OSHA Inspection: HOVENSA LLC

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,000

General-duty citation text

29 CFR 1910.22(a)(1):  Place(s) of employment were not kept clean and
orderly, or in a sanitary
condition:
a- Hovensa St. Croix Refinery, Caustic Area South of the Penex Unit -
Operators making
rounds, performing procedures and responding to emergencies were exposed
to tripping
and slipping hazards while using concrete stairs with debris on their
treads.  Condition
noted on or about 07/06/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.23(c)(1):  Open sided floor(s) or platform(s) 4 feet or more
above the adjacent
floor or ground level were not guarded by standard railings (or the
equivalent as specified in 29
CFR 1910.23(e)(3)(i) through (v)), on all open sides:
a- Hovensa St. Croix Refinery, SRU East - Operators performing procedures
and
responding to emergencies were exposed to fall hazards of over 14 feet
while accessing
the Fabri valve.  Condition noted on or about 06/03/09.
b- Hovensa St. Croix Refinery, 5DD Low Pressure Flash Drums - Operators
performing
procedures and responding to emergencies were exposed to fall hazards of
approximately
14 feet.  No fall protection was provided between the existing platform
and the drum.
Condition noted on 06/03/09.
c- Hovensa St. Croix Refinery, Penex Unit Compressor Building - Employees
were
exposed to fall hazards of 7 feet while working on the compressor
platforms which were
only provided with a single 34 inch high guardrail.  Condition noted on or
about
07/01/09.
d- Hovensa St. Croix Refinery, Penex Unit, D-200 Charge Drum - Employees
were
exposed to falls of 14 feet while working on the platform.  No fall
protection was in
place between the platform and the drum.   Condition noted on or about
07/06/09.
e- Hovensa St. Croix Refinery, Area 1 Control Room Exterior South Side -
Employees
were exposed to falls of over 9 feet while working on the building air
handling platform.
There was no proper top rail, and a mid rail was missing for a portion of
the work
platform.  Condition noted on or about 07/06/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.27(c)(4):  The distance from the centerline of rungs, cleats,
or steps to the nearest
permanent object in back of the ladder was less than 7 inches:
a- Hovensa St. Croix Refinery, East side of the Fin Fan Platform, Penex
Unit -
Employees were exposed to fall hazards of 14 feet while using a fixed
metal ladder
which had a conduit within 1-2 inches of it's rung.  Condition noted on or
about
07/01/09.
b- Hovensa St. Croix Refinery, West side of the Fin Fan Platform, Penex
Unit -
Employees were exposed to fall hazards of 4 feet while using a fixed metal
ladder with
railings located within 1 inch of it's rungs.  Condition noted on or about
07/06/09.
c- Hovensa St. Croix Refinery, D-203, Penex Unit - Employees were exposed
to fall
hazards of 14 feet while using a fixed metal ladder with rungs within 3
inches of the
vessel's concrete support.  Condition noted on or about 07/06/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.36(h):  Each outdoor exit route did not meet the minimum
height and width
requirements for indoor exit routes:
a- Hovensa Refinery St. Croix, SRU East Beavon Unit Cooling Tower - Access
to the
distribution valves located on top of the Cooling Tower was blocked by a
24" pipeline
that diagonally intersected the tubular frame stairway leading to this
area.  Condition
noted on or about 06/03/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B):  Process safety information pertaining to the
equipment in the
process did not include the piping and instrument diagrams:
a- Hovensa St. Croix Refinery, Penex Unit - On E-217, the 3 inlet and 3
outlet
isolation valves were not correctly indicated on P&ID #0200-D-002 sheet 9
with only
1 inlet and 1 outlet valve shown on the drawing.  Condition noted on or
about
07/03/09.
b- Hovensa St. Croix Refinery, Penex Unit - Pressure Safety Valve
(PSV)-671 outlet
isolation valve located at the relief header inlet is not shown as chain
locked open
(CLO) on P&ID #0200-D-0006 sheet 2.  Condition noted on or about 07/03/09.
c- Hovensa St. Croix Refinery, Penex Unit - The E-1101 Hot Slop Cooler Box
which
has been out of service for 3-4 years but was shown as active equipment on
P&ID
#0200-D-0004 sheet 1.  Condition noted on or about 07/03/09.
d) Hovensa St. Croix Refinery, Penex Unit - Set pressures for rupture
disks (RDs)
associated with PSVs were not listed on P&IDs to include but not limited
to PSE-278,
273, 363 and 366 on P&ID #0200D-002 sheet 3.  Condition noted on or about
07/03/09.
e) Hovensa St. Croix Refinery, Alkylation Unit - Set pressures for RDs
associated
with PSVs were not listed on P&IDs to include but not limited to PSE-97
and PSE-
107 on P&ID 7200-D-0011.  Condition noted on or about 07/03/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(d)(3)(ii):  The employer did not document that the
equipment in the
process complied with recognized and generally accepted good engineering
practices
(RAGAGEP):
The employer could not document in their PSI that equipment in the process
complied
with RAGAGEP in the following cases:
a- The employer did not comply with RAGAGEP such as but not limited to
ASME Boiler and Pressure Vessel Code, Division 1 (BPVC), Section VIII,
UG-135(d) when it failed to provide adequate controls to ensure that
intervening valves on the upstream or downstream lines to/from relief
devices
remained in the open position during pressure vessel operation.   A number
of
such valves were found closed, chain locked closed or were open but not
chain
locked open.  The following valves were not chain-locked open:  C-200A,C-
200B, C200C 2" and 4" block valves to/from PSVs on the make-up and
unifiner recycle sides,  E-211 3" outlet isolation valves (4 valves),
PSV-491 1"
inlet isolation valve, PSV-491 1.5" outlet isolation valve, E-205A/B/C/D 4"
shellside outlet isolation valves (2 valves), E-217 6"/6"/4" inlet
isolation
valves (3 valves) and 4" outlet isolation valves (3 valves), PSV-4 3" inlet
isolation valve (also partially closed), PSV-4 3" outlet isolation valve
