OSHA Inspection: CONOCOPHILLIPS BAYWAY REFINERY

Issued

Apr 30, 2008

Abate by

Jun 13, 2008

Penalty

Initial $2,125

General-duty citation text

29 CFR 1910.23(e)(7)(iii):  Floor opening covers were used in which the
cover projected
more than 1 inch above the floor level without all edges chamfered to an
angle with the
horizontal of not more than 30 degrees :
a) ABW, First Level between D7 and D8 West Bank - Workers were exposed to
tripping hazards when walking on/over plywood and wooden planks, 3.75
inches in
height, installed over the metal platform.  Condition noted on or about
02/07/08.

Issued

Apr 30, 2008

Abate by

Aug 30, 2008

Penalty

Initial $2,125 · Current $1,400 Reduced

General-duty citation text

about
03/06/08.
Abatement Note
The minimum clearance distance on the climbing side of a fixed ladder at a
pitch of 90
degrees shall be 30 inches.

Issued

Apr 30, 2008

Abate by

May 5, 2008

Penalty

Initial $2,125 · Current $1,400 Reduced

General-duty citation text

1910.103(b)(1)(iv)(f):  Mobile hydrogen supply units were not electrically
bonded to the
system before discharging hydrogen:
a) 2PF - Two Praxair hydrogen trailers were inadequately grounded when
used to
dispense hydrogen needed for unit operations.  Condition noted on or about
02/25/08.

Issued

Apr 30, 2008

Abate by

May 5, 2008

Penalty

Initial $5,000 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.106(b)(2)(iv)(a):  Atmospheric storage tanks were not
adequately vented to
prevent the development of vacuum or pressure sufficient to distort the
roof of a cone roof
tank or exceeding the design pressure in the case of other atmospheric
tanks as a result of
filling or emptying, and atmospheric temperature changes:
a) FGBW - On or about 11/6/07 workers were filling the newly repaired TK3
20,000
gallon atmospheric storage tank with methanol when a build up of pressure
set off the
high level alarm and bulged the tank bottom.  It was found that a solid
blank was
installed on top of the tank instead of the approved PV device.d

Issued

Apr 30, 2008

Abate by

Jun 13, 2008

Penalty

Initial $5,000 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.106(c)(4):  Piping systems were not substantially supported
and protected
against physical damage and excessive stresses arising from settlement,
vibration, expansion,
or contraction:
a) 2PF - The steel support under the 14 in. elbow for the PF85 control
valve had
corroded leaving the elbow unsupported.  Condition noted on or about
01/16/08.
b) 2PF - Inlet piping on the E101F was inadequately supported in that the
welds on
the spring can supporting the 8 in. piping were broken.  Condition noted
on or about
01/16/08.
c) ABW - Two vertical steel beams had corroded near their concrete pads
north
of
DR1.  Condition noted on or about 02/28/08.
d) ABW - The horizontal steel beam above P7 was substantially corroded
with a large
rusted out section in the middle of the beam.  Condition noted on or about
02/28/08.

Issued

Apr 30, 2008

Abate by

Dec 31, 2008

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D):  Process safety information pertaining to the
technology of the
process did not include safe upper and lower limits for such items as
temperatures, pressures,
flows or compositions:
a) 2PF - The employer did not develop safe operating limits beyond which
the
operation of equipment or a process could result in an unsafe condition or
a
catastrophic release of a highly hazardous chemical.  Examples include but
are not
limited to:
1) Absorber Stripper Column (T101X), Debuntanizer Tower (T103) and
C3/C4 Splitter (T107) did not have written defined safe limits of pressure,
temperature or level defined for their safe operation,
2) C3/C4 Splitter Surge Drum (D110) did not have a safe limit for pressure.
Condition noted on or about 03/03/08.

