OSHA Inspection: EXXONMOBIL BILLINGS REFINERY

Issued

Feb 19, 2010

Abate by

Mar 9, 2010

Penalty

Current $3,000

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D) The employer did not develop and implement
written operating
procedures that provide clear instructions for safely conducting
activities involved in each
covered process consistent with the process safety information and
addresses the steps for
conducting emergency shutdown including the conditions under which
emergency
shutdown
is required to ensure that emergency shutdown is executed in a safe and
timely manner:
a. On or about December 3, 2009 and at times prior thereto, ExxonMobil
Billings Refinery,
700 ExxonMobil Road, Billings, MT, did not develop and implement written
emergency
shutdown procedures that provide clear instructions for safely conducting
emergency
shutdown of the Crude Unit.
b. On or about December 3, 2009 and at times prior thereto, ExxonMobil
Billings Refinery,
700 ExxonMobil Road, Billings, MT, did not develop and implement written
emergency
shutdown procedures for fire emergencies that include the conditions
requiring emergency
shutdown of the Crude Unit.
c. On or about December 3, 2009 and at times prior thereto, ExxonMobil
Billings Refinery,
700 ExxonMobil Road, Billings, MT, did not develop and implement written
emergency
shutdown procedures that provide clear instructions which include
conditions to prevent
overfilling of the D-4 Blowdown Drum.
One feasible means of abatement would be for the employer to develop and
implement
written operating procedures for emergency shutdown of the crude unit and
include in these
procedures the conditions for requiring emergency shutdown of the crude
unit during fire
emergencies and for preventing overfilling of the D-4 Blowdown Drum.  One
means of
preventing overfilling of the D-4 Blowdown Drum would be to include
procedures which
require emergency shutdown of the crude unit and stoppage of quench water
flow into D-4
when CRP400 reads a pre-established pressure, such as 15 psig.  For all
three instances,
crude unit employees are exposed to fire and explosion hazards due to the
potential for
release of hydrocarbons.

Issued

Feb 19, 2010

Abate by

Mar 9, 2010

Penalty

Initial $12,500

Issued

Feb 19, 2010

Abate by

Mar 9, 2010

Penalty

Initial $2,500 · Current $1,750 Reduced

General-duty citation text

29 CFR 1910.119(f)(3) The employer did not review operating procedures as
often as
necessary to assure that they reflect current operating practice:
(a) On or about December 3, 2009 and at times prior thereto, ExxonMobil
Billings Refinery, 700 ExxonMobil Road, Billings, MT, did not review the
Emergency
Procedures in Section 8 of the Crude Operating Manual to assure that the
table for the
furnace shutdown causes for low crude charge flow in Section 14 reflect
current operating
practice.  Crude Unit employees are exposed to fire and explosion hazards
as a result of
inaccurate safety information for the furnaces.
One feasible means of abatement would be to ensure that operating
procedures are reviewed
as often as necessary to assure they accurately reflect current operating
practice.