(also
fully closed), PSV-973 3" inlet isolation valve, PSV-973 3" outlet
isolation
valve, D-302 3" inlet line valve upstream of check valve, D-302 3" inlet
line
valve downstream of check valve, PRCV-184 3" bypass valve, PSV-635 1.5"
inlet isolation valve (also fully closed, and bypass valve closed thereby
isolating system), PRCV-128 3" outlet valve located at relief header inlet
(also
closed), PSV-671 1.5" inlet valve, PSV-671 2" outlet valve (also
chain-locked
closed, and bypass valve closed thereby isolating system), E-260B 6" block
valve between shellside inlet and FRCV-32, FT-609 3" downstream block
valve (also car-seal closed), E-201 6" shellside outlet block valve, block
valve
4" downstream of FT-317 and line #2-812-B-3".  Conditions noted on or about
07/03/09 and 07/06/09.
b- Hovensa St. Croix Refinery, Penex Unit - Reinforced concrete supports
for
equipment to include but not limited to pipelines containing highly
hazardous
chemicals (HHC) were observed in disrepair with concrete spalling off and
exposed steel re-bar.  Structural concrete assessments performed at
Hovensa in
2006 and 2008 noted that pipe support racks throughout operating units had
extensive spalling of reinforced concrete and oxidation of rebar.  The
employer failed to comply with their own Engineering Standards such as but
not limited to 420.1 Pipe Support Design,  430.1 Concrete Construction,
430.2 Concrete Materials and Testing, 430.3 Concrete Reinforcing and 430.5
Concrete Foundations and Structures.  Condition noted on or about 07/01/09.
c- Hovensa St. Croix Refinery, Penex Unit - The employer did not comply
with RAGAGEP such as but not limited to API 576 Section 4.9.2 when
itfailed to install a tell-tale indicator between the RD (PSE-889) and
PSV-199
for the E-277A/B Drier Regeneration Heater.  Condition noted on or about
07/06/09.
d- Hovensa St. Croix Refinery, Penex Unit - On or about 07/06/09 the drain
near the D-161 Flash Drum was plugged, allowing water to accumulate in the
area.  The employer did not comply with RAGAGEP such as but not limited
to CCPS Guidelines for Engineering Design for Process Safe Section 16.5.6
which requires that drainage/spill control systems be inspected on a
regular
basis to ensure they do not contain any blockages.
e- Hovensa St. Croix Refinery, Penex Unit -  The employer did not comply
with RAGAGEP such as but not limited to ASME Boiler and Pressure Vessel
Code, Division 1, Section VIII, UG-120(a) when it failed to maintain U-1 or
U-1A forms for the following pressure vessels:  E-7221A, E-7221B, E-206A,
D-214, R-202 and D-7201B.  Condition noted on or about 09/15/09.
f- Hovensa St. Croix Refinery, Penex Unit - The employer did not comply
with RAGAGEP such as but not limited to API 570 Piping Inspection Code -
Inspection, Repair, Alteration, and Rerating of In-Service Piping Systems
Section 6.2 when it failed to document piping service class for Penex
piping
systems.  Such piping circuits include but are not limited to 100, 410 and
4260
found throughout the unit.  Condition noted on or about 09/16/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(e)(3)(v):  The process hazard analysis did not address
facility siting:
a- Hovensa St. Croix Refinery, Penex Unit - The PHA performed in 2005 and
subsequent facility siting studies performed thereafter did not address
the hazard of
flammable and/or toxic gases entering the Area 1 Control Room during
emergency
events such as but not limited to the loss of positive pressure or  the
release of HHCs
from process equipment under high temperature and pressure.  The air
intake for the
building HVAC system was only 9 feet above the ground with holes noted in
the
unit's metal housing.  In  addition, there were numerous holes in the
control room's
masonry walls.  Condition noted on or about 09/15/09.
b- Hovensa St. Croix Refinery, Penex Unit - The 2005 PHA did not address
hazards
involving the exposure of employees in the Area 1 Control Room to severe
blast
injuries from flying projectiles and falling concrete (walls/roof) as a
result of
exposure to an overpressure of 5.0 psi. The resulting pressure wave will
cause major
damage to total collapse of the structure.  Condition noted on or about
09/15/09.
Abatement Note
The employer must comply with RAGAGEP such as but not limited to API 752
Management of Hazards Associated with Location of Process Plant Buildings
Section
3.3.7.2 which requires mitigation measures such as relocating personnel,
reinforcing
buildings, installing external walls and/or constructing a new
explosion-resistant
structures.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(e)(5):  The employer did not establish a system to
promptly address the
team's findings and recommendations; assure that the recommendations were
completed in a
timely manner and that the resolution was documented:
a- HOVENSA St. Croix Refinery - Procedure 35-0019 Process Hazard Analysis
and
Procedure 35-0027 Audit/Incident/PHA Recommendations Resolutions along with
PHAs conducted for PENEX and Alkylation units failed to set a specific time
period/date by which recommendations are to be completed.  Recommendations
were
risk-ranked with rankings from level A (very high risk) to level E (very
low risk)
with response times ranging from immediate management attention to work
notification/change management.  Condition noted on or about 07/03/09.
b- HOVENSA St. Croix Refinery - The following PHA recommendations/remarks
were not completed at the time of the inspection:
1) PENEX 1995 PHA, node 1, p. 1 - Consider modifying the Standard
Operating Procedure: "Switching from PENEX to Butamer Operation" Step 3
to also ensure that the LCV-249 valve is wide open.  This recommendation
was noted in the PHA as a repeat recommendation but cannot be found
elsewhere in the PHA document.
2) PENEX 1995 PHA, node 2, p. 3 - Consider chain-locking open the 3" 150
psig block valve downstream of FT-609 in Line No. 2-2014-B-3".  This
recommendation was noted in the PHA as a repeat recommendation but cannot
be found elsewhere in the PHA document.
3) PENEX 1995 PHA, node 5, p. 2 - Consider chain-locking open the 6"