Issued

Apr 30, 2008

Abate by

Dec 31, 2008

General-duty citation text

29 CFR 1910.119(d)(2)(i)(E):  Process safety information pertaining to the
technology of the
process did not include an evaluation of the consequences of deviations,
including those
affecting the safety and health of employees:
a) 2PF - The employer did not develop consequences of deviation if safe
upper and
lower limits for pressure, temperature and/or level were exceeded which
could
result
in an unsafe condition or a release of a highly hazardous chemical from
process
equipment to include but not limited to the Absorber Stripper Column
(T101X),
Debutanizer Tower (T103), C3/C4 Splitter (T107) and C3/C4 Splitter Surge
Drum
(D110).  Condition noted on or about 03/03/08.

Issued

Apr 30, 2008

Abate by

May 5, 2008

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)  2PF - The employer failed to develop P&IDs which accurately
represented the
following equipment for the process:
1- T109 inlet block valve for one of the three safety valves (2992) was
chain
and blocked closed with the P&ID indicating that it was supposed to be car
sealed open,
2- Butterfly valve for the cold water line to D118 was to be car sealed
open
but was missing the car seal in the field,
3- PT50, the hot relief high temperature alarm, was listed as a critical
instrument on the P&ID but was not in the critical instrument program,
4- Slop sphere 59 safety valves 2172 and 2173 were missing identification
tags,
5- E103 and E106 were not clearly marked on the unit,
6- J101 safety valve was marked with the wrong number and pressure on the
P&ID (2995 on the P&ID vs. 5789 on the unit),
7- Only one hydrogen trailer hook-up was noted on the P&ID when two
trailers were connected in the field,
8- MOVs PA117A and PA118A were not listed on the P&ID,
9- D115 was missing a tag for safety valve 3821.
Conditions noted on or about 12/11/07 - 04/02/08.

Issued

Apr 30, 2008

Abate by

Dec 31, 2008

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
(REGAGEP):
a) 2PF - The employer failed to protect employees inside the operator
shelter which
was potentially exposed to overpressure hazards of up to 3 psi as a result
of a vapor
cloud explosion.  The 2004 facility siting analysis did not identify the
building
as
exceeding the occupancy criteria and no further action was taken.
However, the
employer failed to conduct an in depth occupancy load analysis at the unit
instead
relying solely on a study performed at their Trainer, PA refinery.
Employees
working within the structure were not protected through mitigation
measures to
include strengthening doorways, reinforcing walls, relocating personnel or
rearranging
room functions within the building.  Condition noted on or about 01/18/08.
Abatement Note
OSHA does not accept occupancy criteria evaluations (see API 752, Section
2.5.2)
as the basis for an employer's determination that adequate protection has
been
provided for employees in occupied structures which employer's have
identified
as being potentially subject to explosions, fires, ingress of toxic
materials or high
energy releases.
b) PPBW - The employer did not comply with API 753 Section 3 when it
failed to
protect employees inside a wooden trailer being used as an operator
shelter that was
placed within the 1 psi overpressure zone.  Condition noted on or about
01/22/08.
c) 2PF - The employer did not comply with ASME Boiler and Pressure Vessel
Code,
Division 1 (BPVC), Section VIII, UG-135(d) when it failed to provide
adequate
controls to ensure that the block valve for safety valve 2992 on T109
remained in the
open position.  Condition noted on or about 03/07/08.
d) 2PF - The employer did not comply with NFPA 496 Section 7.4.1 in that
the air
curtain on the West 1 door was measured at negative 342 feet per minute
(FPM).  A
minimum reading of 60 FPM must be maintained through all openings.  In
addition,
although exceeding a minimum outward velocity in excess of 60 FPM the air
curtains
on doors North 2 and 3 were disabled and not functioning.  Condition noted
on or
about 03/06/08.
e) ABW - Illumination of means of egress as required by NFPA 101 Section
7.8.1
was not adequately maintained throughout the unit.  Employees were exposed
to  slip,
trip and fall hazards while climbing stairs and ladders during the course
of work
operations.  Condition noted on or about 02/12/08.
f) ABW - The process sewer to include the catch basin and lateral piping
under the
Isobutane Receiving Drum (D18) were damaged.  In the case of a release,
isobutane
would pool in the area and not be effectively transported via the process
sewer
exposing workers to fire hazards.  Condition noted on or about 03/06/07.

