250 F maximum and is
used in sulfur service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) UT measurements show that head and shell thicknesses have increased
and that no follow up inspections were made by other nondestructive
methods to determine why this increase had occurred.
3) Vessel recores do not include the vessel design and specifications;
thereby, the change in the vessel's condition could not be accurately
determined.
d) 7-V-9 Main Column Overhead receiver at which collects main column
overhead liquid is designed to operate at 35 psi and 150 F and
is used in sulfer service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by insepctors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Where grooving or pitting had occurred, no follow up inspections
were performed by nondestructive testing methods other than UT.
3) UT measurements show that head and shell thicknesses have increased
and that no follow up inspections were made by other nondestructive
methods to determine why this increase had occurred.
4) Heavy scaling was found throughout the interior of the vessel without
follow up to the cause.
e) Vessel 7-V-20 High Pressure receiver, which collects compressor
discharge condensed liquid is designed to operate at 250 psi and 50 F
maximum and is used in sulfur service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) UT measurements show that head and shell thicknesses have increased
and that no follow up inspections were made by other nondestructive
methods to determine why this increase had occurred.
f) Vessel 7-V-25 Debutanizer Receiver, which collects debutanizer column
overhead liquid is designed to operate at 200 psi and 150 F maximum
and is used in sulfur service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Visual inspections of weld seams were performed without preparing the
weld seam for inspection.
g) Vessel 8-V-4 Acid Regenerator Column, which purifies and concentrates
Hydroflouric Acid is designed to operate at 200 psi and 500 F
maximum.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Where grooving or pitting had occurred, no follow up inspectionswere
performed by nondestructive testing methods other than UT.
h) Vessel 8-V-15 Caustic Propan Scrubber, which is used to remove H 2 3
from propane is designed to operate at 375 psi and 250 F maximum and
is used in sulfur service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Visual inspections of this vessel were made from the bottom manway
of the vessel.
i) Vessel 8-V-19 Depropanizer Feed Surge Drum, which holds depropanizer
liquid feed is designed to operate at 400 psi and 250 F maximum.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) The reports reference "excessive metal loss at a weld seam." However,
only UT measurements were made to determine the condition of the weld
furthermore the vessel was not repaired or re-tested to determine the
integrity of the vessel.
3) Where grooving or pitting had occurred, no follow up inspections were
performed by nondestructive testing methods other than UT.
4) Skin blisters were noted and were only examined by visual and UT.
j) Vessel 10-V-2 Separator, which is used to separate liquid products
form recycled gas is designed to operate at 450 psi and 300 F maximum
and is used in Hydrogen and sulfur service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Where grooving or pitting had occurred, no follow up inspections were
performed by nondestructive testing methods other than UT.
3) Visual inspections of weld seams were performed without preparing the
weld seam for inspection.
k) Vessel 10-V-3 Stripper, which is used to strip light hydrocarbons
from treated naptha is designed to operate at 200 psi and 475 F
maximum and is used in sulfur serviced.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Where an internal explosion had occurred, the inspector did not
determine whether or not the integrity of the vessel had changed.
3) When corrosion was refenced by previous inspections, only visual
inspections were performed.
4) Visual inspections of weld seams were performed without preparing the
weld seam for inspection.
l) Vessel 10-V-4 Stripper Receiver, which collects stripper overhead
liquid is designed to operate at 200 psi and 100 F maximum and is
used in sulfur service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) This vessel was modified by removing two nozzles and welding them
shut at vessel surface. After the modification, the vessel's
intergity was not determined nor did a certified inspector examine
the modifications.
3) Ut measurements show that head and shell thicknesses have increased
and that not follow up inspections were made by other nondestructive
methods to determine why this increase had occurred.
m) Vessel 14-V-1 Reactor, which is used to hydrogenerate sulfur in ray
naptha is designed to operate and 475 psi and 800 F and is used in
Hydrogen and sulfur service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) UT measurements show that head and shell thicknesses have increased
and that no follow up inspections were made by other nondestructive
methods to determine why this increase had occurred.
n) Vessel 14-V-3 Separator, which is used to separate liquid products
from recycled gas is designed to operate at 425 psi and 250 F
maximum and is used in Hydrogen and sulfur service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) UT measurements show that head and shell thicknesses have increased
and that no follow up inspections were made by other nondestructive
medhods to determine why this icrease had occurred.
o) Vessel 14-V-4 Stripper Column, which is used to strip light hydro
carbons from treated naptha is designed to operate at 150 psi and
500 F maximum is used in sulfur service.
Pressure Vessel Report of Inspections indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Visual inspections of this vessel were made from the manways of the
vessel.
p) Vessel 5-V-5 Product Separator, which is used to separate products
from recycle gas id designed to operate at 525 psi and 150 F
maximum and is used in hydrogen and sulfur service.
Pressure Vessel Report of Inspection indicated the following deficienc-
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Visual inspections of weld seams were performed without preparing
the weld seam for inspection.
3) Visual inspections of this vessel were made from the manways of the
vessel.
q) Vessel 9-V-9 Stripper Receiver, which is designed to collect stripper