block valve on the shellside outlet of E-201 in Line No. 2-819-C-6"-IH.
This
recommendation was noted in the PHA as a repeat recommendation but cannot
be found elsewhere in the PHA document.
4) PENEX 1995 PHA, node 6, p. 1 - Consider chain-locking open the 4"
block valve downstream of FT-317 on Line No. 2-176-B-4".  This
recommendation was noted in the PHA as a repeat recommendation but cannot
be found elsewhere in the PHA document.
5) PENEX 1995 PHA, node 11, p. 1 - Consider chain-locking open the 6"
block valve between E-260B shellside inlet and FRCV-32 since it could be
subject to high pressure from deadheaded pumps.  This recommendation was
noted in the PHA as a repeat recommendation but cannot be found elsewhere
in the PHA document.
6) PENEX 1995 PHA, node 12, p. 2 - Consider adding a paddle blind
isolation between the two normally closed 3" block valves in the evacuation
line from reactors: R-203 and R-204 in Line No. 2-632-B-3".   This
recommendation was noted in the PHA as a repeat recommendation but cannot
be found elsewhere in the PHA document.  No paddle blind was observed on
the union 07/03/09.
7) PENEX 2005 PHA, node 4, p. 68 - Provide adequate overpressure
protection for E-200, H-200, R-200 in the event E-200A is blocked
bycatalyst.  This will reduce the likelihood for the release of flammable
material
to atmosphere which may lead to fire, personnel injury, or environmental
impact.  This recommendation included the wording "By matter of HOVENSA
practice, the justification was not recorded for the rejection of the
following
recommendation."   When requested, no explanation regarding the rejection
or
status of this recommendation was provided.
8) Alkylation 1998 PHA, p. 139 - Consider providing permanent safe access
to
the equipment.  This item was noted in the PHA as a remark and refers to a
punchlist.  The copy of the punchlist provided by the company lists the
item
but does not document completion.  This item is considered a deficiency
discovered during the PHA and should be captured as a recommendation in the
PHA recommendation tracking system.
9) Alkylation 1998 PHA, p. 139 - Consider labeling the exchangers.  This
item was noted in the PHA as a remark and refers to a punchlist.  The copy
of
the punchlist provided by the company lists the item but does not document
completion.  This item is considered a deficiency discovered during the PHA
and should be captured as a recommendation in the PHA recommendation
tracking system.
10) Alkylation 1998 PHA, p. 140 - Consider re-tagging the PSV-363 and
update P&ID as necessary.  This item was noted in the PHA as a remark and
refers to a punchlist.  The copy of the punchlist provided by the company
lists
the item but does not document completion.
11) Alkylation 1998 PHA, p. 159 - Consider connecting the ground cable to
the Pump, P-7201C.  This item was noted in the PHA as a remark and refers
to a punchlist.  The copy of the punchlist provided by the company lists
the
item but does not document completion.
12) Alkylation 1998 PHA, p. 160 - Consider closing the 1" line and repair
the
local damage.  This item was noted in the PHA as a remark and refers to a
punchlist.  The copy of the punchlist provided by the company lists the
item
but does not document completion.
13) Alkylation 1998 PHA, p. 160 - Consider installing the missing guard on
the Pumps, P-7215A/C.  This item was noted in the PHA as a remark and
refers to a punchlist.  The copy of the punchlist provided by the company
lists
the item but does not document completion.
14) Alkylation 1998 PHA, p. 160 - Fan guard not bolted to the structural
support.  Consider bolting the fan guard to the structure.  This item was
noted
in the PHA as a remark and refers to a punchlist.  The copy of the
punchlist
provided by the company lists the item but does not document completion.
15)
15) Alkylation 1998 PHA, p. 167.  Consider cleaning up the area...Debris
obstructing personnel platform, sample bottle clamp is missing.  This item
was
noted in the PHA as a remark and refers to a punchlist.  The copy of the
punchlist provided by the company lists the item but does not document
completion.
16) Alkylation 1998 PHA, p. 168.  Consider completing Instrumentation
Punchlist Report...Tubing tray clamps are missing, not installed properly,
leaking or corroded.  This item was noted in the PHA as a remark and
refersto a punchlist.  The copy of the punchlist provided by the company
lists the
item but does not document completion.
17) Alkylation 2004 PHA, p. 93 - Consider reprogramming the engineered
low alarm on AI-283 pH analyzer on alkaline water wash.  This
recommendation was noted in the PHA as a repeat recommendation but cannot
be found elsewhere in the PHA document.
18) Alkylation 2006 PHA, Node 5, p. 70 - Take daily samples of water from
S-7201 for pH testing.  This recommendation was noted in the PHA as a
repeat recommendation but cannot be found elsewhere in the PHA document.
19) PENEX 1995 PHA, recommendation #0200-028 - Consider posting sign or
label indicating hydrogen supply to D-209, LSR Sump level instrument
bubblers.  On 07/03/09 no signs or labels were observed on unit equipment.
20) PENEX 1995 PHA, recommendation #0200-035 - Consider evaluating
current policy with regards to installing 5 minute escape packs in Control
Room and in various locations through unit.
21) PENEX 2000 PHA, recommendation #0200-005R1 - Consider rotating the
downstream isolation valve from the vertical position to the horizontal
position
for PSV-479 on D-288; HOVENSA standards require relief valve isolation
valves to be installed in the horizontal position.
22) Alkylation 1995 PHA, recommendation #7200-001 - Suggest high-flow
alarm on FV-447.
23) Alkylation 2006 PHA, recommendation #7200-004R3 - Provide a high
level alarm on Acid KO Drum D-7203 to reduce potential for acid carryover
to effluent treating that would cause severe downstream corrosion.
Equipment
failure from corrosion may release concentrated acid and hydrocarbons
leading
to fire, explosion, and personnel exposure to hazardous material.
(Duplicate
to incident #05-769 and PSM incident #P320-05).
Conditions noted on or about 07/03/09.s