Issued

Apr 30, 2008

Abate by

Sep 30, 2008

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(e)(3)(iii):  The process hazard analysis did not address
the engineering and
administrative controls applicable to the hazards and their
interrelationship,
such as,
appropriate application of detection methodologies to provide early
warning of releases:
a) 2PF - The PHA performed in 2006 did not address the lack of
fireproofing on
piperack supports located in close proximity to process equipment such as
but not
limited to pumps which have the potential for hydrocarbon leaks resulting
in pool
fires.  Condition noted on or about 02/27/08.
b) 2PF - The 2006 PHA did not address critical instruments that were
overdue for
inspection to include but not limited to the C103 seal oil overhead o/h
tank level
alarm (PC70A) and C3/C4 splitter feed high level alarm for D110 (PL14).  In
addition, PT050, the hot relief high temperature alarm on the D118 water
disengaging
drum was removed from the critical instrument program.  Condition noted on
or
about 01/02/08.

Issued

Apr 30, 2008

Abate by

Sep 30, 2008

General-duty citation text

29 CFR 1910.119(e)(3)(v):  The process hazard analysis did not address
facility siting:
a) 2PF - The PHA performed in 2006 did not address the location of a
piperack
containing hydrogen, benzene, naphtha and butane found to be within 22 ft.
of the
operator shelter.  Leakage or failure of such piping could expose workers
in the
shelter to fire hazards and limit their ability to properly shutdown the
unit.  Condition
noted on or about 02/07/08.
b) 2PF - The 2006 PHA did not address the discharge of flammable gasses to
include
but not limited to butane, propane and naphtha from the stack of the D118
Atmospheric Blowdown Drum which could impact the Dryer Reactivatioin Gas
Furnace (F107) and Operator Shelter located some 43 ft. and 91 ft. away,
respectively.  Condition noted on or about 02/07/08.

Issued

Apr 30, 2008

Abate by

Aug 30, 2008

General-duty citation text

29 CFR 1910.119(e)(3)(vi):  The process hazard analysis did not address
human factors:
a) 2PF - The PHA performed in 2006 did not address the hazard of operating
the
E101 I/J isolation valve during emergency conditions.  Workers have to
climb stairs
and/or a ladder to operate the gate valve which is located on the 2nd
floor platform.
Condition noted on or about 02/27/08.
b) 2PF - The 2006 PHA did not address the hazard of operating difficult to
access
valves to include the gate valve to bypass E101G/H and block valve for
PP91.
Workers could be exposed to fall hazards of 23-45 ft. to the ground below
when
opening/closing the above noted valves.  Condition noted on or about
03/06/08.
c) 2PF - The 2006 PHA failed to consider unmarked equipment on the unit to
include
exchangers and safety relief valves which could lead to confusion by
operators and/or
contractors.  Condition noted on or about 12/11/07.
d) 2PF, E158 - The 2006 PHA did not consider overhead hazards when
employees
were climbing fixed ladders.  An 8 in. pipeline, 13 ft. above the ground,
was located
within 24 inches of the climbing side of the ladder.  Condition noted on
or about
03/06/08.
e) 2PF - The 2006 PHA failed to consider the hazard of using machinery to
include
but not limited to powered industrial trucks, backhoes and aerial lifts in
close
proximity to process equipment which can be struck/damaged with the
potential
release of highly hazardous chemicals.  Condition noted on or about
03/17/08.