overhead liquid and to operate at 325 psi and 150 F maximum, and
is also used in Sulfur service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Where grooving or pitting had occurred, no follow up inspectionswere
performed by nondestructive testing methods other than UT.
r) Vessel 9-V-17 Reactor, which is used to hydrogenate sulfur in raw
naptha is designed to operate at 700 psi and 975 F maximus and is
used in Hydrogen and sulfur service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) UT measurements show that head and shell thicknesses have increased
and that no follow up inspections were made by other nondestructive
methods to determine why this increase had occurred.
3) Inspections were not performed because the vessel had not been
opened for the inspector.
s) Vessel 13-V-2 Steam Drum is used to produce saturated steam, is
designed to operate at 180 psi and 400 F maximum.
Pressure Vessel Report of Inspections indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Vessel inspection reports reference other inspection reports which
are not included in the vessel's file.
3) Report indicates that safety relief devices which were set at the
maximum operating pressure were corroded and partially plugged.
t) Vessel 13-V-8 Product Separator, which separates liquid reaction
products from gas is designed to operate at 500 psi and 250 F and is
used in hydrogen service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2. Visual inspections of weld seams were performed without preparing the
weld seam for inspection.
u) Vessel 13-V-9 Stabilizer Column, which is used to remove light
hydrocarbons from platformate, is designed to operate at 300 psi and
550 F maximum.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) UT measurements show that head and shell thicknesses have increased
and that no follow up inspections were made by other nondestructive
methods to determine why this increase had occurred.
3) Visual inspections of weld seams were performed without preparing the
weld seam for inspection.
v) Vessel 20-V-5 Product Separator, which separates liquid reaction
products from gas, is designed to operate at 250 and 250 F maximum,
and is used in hydrogen service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Vessel records do not include the vessel design and specifications;
thereby, the change in the vessel's condition could not be
accurately determined.
3) Inspections were not performed because the vessel had not been
opened for the inspector.
4) When corrosion was referenced by previous inspections, only visual
inspections were performed.
w) Vessel 20-V-8 Debutanizer Receiver, which collects debutanizer over
head liquid is designed to operate at 300 psi and 250 F maximum.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Vessel recores do not include the vessel design and
specifications; thereby, the change in the vessel's conditions could
not be accurately determined.
3) Where grooving or pitting had occurred, no follow up inspections were
performed by nondestructive testing methods other than UT.
4) Visual inspections were performed without any other nondestructive
testing methods being used to determine the change in condition of
the vessel welds.
x) Vessel 20-V-9 Steam drum, which produces 150 psi saturated steam is
designed to operate at 180 psi and 400 F maximum.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Vessel records do not include the vessel design and specifications;
thereby, the change in the vessel's condition could not be
accurately determined.
3) UT measurements show that head and shell thicknesses have increased
and that no follow up inspections were made by other nondestructive
methods to determine why this increase had occurred.
4) Vessel inspection reports reference other inspection reports which
are not included in the vessel's file.
y) Vessel 23-V-6 Reaction Furnace, which reacts to hydrogen sulfide with
sulfur dioxide is designed to operate at 80 psi and 324 F maximum,
and is used in sulfur service.
Pressure Vessel Report of Inspection indicated the following
deficiencies:
1) Inspections were performed by inspectors who were not certified to
inspect and interpret the results of pressure vessel inspections.
2) Vessel inspections reports show either incorrect vessel
identification numbers for the vessel being inspected or reports of
other vessels being inspected in this vessel's records. This leads
to the question of whether or not this vessel was inspected.
A feasible and useful method of correcting these hazards is to
establish and properly implement an effective pressure vessel safety
program including maintenance, inspection, rating, repair, alteration
and/or replacement of pressure vessels, associated piping and safety
devices, such a program must include the following elements as a
minimum:
1) Ensure that persons who are authorized to perform and interpret
nondestructive examination are qualified in the American Society of
Non-destructive Testing (ANST) Recommended Practice SNT-TC-1A, or
equivalent written requirements, or written procedures in accordance
with the 1989 ASME Boiler and Pressure Vessel Code (ASME B&PV),
Section V.
2) Ensure that determination of probable corrosion rate and
specification of maximum period between inspections is performed
accordance with the 1989 ASME Boiler and Pressure Vessel Code and
1989 ANSI National Board Inspection Code (NBIC), Sections U-105 and
U-106, or API Standard 510.
3) Train pressure vessel inspectors in ASNT RO SNT-TC-1A and require
ASNT Level II or equivalent qualifications for all inspectors.
4) Establish and owner-user inspection agency or contract an Insurance
inspection agency in accordance with the ANSI/NBIC and/or API 510
to perform:
a) Inspections of all weld repairs made to ASME pressure vessels in
accordance with the 1989 ASME B&PV Code, Section VIII, Sections UG-90
through UG-136.
b) Inspections of the fabrications of new vessels in accordance with
the 1989 ANSI/NBIC, Chapter II, I-100 through I-203.8, I-300 and
I-400.
5) Perform hardness testing in accordance with API RP 942 and the
National Association of Corrosion Engineer's (NACE) Standard RP-04-72
for pressure vessels in hydrogen service and/or subject to hydrogen
attack.
6) Establish an inspection program and perform inspections of pressure
vessels handling corrosive liquids in accordance with 1989 ASME
B&PV Code, API 510 and/or the ANSI/NBIC Inspection Code.