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(f)(1):  The employer did not develop and implement written
operating
procedures that provided clear instructions for safely conducting
activities in each covered
process consistent with the process safety information:
a- Hovensa St. Croix Refinery, Penex Unit - The written procedure, Area 1
Chain
Lock/Carseal Survey checklist, which is used to ensure that chain locked
and car
sealed valves remain open did not include the following valves:
PSV-4 3" inlet isolation valve,
PSV-4 3" outlet isolation valve,
PSV-973 3" inlet isolation valve,
PSV-973 3" outlet isolation valve,
D-302 3" inlet line valve upstream of check valve,
D-302 3" outlet line valve downstream of check valve,
PSV-671 8" outlet valve located at relief header inlet,
PRCV-128 3" outlet valve located at relief header inlet,
These valves were also found not chained locked open.  Condition note on
or about
07/03/09.
b- Hovensa St. Croix Refinery, Penex Unit - The following valves were
inspected
using the Area 1 Chain Lock/Carseal Survey checklist on 02/16/09, and
found by
HOVENSA to be not CLO as required:
PSV-491 1.5" outlet isolation valve,
E-205A/B/C/D 4" shellside outlet isolation valves (2 valves),
PRCV-184 3" outlet isolation valve,
Block valve 6" between E-260B shellside inlet and FRCV-32,
Block valve 3" downstream of FT-609 (valve observed as car-sealed closed).
On or about 07/03/09 the above noted valves were observed by OSHA to be in
the
same position.  The company failed to implement procedures to correct these
deficiencies.
c- Hovensa St. Croix Refinery, Penex Unit - There was no  written operating
procedures for isolating the sample recovery surge drum D-281 with specific
measures for draining and venting the drum as required by PHA
recommendation no.
0200-021.  Condition noted on or about 07/10/09.
d- Hovensa St. Croix Refinery, Area 1 Control Room - There were no written
procedures covering the loss of positive pressure or necessary actions
required if
hydrocarbon or toxic gas was detected in the HVAC system.  Condition noted
on or
about 07/06/09.
e- Hovensa St. Croix Refinery, Penex Unit - There was no written procedure
for theuse of snuffing steam used to extinguish fires on process
equipment.  Condition noted
on or about 07/07/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(j)(2):  The employer did not establish and implement
written procedures to
maintain the on-going integrity of process equipment:
a- Hovensa St. Croix Refinery - The employer failed to implement written
procedures
for inspecting and testing piping outside battery limits.  Condition noted
on or about
07/10/9.
b- Hovensa St. Croix Refinery - The employer failed to implement their CUI
program
with pipe systems identified as susceptible to CUI to include but not
limited to piping
throughout the Penex Unit observed with damaged and/or missing insulation.
Condition noted on or about 07/10/09.
c- Hovensa St. Croix Refinery - The employer failed to establish and
implement
procedures to address anomalous readings such as growths at TMLs.
Condition noted
on or about 09/18/09.
d- Hovensa St. Croix Refinery, Alkylation Unit - There was no written
procedure
developed for periodic inspection of acid tanks as required by PHA
recommendation
no. 7200-009R3.  Condition noted on or about 07/10/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(j)(3):  The employer did not train each employee involved
in
maintaining
the on-going mechanical integrity of process equipment in an overview of
that process and its
hazards and in the procedures applicable to the employee's job tasks to
assure that the
employee can perform the job tasks in a safe manner:
a- Hovensa St. Croix Refinery - Maintenance employees to include but not
limited to
electricians and millwrights working throughout the refinery were not
trained on an
overview of process units and respective hazards such as exposure to
highly hazardous
chemicals.  Condition noted on or about 07/09/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(j)(4)(ii):  Inspections and testing procedures performed
on process
equipment to maintain its mechanical integrity did not follow recognized
and generally
accepted good engineering practices (RAGAGEP):
a- Hovensa St. Croix Refinery, Alkylation Unit - The employer did not
comply
with
RAGAGEP such as but not limited to API 510 Section 6.6 requirements when it
failed to reduce the inspection interval of PSV-00277 which was which
heavily fouled
and leaked at pretest.  Condition noted on or about 09/15/09.
b- Hovensa St. Croix Refinery, Alkylation Unit - The employer did not
comply with
RAGAGEP such as but not limited to API 510 Section 6.6 when PSVs were
replaced
and were not inspected after removing them from service to determine if
their
inspection intervals were appropriate.  Such valves included but were not
limited to
serial numbers:  TJ-82127, TJ-48042, TJ-48046, TJ-48051, TJ-82130, unknown
ser.
