OSHA Inspection: CITGO PETROLEUM CORPORATION

Issued

Oct 3, 1990

Abate by

Oct 6, 1990

Penalty

Initial $10,000 · Current $5,000 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 from the recognized hazard of fire
and explosion in that:
1a) The employer did not take adequate measures to implement commonly
recognized management control systems and methods to prevent or
minimize the loss from fire or explosion in a liquid process
operation in that:
a) The employer did not conduct internal audits that included such
items as a process hazard review, a job safety analysis, and a
human factors analysis of the tank truck loading rack operation
and the operation of the John Zink Company, vapor recovery system,
modified x unit, shop order rs x50585, at the Tampa Terminal.
This condition could be corrected by addressing safety factors in, for
example, a general hazard and operability study, a structured method of
systematically investigating each element, of a process design to
identify all the way in which deviations can occur from intended design
parameters to create hazards or operability problems. for guidance in
developing such an audit such recognized sources as follows may serve
as valuable guides.
1) NFPA 30 Flammable and Combustible Liquids Code, 1987 chapter 5
"Operations" with special attention paid to chapter 5-5, "Fire
Prevention and Control".
2) Citgo Petroleum Corporation Safety manual, August 1988, section
30 "Engineering Design" and section 33 "Safety Devices".
3) Loss prevention in the process industries, Frank P Lees,
Butterworths, 1986, chapter 6, "Management Systems", and chapter
B. "Hazard Identification and Safety Audit".
1b) The employer failed to locate and operate the rack loading and
zink vapor processing systems so that they did not constitute a
fire and explosion hazard in that:
a) Vapor laden tank vehicles were filled at the loading rack and
the displaced vapors were vented to the atmosphere when the
vapor processing system was not in good working order, on or
about 4/15/90.
One method of abating this hazard, among others, would be to discontinue
loading operations until the vapor processing system was restored to
operation in good working order. For guidance see Florida Department of
Environmental Regulations, Fac Rule 17-2.650(1)(f)(10). See also Florida
Department of Environmental Regulation Permit/Certification, Permit No.
A029-130199.
b) Those areas, such as the diked area containing storage tank 211
and the zink vapor process system with its associated piping and
underground condensate tank, where a potential existed for a
flammable liquid spill were not monitored as appropriate, on or
about 4/15/90.
One method of correction, among others would include the provision of
gas detectors where the facilities are unattended, for guidance see NFPA
30, Flammable and Combustible Liquids Code, 1987, chapter 5-5.5.2.
c) The zink vapor processing system was situated in a diked
area so that the pressure vacuum vent stack was located between
the carbon tanks and the underground condensate tank resulting
in the vent exhausting into an area of limited natural ventilation
in the vicinity of potential sources of ignition such as hot
surface, electrical sparks, or frictional sparks, on or about
4/15/90.
One method, among others, of correcting this hazard would be to locate
the pressure vacuum vent stack at an area of better ventilation remote
from the vapor process system apparatus. for guidance see NFPA 30,
chapter 5-3.3 and 5-5.2.
d) The zink vapor processing system was not segregated from storage, but
rather situated in a common diked area with gasoline, on or about
4/15/90.
One method of correcting this hazard would be to segregate the storage
operation from the process operation. For guidance see Loss Prevention
in the Process Industries, Frank P Lees, Butterworths 1986, chapter 10,
"Plant Siting and Layout".