Issued

Jan 30, 1991

Abate by

Feb 18, 1991

Penalty

Initial $900 · Current $600 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
being overcome by oxygen deficient, flammable, and/or toxic atmospheres,
such as but not limited to, hydrogen sulfide, benzene, carbon monoxide,
carbon dioxide, sulfur dioxide, and hydrocarbons, while entering tanks
and/or vessels for repair, maintenance, and/or inspection.
a) Throughout the facility employees were exposed to the above hazards
on a continuing and regular basis due to deficiencies in the
employers written "vessel entry" program coupled with a lack of
appropriate training for employees.
These deficiencies included:
1) The company's written "vessel entry" procedures were inadequate in
that they did not specify the following:
a) Hazard Identification
b) Warning signs and symbols
c) Rescue
d) Toxic Atmosphere Testing
2) Employees entering confined spaces were not effectively trained in
the following:
a) Reason for, proper use, and limitations of Personal protective
equipment
b) How to respond to emergencies
c) Description of how to recognize probable air contaminant over
exposure symtpoms to themselves and co-workers, and method(s)
for alerting attendants.
Among other methods, a feasible and acceptable method to correct this
hazard is to revise the company's "vessel entry" procedures to
incorporate the elements of an adequate confined space entry program,
such as specified in ANSI Z117.1 1989. Elemetns of this program shall
include, but are not limited to:
1) Written procedures - Confined space entry procedures shall be written
and include at least the following items: hazard idenfification,
permit systems, stmospheric testing, attendants, ventilation,
equipment, rescue, warning signs and symbols, employee training, and
contractors.
2) Hazard identification - Hazards shall be identified for each confined
space. The hazard identification process shall include, but is not
limited to the following:
a) The past and present uses of the confined space which may effect
the atmosphere of the space.
b) The physical characteristics, configuration and location of the
space.
c) Existing or potential hazards in the confined space relating to
atmospheres.
d) Biological hazards associated with confined spaces.
3) Permit system - Establish a written permit system for the proper
preparation, implementation, duration, and revoking of permits.
4) Atmospheric testing - Before entry into a confined area testing
shall be conducted for hazardous atmospheres (oxygen deficiency,
flammability, and toxicity). Testing of confined spaces shall be
conduced throughout the entire atmosphere of cofined space to be
occupied. The acceptable limits whenever the following conditions are
maintained:
Oxygen - 19.5-23.5%
Flammability - less than 10% of the LEL
Toxicity - less than recognized exposure limits
5) Attendants - Attendants shall be stationed outside of any permit
required confined space and have the following duties:
a) Provide standby assistance to occupants entering the confined
space.
b) Direct occupants to exit the confined space when any irregularity
is observed.
c) Initiate evacuation and emergency procedures.
d) Monitor for any conditions or changes that could adversely effect
the entry.
e) Remain at the entry point unless relieved by another attendant.
6) Centilation - When mechanical ventilation used in confined spaces to
remove atmospheric contaminants, the space shall be ventilateduntil
the atmosphere is within the acceptable ranges specified in 4.
Ventilation shall be continued during the entire occupancy of the
space when the change of atmospheric conditions is possible.
7) Equipment - Provide, maintain and assure the proper use of the
equipment necessary for safe entry, including testing, monitoring,
communication and personal protective equipment.
8) Rescue - Ensure that the methods and/or equipment necessary to
retrieve entrants of confined spaces available at the entry site.
9) Warning signs and symbols - All confined spaces which could be
inadvertently entered shall have a sign identifying it as a
confined space.
10) Employee training - Personnel responsible for supervising, planning,
entering, or participating in confined space entry and rescue shall
be adequately trained in their functional duties prior to any
confined space entry. Training shall be repeated as often as
necessary to maintain an acceptabl elevel of personnel competence.
11) Contractors - Employers who have outside contractors enter confined
spaces shall inform contractors of the appropriate hazards associated
with the confined space to be entered.

Issued

Jan 30, 1991

Abate by

Mar 4, 1991

Penalty

Initial $800 · Current $650 Reduced

Issued

Jan 30, 1991

Abate by

Feb 4, 1991

Penalty

Initial $700 · Current $400 Reduced

Issued

Jan 30, 1991

Abate by

Feb 11, 1991

Penalty

Initial $800 · Current $600 Reduced

Issued

Jan 30, 1991

Abate by

Aug 5, 1991

Penalty

Initial $9,000 · Current $1,000 Reduced