Issued

Apr 30, 2008

Abate by

Sep 8, 2008

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(e)(5):  The employer failed to establish a system to
promptly address the
process hazard analysis team's findings and recommendations and to assure
that the
recommendations were resolved in a timely manner:
Category II (medium) and Category III (significant) risks were not
resolved in a
timely manner with Category II recommendations completed within 5 years
and
Category III findings resolved within 3 years.  This time frame developed
by the
employer did not meet OSHA and industry standards.  In addition, some PHA
recommendations were not completed within their assigned completion dates.
PHA
recommendations that remained open at the time of the inspection included
but were
not limited to:
a) Flare Grid PHA, Action Item 78050, Cat III, Audit Date 02/08/05,
Finding -
Potential for sulfur buildup and back pressure in flare grid.  Action -
Install rupture
disks per Process Specification 2007-13.  Condition noted on or about
04/16/08.
b) ABW PHA, Action Item 70565, Cat II, Audit Date 06/02/04, Findings - The
P-36
appears to have difficulty in pumping light hydrocarbons.  A procedure
exists to
bypass D-36 to use nitrogen pressure to help pump the material, but it
takes time to
make the lineup.  Action - Consider whether modification/replacement of
P-36 is
required to enable pumping of light hydrocarbon from the ABW flare KO drum
D-36.
Condition noted on or about 02/28/08.
c) ABW PHA, Action Item 70629, Cat II, Audit Date 06/02/04, Findings -
Since the
D-3 EIV is greater than 8-inch size, a power operated EIV is recommended
per API
553.  The D-3 EIV is located at a distance greater than 25 feet from the
P-3 seal,
therefore a Type CE EIV is adequate.  Action - Consider motorizing the
existing 12-
inch EIV under D-3 to a Type C.  Condition noted on or about 03/07/08.
d) 2PF PHA, Action Item 66914, Cat II, Audit Date 09/25/06, Finding - No
Flow-
Outlet valve of E-122 Stabilizer Reflux Condenser closed.  Action -
Consider car-
sealing open inlet and outlet valves of E-122 Stabilizer Reflux Condenser.
Condition
noted on or about 02/27/08.
e) 2PF PHA, Action Item 66754, Cat III, Audit Date 09/25/06, Finding -
PL56 open
more than required.  Potential decreased level in D-114 Powerformate
Splitter Feed
Surge Drum potential cavitation of P-123A/B Powerformate Splitter Feed
Pumps.
Action - Consider providing independent high and low level alarms on D-114
Powerformate Splitter Feed Surge Drum.  Condition noted on or about
04/16/08.
f) FCAT PHA, Action Item 70038, Cat II, Audit Date 09/08/03, Finding - The
distance to the isolation valve is less than 25 feet from the
pumps/compressors and the
inventory in the drum is greater than 2,000 gallons of light ends.
Recommendation -
Consider upgrading the D-1 Suction Drum and D-301 Suction Drum isolating
bottom
valves from type A to type D.  Condition noted on or about 12/11/07.

Issued

Apr 30, 2008

Abate by

Aug 30, 2008

Penalty

Initial $5,000 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(ii):  The employer did not inform contract employers
of the known
potential fire, explosion, or toxic release hazards related to the
contractor's work and the
process:
a) 2PF, C103 Compressor Building - On or about 11/27/07 contractors
performing
welding operations ignited flammable gas emitted from the C103 dirty seal
oil
demister vent.

Issued

Apr 30, 2008

Abate by

Aug 30, 2008

General-duty citation text

29 CFR 1910.252(a)(1)(ii) or in the alternative 29 CFR 1926.352(b):  When
the object to be
welded or cut could not be moved and all the fire hazards could not be
removed,  guards were
not used to confine the heat, sparks, and slag to protect the immovable
fire hazards:
a) 2PF, C103 Compressor Building - On or about 11/27/07 contract employees
performing welding operations ignited flammable gas emitted from the C103
dirty seal
oil demister vent.ter

Issued

Apr 30, 2008

Abate by

Jun 13, 2008

Penalty

Initial $5,000 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(iv):  The employer did not develop and implement
safe work
practices consistent with 29 CFR 1910.119(f)(4), to control the entrance,
presence and exit of
contract employers and contract employees in covered process areas:
a) Facility Wide - Contractor supervisors were allowed to sign for work
permits at
unit control houses but individual employees on the work crew remained
unaccounted
for at process units.  Condition noted on or about 11/09/07.