no. model 601HG01-AM PSV01529, 92332060 and 92332063.  Condition noted on
or about 09/15/09.
c- Hovensa St. Croix Refinery, Penex Unit - The employer did not comply
with
RAGAGEP such as but not limited to API 510 Section 6.6 when PSVs were
replaced
and were not inspected after removing them from service to determine if
their
inspection intervals were appropriate.  Such valves included but were not
limited to
serial numbers:  TB-95934, TL-66485 and TL-66484.  Condition noted on or
about
09/15/09.
d- Hovensa St. Croix Refinery, Penex Unit - The employer did not comply
with
RAGAGEP such as but not limited to API 510 Section 6.6 when it failed to
perform a
pretest for valve, serial number TM-58561.  Condition noted on or about
09/15/09.
e- Hovensa St. Croix Refinery, Penex Unit - The employer did not comply
with
RAGAGEP such as but not limited to API 574 Section 6.3.3.2 requirements
when it
failed to ensure that insulation plugs were replaced and sealed after
taking piping
thickness measurements on insulated piping throughout the unit.  Condition
noted on
or about 07/06/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(j)(4)(iii):  The frequency of inspections and tests of
process equipment to
maintain its mechanical integrity, was not consistent with applicable
manufacturer's
recommendations and good engineering practices, or more frequently
determined to be
necessary by prior operating experience:
a- Hovensa St. Croix Refinery, Alkylation Unit - External/visual
inspections were not
performed at the required frequency for E-7223A Lube  oil Cooler (last
visual in
1997 with UTs performed in 2000), E-7221A Ejector Condenser (last visual
in 1997
with  UTs performed in 2007) and E-7221B Ejector Condenser (no visual
inspection
report with last UTs in 2000).  Condition noted on or about 09/15/09.
b- Hovensa St. Croix Refinery, Alkylation Unit - Pressure vessels were not
inspected
at their required due dates.  The D-7210 Alkyline Water Wash Drum was last
inspected in May 2006.  The vessel was not inspected by its scheduled due
date of
06/18/09.  The T-7204 Acid Flash Vapor Scrubber was last inspected in
December
2000.  The vessel was not inspected by its scheduled due date of 08/30/08.
Conditions noted on or about 09/15/09.
c-Hovensa St. Croix Refinery, Penex Unit - TML readings were not taken
every 5
years with the last UTs taken in 1998 for Pipe Circuit 100 - stripper
bottoms drain to
U/G sewer, DWG-200-1595.  Condition noted on or about 09/15/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(j)(5):  The employer did not correct deficiencies in
equipment
that were
outside acceptable limits (as defined by the process safety information in
29 CFR
1910.119(d)) before further use or in a safe and timely manner:
a- Hovensa St. Croix Refinery, Penex Unit - The RD for PSV-0973 D-302
Knock-
Out Drum had burst as indicated by a pressure reading of 70-80 psi on the
tell tale
pressure gauge.  Condition noted on or about 07/01/09.
b- Hovensa St. Croix Refinery, Alkylation Unit - The RD for PSV-22 R-7201A
Contactor had burst as indicated by a pressure reading of 50 psi on the
tell tale
pressure gauge.  Condition noted on or about 07/06/09.
c- Hovensa St. Croix Refinery, Alkylation Unit - The RD for PSV-71 D-7201B
Acid
Settler was leaking as indicated by a pressure reading of 18 psi on the
tell tale
pressure gauge.  Condition noted on or about 07/06/09.
d- Hovensa St. Croix Refinery, Alkylation Unit - The pressure gauge for
the E-7221A
Ejector Condenser was inoperative with the needle bent and the gauge
reading over
100 psi.  Condition noted on or about 07/06/09.
e- Hovensa St. Croix Refinery, Penex Unit - Excessive vibration was
observed on fin
fan motors to include but not limited to FFD 0617-C and FFD 0167-D with
visible
movement of structural steel decking and supports.  Condition noted on or
about
07/01/09.
f- Hovensa St. Croix Refinery, Penex Unit - The pressure gauge for the
E-160
Fractionator Bottoms Exchanger was inoperative with the needle pegged and
gauge
reading over 800 psi.  Condition noted on or about 07/06/09.
g- Hovensa St. Croix Refinery, Penex Unit - The C-200B Make-Up Compressor
and
C-200C Make-Up Recycle Compressor was observed in use with their reset
buttons
missing.  Condition noted on or about 07/01/09.
h- Hovensa St. Croix Refinery, Penex Unit - A 1 inch pipe containing
flammable
liquid located on the South side of the P-0201-A Unifiner Stripper
Reboiler was not
adequately supported.  Condition noted on or about 07/01/09.
i- Hovensa St. Croix Refinery, Penex Unit - A 1 inch pipe containing
liquid butane
located on the upper fin fan platform, South side, was not adequately
supported.
Condition noted on or about 07/03/09.
j- Hovensa St. Croix Refinery, Penex Unit - A 4 inch pipe containing
flammable
liquid located between the Regen Stripper Bottoms and Penex Surge Drum was
not
adequately supported.  Condition noted on or about 07/06/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000