Issued

Feb 19, 2010

Abate by

Mar 24, 2010

Penalty

Initial $2,500 · Current $3,000

General-duty citation text

29 CFR 1910.119(f)(4) The employer did not develop and implement safe work
practices for
the control of hazards during operations:
a. On or about November 20, 2009 and at times prior thereto, ExxonMobil
Billings
Refinery, 700 ExxonMobil Road, Billings, MT, did not develop and implement
a safe work
practice for the control of fire and explosion hazards during operations
associated with the
potential for coexistence of flammable vapors and ignition sources, such
as vehicles and
equipment with internal combustion engines, used in Class 1, Division 2,
Group D classified
locations along F Avenue near D-208 and D-202, and 4th Street near R-400
and 401.
Employees are exposed to fire and explosion hazards.
b. On or about November 20, 2009 and at times prior thereto, ExxonMobil
Billings
Refinery, 700 ExxonMobil Road, Billings, MT, did not develop and implement
a safe work
practice for the control of fire and explosion hazards during operations
associated with the
potential for coexistence of flammable vapors and ignition sources, such
as vehicles and
equipment with internal combustion engines, used in Class I, Division 2,
Group D locations
within the Crude Unit process area. Employees are exposed to fire and
explosion hazards.
One feasible means of abatement would be to develop and implement a safe
work practice
which includes installing flammable vapor detectors in hazardous
classified locations in these
process units which would continuously monitor for flammable vapors and
effectively notify
employees of the existence of flammable vapors.  In the event flammable
vapors are
detected, employees would be required to prevent the entry of ignition
sources, such as
vehicles and equipment with internal combustion engines, into the
hazardous location and
eliminate ignition sources in the hazardous location that they are
currently using.  Such
detectors could also serve to warn employees using open flame type
ignition sources during
hot work activities.

Issued

Feb 19, 2010

Abate by

Mar 9, 2010

Penalty

Initial $2,500 · Current $3,000

General-duty citation text

29 CFR 1910.119(l)(2)(i)  The pre-startup safety review did not confirm
prior to the
introduction of highly hazardous chemicals to a process that construction
and equipment was
in accordance with design specifications:
(a) On or about November 4, 2009 and at times prior thereto, ExxonMobil
Billings Refinery,
700 ExxonMobil Road, Billings, MT, did not confirm that the two vent
valves for safety
valve SV-108 in the crude unit were car-sealed open and painted yellow
prior
to the
introduction of highly hazardous chemicals to the process.  The employer's
procedures
require vent valves on safety valves to be car-sealed open and painted
yellow. Crude unit
employees were exposed to fire and explosion hazards due to the potential
for closure of
these vent valves.
(b) On or about October 27, 2009 and at times prior thereto, ExxonMobil
Billings Refinery,
700 ExxonMobil Road, Billings, MT, did not confirm that the double seal
installation for the
P-401 crude oil pump was installed in accordance with its design
specifications.  The seal pot
did not have a level gauge indicator connected to the Bently Nevada Alarm
as shown on the
design drawing (Drawing 001-300-0158) for a Type II seal system.

Issued

Feb 19, 2010

Abate by

Mar 9, 2010

General-duty citation text

29 CFR 1910.119(l)(2)(ii)  The pre-startup safety review did not confirm
prior to the
introduction of highly hazardous chemicals to a process that safety,
operating, maintenance,
and emergency procedures are in place and adequate:
(a) On or about November 4, 2009 and at times prior thereto, ExxonMobil
Billings Refinery,
700 ExxonMobil Road, Billings, MT, did not confirm that safety and
operating procedures
were in place and adequate for the crude charge safety valve (SV-108).
The operator's car-
seal checklist procedure (i.e. SAT Intellatrac) identifies only one vent
valve for this safety
valve needing car-sealed open when there are two vent valves.  Crude unit
employees were
exposed to fire and explosion hazards due to the potential for closure of
these vent valves for
this safety valve.
One feasible means of abatement would be for the employer to confirm,
prior to the
introduction of highly hazardous chemicals, that safety, operating,
maintenance, and
emergency procedures are in place and adequate.