Issued

Apr 30, 2008

Abate by

May 5, 2008

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(j)(4)(i):  Inspections and tests were not performed on
process equipment to
maintain its mechanical integrity:
a) 2PF - PT50, the hot relief high temperature alarm on the D118 water
disengaging
drum was mistakenly removed from the critical instrument program.  The
critical
instrument had not been inspected since 2003.  Condition noted on or about
01/02/08.

Issued

Apr 30, 2008

Abate by

May 5, 2008

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:
a) 2PF, Slop Sphere 53 - On 10/04/06 safety valve 2113 failed to pop at
its set
pressure due to fouling.  The valve was repaired and returned to service
with the
same 6 year inspection frequency.  API 510 6.6.2.3 requires that when a
pressure
relieving device is heavily fouled the inspection interval shall be
reduced.  Condition
noted on or about 02/11/08.

Issued

Apr 30, 2008

Abate by

Sep 30, 2008

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 (defined by the process safety information in
paragraph (d) of this
section) before further use or in a safe and timely manner:
a) 2PF - Workers were unable to take readings on T109 and T104 using gage
glasses
which were not maintained in a clean/readable condition.  Condition noted
on or
about 02/07/08.
b) 2PF - The supports for the E101G/H and E116 Exchangers were visibly
deteriorated with concrete spalled off exposing reinforcing steel.
Condition noted on
or about 11/06/07.
c) 2PF - Fireproofing insulation was removed from conduits powering EIVs
PA117
and PA118 when EIV motors were replaced in 2004.  The fireproofing was
never
replaced and continued to fail critical instrument inspections.  Condition
noted on or
about 01/16/08.
d) HDBW - Workers were unable to take readings on D203 using the gage glass
which was not maintained in a clean/readable condition.  Condition noted
on or about
02/07/08.

Issued

Apr 30, 2008

Abate by

May 5, 2008

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) 2PF - An MOC was not performed for modified spectacle blinds used for
the E101
shell side block valves.  The blinds have been in use since 2004.
Condition note on
or about 12/17/07.
b) 2PF - An MOC was not performed for fireproofing insulation removed from
conduits powering EIV PA 117 and EIV PA 118.  The fireproofing was removed
when the EIV motor operators were replaced in 2004.  Condition noted on or
about
01/16/08.
c) 2PF - An MOC was not performed when process stopped opening bypasses on
regs. PP65V and PP66V during reactor regeneration procedures - Section
2.5.1.05,
Action 7, Step 13.  Condition noted on or about 02/05/08.
d) 2PF - An MOC was not performed when PT50, the hot relief header high
temperature alarm on the D118 water disengaging drum was removed from the
critical instrument program.  The critical instrument had not been
inspected since
2003.  Condition noted on or about 01/02/08.
e) Facility Wide - The employer did not implement procedures addressing
time
limitations on temporary changes.  The following MOCs were found to have
gone
past their expiration dates:
1- MOC 20060366, expired 01/01/07, closed 03/28/07,
2- MOC 20060374, expired 01/01/07, closed 03/28/07,
3- MOC 20060437, expired 10/31/06, closed 12/06/06,
4- MOC 20070053, expired 03/14/07, closed 03/29/07,
5- MOC 20070056, expired 03/08/07, closed 03/29/07,
6- MOC 20070068, expired 03/01/07, closed 03/23/07,
7- MOC 20076070, expired 03/06/07, closed 03/29/07,
8- MOC 20070095, expired 03/05/07, closed 04/04/07,
9- MOC 20070118, expired 03/15/07, closed 03/22/07,
10- MOC 20070225, expired 05/10/07, closed 06/13/07,
11- MOC 20070688, expired 12/07/07, closed 12/10/07,
12- MOC 20070706, expired 12/11/07, closed 12/20/07,
13- MOC 20070726, expired 12/17/07, closed 12/31/07.