General-duty citation text

29 CFR 1910.119(j)(6)(ii):  Appropriate checks and inspections were not
performed to assure
that equipment was installed properly and consistent with design
specifications and the
manufacturer's instructions:
a- Hovensa St. Croix Refinery, Penex Unit - Inspections did not detect the
improper
installation of flange bolts on the 2.5 inch line to flare off PSV-836
located on the fin
fan deck.  Such bolts were not properly installed in that 2 to 4 threads
were not
showing beyond the nut after bolt-up as required by Hovensa Piping
Engineering
Standards.  Condition noted on or about 07/06/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(l)(1):  The employer did not establish and implement
written procedures to
manage changes to process chemicals, technology, equipment, and
procedures; and, changes
to facilities that affect a covered process:
a- Hovensa St. Croix Refinery, Facility Wide - No MOCs were written to
address the
removal from service of fire hydrants and fire monitors.  Condition noted
on or about
07/01/09.
b- Hovensa St. Croix Refinery, Penex Unit - No MOCs were written to
address the
use of temporary structural supports.  Condition noted on or about 7/01/09.
c- Hovensa Refinery St. Croix, Alkylation Unit - The employer did not
perform an
MOC when the automatic level shut down system (LAHH-136, LAHH-1155 and
LAH-468) for D-7202 had been non operative since April 2009 and the
automatic
control valve (LC-146) was being used in the manual mode to control drum
levels.
Condition noted on or about 07/08/09.
d- Hovensa Refinery, St. Croix, Penex Unit - An MOC was not written when
the E-
279 channel head gasket was changed from carbon steel to stainless steel.
Condition
noted on or about 10/19/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(l)(3):  Employees involved in operating a process and
maintenance and
contract employees whose job tasks will be affected by a change in the
process were not
informed of, and trained in, the change prior to start-up of the process
or affected part of the
process:
a- Hovensa St. Croix Refinery, Alkylation Unit - Employee(s) who were
absent
during the training sessions for MOC 12 (out sick, on vacation, out of
plant, etc.)
failed to receive the required training upon their return to work.
Condition noted on
or about 09/03/09.
b- Hovensa St. Croix Refinery, Penex Unit - Employee(s) who were absent
during
training sessions for MOC 8202 failed to recieve such training upon their
return to
work.  Condition noted on or about 09/03/09.
c- Hovensa St. Croix Refinery, Penex Unit - Employee(s) who were absent
during
training sessions for MOC 7211 failed to receive such training upon their
return to
work.  Condition noted on or about 09/03/09.
d- Hovensa St. Croix Refinery, Penex Unit - Employee(s) who were absent
during
training sessions for MOC 7746 failed to receive such training upon their
return to
work.  Condition noted on or about 09/03/09.
e- Hovensa St. Croix Refinery, Penex Unit - Employee(s) who were absent
during
training sessions for MOC 6573 failed to receive such training upon their
return to
work.  Condition noted on or about 09/03/09.
f- Hovensa St. Croix Refinery, Penex Unit - Employee(s) who were absent
during
training sessions for MOC 6012 failed to receive such training upon their
return to
work.  Condition noted on or about 09/03/09.
g- Hovensa St. Croix Refinery, Penex Unit - Employee(s) who were absent
during
training sessions for MOC 6717 failed to receive such training upon their
return
to
work.  Condition noted on or about 09/03/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(l)(5):  A change covered by 29 CFR 1910.119(l) resulted in
a change in
the operating procedures or practices required by 29 CFR 1910.119(f) and
such procedures
or practices were not updated:
a- Hovensa Refinery St. Croix, Alkylation Unit - MOCs 110 & 111 permanently
removed the existing outlet distribution pipe along the top of the Acid
Settler D-7201
including the internal pipe projection of the hydrocarbon outlet nozzle
and installed
two housings with coalescing media at the top of the drum.  However, the
Alkylation
Unit Training Manual, dated 2/4/99-Rev. 1, was not updated to reflect this
change.
Condition noted on or about 09/02/09.
b- Hovensa Refinery St. Croix, Alkylation Unit - MOC 12 permanently
removed the
Electrostatic Precipitator S-7203 located inside the Acid Wash Drum D-7209
and
welded to the top of the vessel shell a housing with a coalescing and
settling media,
an acid collection sump and a drain pipe extended to the liquid level.
However, the
Alkylation Unit Training Manual, dated 2/4/99-Rev. 1, as not updated to
reflect this
change.  Condition noted on or about 09/02/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(o)(4):  The employer did not determine and document an
appropriate
response to each of the findings of the compliance audit required by 29
CFR1910.119(o)(1),
and document that the deficiencies had been corrected:
a- Hovensa St. Croix Refinery - A number of findings were not resolved
from both
the 2004 and 2007 PSM Compliance Audit and Risk Management Program Audits
with many findings from the 2004 audit carrying over as repeat findings on
the 2007
compliance audit.  Findings from the 2007 which were not resolved include
but were
not limited to items:  3.3.2, 3.3.3, 3.3.5, 3.3.6, 3.3.7, 3.3.9, 3.6.2,
3.9.3, 3.9.4,
3.9.9, 3.10.7 and 3.12.24.  Condition noted on or about 09/01/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.134(k)(1)(iii):  The employer did not ensure that each user
could demonstrate
knowledge on how to use the respirator effectively in an emergency
situations including
situations in which the respirator malfunctioned:
a- Hovensa Refinery St. Croix, Penex Control and Alkylation Control Rooms -
Operators could not effectively don their Scott Ska-Pak airline
respirators which must
be used during emergency events including but not limited to the entry of
flammable
or toxic gases into control rooms.  Conditions noted on or about 07/06/09,
07/07/09
and 07/08/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

