OSHA Inspection: LA GLORIA OIL AND GAS COMPANY

Issued

Mar 3, 1992

Abate by

May 26, 1997

Penalty

Initial $5,000 · Current $1,250 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 recognized hazard of fire and explosion.  The following
conditions contributed to the existence of this hazard:
a.   On or about October 16, 1992, the employer had not
established and documented current information regarding the hazards
of the process including, but not limited to written documentation of
the critical operating parameters of the FCCU, standard operating
procedures, and flow diagrams for the FCCU.  Without such current
information operators may not be aware of critical parameters, thus
exposing employees to the potential of a process upset and release of
flammable hydrocarbons, by exceeding such parameters.
Feasible abatement methods to correct this hazard may include, but is
not limited to:
1.   Maintaining current process safety information so that it
is readily available to operators and employees.
b.   On or about October 23, 1991, the employer had not conducted
a hazard analysis of process including but not limited to the Reactor/-
Regenerator of the FCCU where the differential pressure is considered
critical.
Feasible abatement methods to correct this hazard may include but is
not limited to implementation of a program of hazard analysis.
c.   On or about October 16, 1991, the employer was not conducting
comprehensive investigations of incidents (including near misses), such
as but not limited to the leak on the stripper in the FCCU in 1990, to
the extent necessary to understand its causes and potential con-
sequences, and to determine how future incidents can be avoided.
Failure to investigate, identify the cause, and eliminate causes, may
lead to repeated incidents which include the release of flammable
hydrocarbons, fire and/or explosion.
Feasible abatement methods to correct this hazard may include, but are
not limited to:
1.   Implementation of an Incident Investigation program with
adequate follow through provisions to ensure that the cause(s) of
an incident are understood and appropriate corrective action is taken
to prevent other similar incidence.
d.   On or about October 16, 1991, the employer had not
established and implemented a preventative maintenance program to
ensure that the mechanical integrity of equipment used to handle or
process hazardous materials was maintained to control the risk of
releases and other accidents.  One such example is, but not limited
to, wet gas compressors in the FCC Unit, hot pumps in the fractionation
section.  Failure to implement a program of preventative maintenance
may result in failure of the equipment leading to process upset and
possible release of flammable hydrocarbons.
Feasible abatement methods to correct this hazard may include, but are
not limited to the following:
1.   Establish and implement a preventative maintenance program
which includes written procedures and establishes the use of techniques
such as nondestructive testing for corrosion analysis, vibration
monitoring of compressors or pumps on actual processes, calibration of
critical instruments, and an established expected service life of
critical parts with replacement schedules.