Issued

Apr 30, 2008

Abate by

May 5, 2008

General-duty citation text

29 CFR 1910.119(f)(3):  The operating procedures were not reviewed as
often as necessary
to assure that they reflect current operating practice, including changes
that result from
changes in process chemicals, technology, and equipment, or changes to
facilities:
a) 2PF - Action 7 of Step 13 in Section 2.5.1.05 was not removed from the
operating
and equipment procedures after process stopped opening bypasses on regs.
PP65V
and
PP66V during reactor regeneration.  Condition noted on or about 02/05/08.

Issued

Apr 30, 2008

Abate by

May 5, 2008

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(m)(3):  The incident investigation team did not consist of
at least one
person knowledgeable in the process involved, including a contract
employee if the incident
involved work of the contractor, and other persons with appropriate
knowledge and
experience to thoroughly investigate and analyze the incident:
a) 2PF, C103 Compressor Building - On or about 11/27/07 LG Constructors,
Inc.
employees performing welding operations ignited flammable gas emitted from
the
C103 dirty seal oil demister vent.  A representative from the contractor
was not
initially included on the investigation team.

Issued

Apr 30, 2008

Abate by

Jun 13, 2008

Penalty

Initial $2,975

General-duty citation text

29 CFR 1910.219(c)(2)(i):  Exposed part(s) of horizontal shafting were not
protected by
stationary casing(s) enclosing shafting completely or by trough(s)
enclosing sides and top or sides
and bottom of shafting:
a) ABW, West Bank Platform - Workers were exposed to inadequately guarded
horizontal shafts on alkylation mixers in that their metal guards did not
fully enclose
motor shafts.  Condition noted on or about 11/07/07.

Issued

Apr 30, 2008

Abate by

Jun 13, 2008

General-duty citation text

29 CFR 1910.219(i)(2):  Revolving surfaces of shaft coupling(s) were not
covered by a safety
sleeve:
a) ABW, West Bank Platform - Workers were exposed to inadequately guarded
shaft
couplings on alkylation mixer motors.  Condition noted on or about
11/07/07.

Issued

Apr 30, 2008

Abate by

May 5, 2008

Penalty

Initial $2,125

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) East Side, VPP Tag 2753 - Transformer box (high voltage 480, low
voltage 120/240
was rotted out exposing workers to live parts.  Condition noted on or
about 11/07/07.
b) FCC Fractionator, VPP Tag 1559 - Two covers missing on conduit with
exposed
120V wires.  Condition noted on or about 02/27/08.
c) FCC Steam Gen, VPP Tag 981 - Electrical fittings for 120V wires missing
covers.
Condition noted on or about 02/27/08.
d) ISOM, VPP Tag 1949 - Cover broken on an electrical fitting with exposed
120V
wires.  Condition noted on or about 02/28/08.
e) ISOM, VPP Tag 2056 - Cover missing from tee with exposed 120V wires.
Condition
noted on or about 02/28/08.

Issued

Apr 30, 2008

Abate by

May 5, 2008

Penalty

Initial $5,000 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.307(b):  Equipment, wiring methods, and installations of
equipment in
hazardous (classified) locations were not intrinsically safe, or approved
for the hazardous
(classified) location, or safe for the hazardous (classified) location:
a) 2PF - Workers were exposed to equipment which was not intrinsically
safe or
approved for Class I, Division 2 locations.  The explosion proof
illuminator for the
T109 gage glass was in disrepair, missing both its cover and glass
housing.  In
addition, a broken lamp was still in place in the socket assembly.
Condition noted on
or about 02/07/08.