General-duty citation text

29 CFR 1910.134(k)(1)(iv):  The employer did not ensure that each user
could demonstrate
knowledge on how to inspect, put on, and remove, use, and check the seals
of the respirator:
a- Hovensa Refinery St. Croix, Penex and Alkylation Control Rooms -
Operators
could not effectively don their Scott Ska-Pak airline respirators which
must be used
during emergency events.  Conditions noted on or about 07/06/09, 07/07/09
and
07/08/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.212(a)(5):  Fan blade guards, where the periphery of the
blades was less than
seven feet above the floor or working level, had openings larger than one
half inch:
a- Hovensa St. Croix Refinery, Penex Unit Fin Fan Deck - Workers making
rounds,
performing maintenance and inspection activities were exposed to unguarded
fan blades
78 inches above the work platform.   Condition noted on or about 07/01/09.
b- Hovensa St. Croix Refinery, Penex Unit Fin Fan Deck - Workers were
exposed to a
a partially unguarded fan blade on the motor for the FFD-0165-B OVHD
Condenser.
A 2.5 in x 5in. opening was found on the waist height guard.  Condition
noted on or
about 07/01/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.219(c)(3):  Vertical or inclined shafting was not enclosed
with stationary casing(s):
a- Hovensa St. Croix Refinery, No.5 and No. 6 Crude Unit - Workers were
exposed to
unguarded sections of vertical shafts on pumps P-3132-C and P-3110-B.
Condition noted
on or about 06/02/09.
b- Hovensa St. Croix Refinery, Fin Fan Platform, Penex Unit - Workers were
exposed
to a 2 inch diameter by 5 foot vertical shaft for FFD-0217B which was not
guarded.
Condition noted on or about 07/01/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.219(d)(1):  Pulley(s) with part(s) seven feet or less from the
floor or work
platform were not guarded in accordance with the requirements specified at
29 CFR
1910.219(m) & (o):
a- Hovensa St. Croix Refinery, Fin Fan Deck Penex Unit - Workers
performing rounds,
inspecting and maintaining equipment were exposed to an unguarded 24 inch
diameter
spoked pulley on FFD-0127B.  Condition noted on or about 07/01/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

