OSHA Inspection: CONOCOPHILLIPS

Issued

Dec 12, 2006

Abate by

Jan 4, 2007

Penalty

Initial $4,500 · Current $3,400 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 hazards of severe thermal burns and skin irritation.
a) On July 1, 2006, at the Trainer Refinery, at the HF Alkylation Unit,
near the
Isostripper Tower, during the start-up of the Unit, a gate valve suffered
a catastrophic
failure in place which released a mixture of hot, scalding condensate,
steam, and an
unknown amount of UltrAmine 120, a severe eye and skin irritant.  One
operator
sustained second degree burns and another operator sustained a sprained
right ankle.  The
primary cause of this incident was a condensation induced water hammer and
the
contributing factors were inadequate procedures, lack of adequate
equipment, and training
to prevent this phenomenon.  On or about 09/14/06.
Abatement Note: Several feasible means to eliminate or materially reduce
this hazard
would include but not be limited to:
a. Regularly inspect and test condensate removal equipment, such as, steam
traps
and drain valves to ensure that they operate properly.  Immediately repair
or
replace erratic steam traps.  Verify that all low points in the steam
systems have
steam traps.  Valves in the pipelines that lack properly positioned steam
traps
should remain open at all times or be removed from the piping system.
b. Provide both managers and operators with training concerning the
development
of condensation-induced water hammers, its potential impact on steam
systems,
design and operational preventions, and the expected operator response to,
and
how to prevent its occurrence.
c. Modify start-up operating and maintenance procedures to include the
adequate
drainage of condensate system.  Before opening valves in steam lines and
inducting steam into the piping, operators should verify that water
(condensate)
has been removed, adequate placement of the steam traps, and the adequate
operation of the steam traps.
d. Modify remaining steam systems to ensure low point drains are not
compromised by the addition of chemical injection points.
e. Modify shutdown operating procedures to ensure the isolation of chemical
injection systems.
b) Throughout the Trainer Refinery, the employer did not regularly inspect
the low
pressure steam pipe support systems.  On July 1, 2006, during the start up
of the HF
Alkylation Unit, a gate valve suffered a catastrophic failure in place and
released hot
condensate, steam, and an unknown amount of UltrAmine 120, a eye and skin
irritant
and corrosion inhibitor.  One operator sustained second degree burns and
the other
operator sustained a sprained right ankle.  The root cause of the incident
wascondensation-induced water hammer; however, pipe spring hanger SH-188
was tilted and
it only provided approximately 60of the intended piping load.  This pipe
support was
tilted before the incident and was located directly upstream of the gate
valve that failed.
Therefore when the valve fractured the pipe shifted and fell exposing
employees to
impact and crushing injuries.
Abatement Note: A feasible means to eliminated or materially reduce this
hazard:
a. Perform regular inspections of the low pressure steam pipe support
systems as
described in ASME B31.1-2001.
NOTE:  ABATEMENT DOCUMENTATION REQUIREDATION

Issued

Dec 12, 2006

Abate by

Dec 25, 2006

Issued

Dec 12, 2006

Abate by

Dec 25, 2006