General-duty citation text

29 CFR 1910.219(e)(3)(i):  Vertical or inclined belt(s) were not enclosed
by guard(s) conforming
to the requirements specified at 29 CFR 1910.219(m) and (o):
a- Hovensa St. Croix Refinery, Fin Fan Deck Penex Unit - Operators and
mechanics
making rounds and repairing equipment were exposed to an unguarded 3/4 in.
belt on
FFD-0127B.  Condition noted on or about 07/01/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.303(b)(7)(iv):  Electrical equipment was not free from damages
parts that may
adversely affect safe operation or mechanical strength, such as parts that
were broken, bent,
cut, or deteriorated by corrosion, chemical action, or overheating:
a- Hovensa St. Croix Refinery, Rear of South Board, Area 1 Control Room -
There
was a damaged cord and splice  on the power cord to component 1S-TRC-1.
Condition noted on or about 07/01/09.
b- Hovensa St. Croix Refinery, Rear of North Board, Area 1 Control Room - A
permanent power strip had a damaged outlet that was pulled out of it's
case.
Condition noted on or about 07/01/09.
c- Hovensa St. Croix Refinery, Rear of North Board, Area 1 Control Room -
Cords
in use were damaged with exposed copper parts.  Condition noted on or about
07/01/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.303(g)(2)(i):  Live parts of electric equipment operating at
50 volts or more were
not guarded against accidental contact by approved cabinets or other forms
of approved
enclosures, or other means listed under this provision:
a- Hovensa St. Croix Refinery, South Wall of Area 1 Control Room - The
door to
inverter power panel B-2 was opened, exposing unguarded energized parts.
Condition
noted on or about 07/01/09.
b- Hovensa St. Croix Refinery, South Wall of Area 1 Control Room - The
cover to
Instrument Panel I-B fed from MCC-E is lifted off to access the interior,
exposing
unguarded energized parts.  Condition noted on or about 07/01/09.
c- Hovensa St. Croix Refinery, Rear of South Control Panel in Area 1
Control Room -
Numerous wire ends, busses, and component lugs were exposed, unguarded and
energized Condition noted on or about 07/01/09.
d- Hovensa St. Croix Refinery, Rear of North Control Panel in Area 1
Control Room -
Numerous wire ends, busses, and component lugs were exposed, unguarded and
energized Condition noted on or about 07/01/09.
e- Hovensa St. Croix Refinery, Upper Fin Fan level, North Side, Penex Unit
- Bare
wires protruding from an exposed conduit were energized and unguarded
Condition noted
on or about 07/01/09.
f- Hovensa St. Croix Refinery, Penex Electrical Sub Station  - The doors
to panels P-
292-B, P-153-A, P-301-A, and Motor Control Center #6 were opened exposing
unguarded energized parts.  Condition noted on or about 07/10/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.304(f)(1)(iv): Overcurrent devices for protection of circuits
rated at 600 volts,
nominal, or less were not readily accessible to each employee or
authorized building
management personnel:
a- Hovensa St. Croix Refinery, Area 1 Control, North Wall - An electrical
box,
Instrument Panel I-A was blocked, preventing entry.  Condition noted on or
about
07/01/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.305(g)(2)(iii):  Fixed cords and cables were not connected to
devices and
fittings so that strain relief is provided that would prevent pull from
being directly
transmitted to joints or terminal screws:
a- Hovensa St. Croix Refinery, Area 1 Control Room, Rear of South Panel -
Numerous components and connections were not provided with strain relief,
both on
new installations and damaged existing strain relief.   Condition noted on
or about
07/01/09.
b- Hovensa St. Croix Refinery, Area 1 Control Room, Rear of North Panel -
Numerous components and connections were not provided with strain relief,
both on
new installations and damaged existing strain relief.   Condition noted on
or about
07/01/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.307(c):  Equipment, wiring methods, and installations of
equipment in
hazardous (classified) locations was not intrinsically safe, approved for
the hazardous
(classified) location, or safe for the hazardous (classified) location:
The following equipment was located in Class I Division II locations:
a- Hovensa Refinery St. Croix, Penex Unit - Cover on the electrical
control panel that
operates equipment ID numbers, C-1925, C-1926 and D-1426 was missing 22 of
the
24 bolts on the front cover.  Condition noted on or about 05/28/09.
b- Hovensa Refinery St. Croix, Unifier Stripper Reboiler Area - Exposed
conductors
were found outside of a vertical conduit near junction cover adjacent to
local
disconnect for P-905. Condition noted on or about 05/28/09.
c- Hovensa Refinery St. Croix, Coker Cutting Shack - Ordinary electrical
light
switches were found in the building.  Condition noted on or about
06/02/09.
d- Hovensa Refinery St. Croix, Gas Con Unit -  Thermojet oil purifier
(equipment #
S3398/SD3398) was being powered with temporarily installed conductors
(including a
plastic bag that covered spliced conductors) strung overhead on beams
across the aisle
originating from a 480V electrical connection plug on column PS7106.
Condition
noted on or about 06/02/09.
e- Hovensa Refinery St. Croix, No.4 Platformer - Air pressure readings on
the three
Instant Air instrumentation cabinets were in the "Low" level on cabinet
number C-
5401A, C-5401B, C-5401C.  Condition noted on or about 05/28/09.
f- Hovensa Refinery St. Croix, Penex Unit - Junction box seal was loose
and not
making a tight fit on the mating surface on P-208-A (Penex charge pump).
Condition
noted on or about 07/06/09.
g- Hovensa Refinery St. Croix, Penex Unit - Lens on light #10 cracked
above the
sample/lab station near column 112.  Condition noted on or about 07/06/09.
h- Hovensa Refinery St. Croix, Penex Unit - Open electrical conduits North
of
column 2060.  Condition noted on or about 07/01/09.
i- Hovensa Refinery St. Croix, Penex Unit Fin Fan Upper Deck - Damaged
light
fixture and open electric connection.  Condition noted on or about
07/01/09.
j- Hovensa Refinery St. Croix, Penex Unit Fin Fan Upper Deck - No cover on
electrical box with exposed wires.  Condition noted on or about 07/01/09.
k- Hovensa Refinery St. Croix, Penex Unit Fin Fan Upper Deck - Light cover
was
not in place with an exposed light bulb.  Condition noted on or about
07/01/09.
l- Hovensa Refinery St. Croix, T-200 Stripper Column - Glass cover and
light
missing on the fixture located at the 28 foot level.  Condition noted on
or about
07/06/09.
m- Hovensa Refinery St. Croix, Area 2 Phase 4 - Open electrical conductors
in an
outlet mounting box on the side of a portable structure TO-319 were
covered with
duct tape that had deteriorated.  Condition noted on or about 07/08/09.
n- Hovensa Refinery St. Croix, Alkylation Unit - Energized wires with
electrical tape
around the ends were protruding from flexible conduit on PD-7210-C
alkylate pump.
Condition noted on or about 07/01/09.
o- Hovensa Refinery St. Croix, Penex Unit - The Trane HVAC unit and
associated
electrical disconnect located outside the Area 1 Control Room was not
rated for use in
the Class I Div II area.  In addition, the metal housing for the HVAC unit
was rusted
with holes evident throughout.  Condition noted on or about 07/06/09.
p- Hovensa Refinery St. Croix, Area 1 Control Room - Engineering controls
such as
but not limited to the building HVAC system failed to maintain a positive
pressure
reading of at least 0.1 inches of water.  Workers were exposed to
fire/explosion
hazards posed by flammable vapors entering through wall openings (bathroom
exhaust, electric conduit) and contacting ordinary electric
wiring/equipment.
Condition noted on or about 07/06/09.
q- Hovensa Refinery St. Croix Area 2 Control Room - Engineering controls
such as
but not limited to the building HVAC system failed to maintain a positive
pressure
reading of at least 0.1 inches of water.  Workers were exposed to
fire/explosion
hazards posed by flammable vapors entering through the control room door,
which
did not fully close and contacting ordinary electric wiring/equipment.
Condition
noted on or about 07/08/09.

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,000 · Current $3,000

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,000

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500 · Current $6,000

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,000 · Current $1,000 Reduced

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500 · Current $1,000 Reduced

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $5,000 · Current $5,000

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500 · Current $1,000 Reduced

Issued

Nov 24, 2009

Abate by

Jan 13, 2010

Penalty

Initial $2,500 · Current $1,000 Reduced