Issued

Feb 19, 2010

Abate by

Mar 24, 2010

Penalty

Initial $2,500 · Current $3,000

General-duty citation text

29 CFR 1910.178(c)(2)(iv) Power-operated industrial trucks which were not
designated
as
DY, EE, or EX were being used in locations where volatile flammable
liquids or flammable
gases are handled, processed or used, but in which the hazardous liquids,
vapors or gases
will normally be confined within closed systems from which they can escape
only in case of
accidental rupture or breakdown of such systems, or in case of abnormal
operation of
equipment:
a) On or about November 19, 2009 and at times prior thereto, ExxonMobil
Billings
Refinery, 700 ExxonMobil Road, Billings, MT, used power-operated
industrial trucks not
designated as DY, EE, or EX to deliver liquids and chemicals into
locations within the crude
unit and the hydrocracker unit where volatile flammable liquids or
flammable gases are
handled, processed or used, but in which the hazardous liquids, vapors or
gases will
normally be confined in closed systems from which they can escape only in
case of
accidental rupture or breakdown of such systems, or in case of abnormal
operation of
equipment.  Employees are exposed to fire and explosion hazards due to the
potential for the
truck to cause ignition of a flammable vapor or gas in the location.
One feasible means of abatement would be to use either EE or EX designated
power-operated
industrial trucks to deliver liquids/chemicals within these locations when
feasible.

Issued

Feb 19, 2010

Abate by

Feb 24, 2010

Penalty

Initial $2,125 · Current $1,750 Reduced

General-duty citation text

29 CFR 1910.305(g)(1)(iv)[A]  Unless specifically permitted otherwise in
paragraph (g)(1)(ii)
of this section, flexible cords and cables may not be used as a substitute
for the fixed wiring
of a structure:
(a) On or about November 3, 2009 and at times prior thereto, ExxonMobil
Billings Refinery,
700 ExxonMobil Road, Billings, MT, ran a flexible cord through a wall near
the southeast
corner of the mechanical shop to recharge a Tennant sweeper battery using
115
volt power.
The cord was also used as a substitute for the fixed wiring of the
mechanical shop building.
Employees were subject to electrical shock or electrocution hazards.
One feasible means of abatement would be to install permanent electrical
receptacles to
power the electrical equipment in accordance with the most current edition
of the National
Electrical Code.
(b) On or about November 3, 2009 and at times prior thereto, ExxonMobil
Billings Refinery,
Company, 700 ExxonMobil Road, Billings, MT, ran a flexible cord through a
wall near the
southeast corner of the mechanical shop to connect a 115 volt relocatable
power tap.  Such
power tap provided power for an oxygen analyzer and other electrical
equipment. The
flexible cord was being used as a substitute for the fixed wiring of the
mechanical shop
building. Employees were subject to electrical shock or electrocution
hazards.
One feasible means of abatement would be to install permanent electrical
receptacles to
power the electrical equipment in accordance with the most current edition
of the National
Electrical Code.

Issued

Feb 19, 2010

Abate by

Feb 24, 2010

General-duty citation text

29 CFR 1910.305(g)(1)(iv)[B]  Unless specifically permitted otherwise in
paragraph (g)(1)(ii)
of this section, flexible cords and cables may not be run through holes in
walls, ceilings, or
floors:
(a) On or about November 3, 2009 and at times prior thereto, ExxonMobil
Billings Refinery,
700 ExxonMobil Road, Billings, MT, ran a flexible cord through a wall near
the southeast
corner of the mechanical shop to recharge a Tennant sweeper battery using
115 volt power.
Employees were subject to electrical shock or electrocution hazards.
One feasible means of abatement would be to install permanent electrical
receptacles
to
power the electrical equipment in accordance with the most current edition
of the National
Electrical Code.
(b) On or about November 3, 2009 and at times prior thereto, ExxonMobil
Billings Refinery,
700 ExxonMobil Road, Billings, MT, ran a flexible cord through a wall near
the southeast
corner of the mechanical shop to connect a 115 volt relocatable power tap.
Such power tap
provided power for an oxygen analyzer and other electrical equipment.
Employees were
subject to electrical shock or electrocution hazards.
One feasible means of abatement would be to install permanent electrical
receptacles to
power the electrical equipment in accordance with the most current edition
of the National
Electrical Code.

Issued

Feb 19, 2010

Abate by

Feb 24, 2010

Issued

Feb 19, 2010

Abate by

Mar 24, 2010

Penalty

Current $3,000

General-duty citation text

29 CFR 119(f)(1)(iv) The employer did not develop and implement written
operating
procedures that provide clear instructions for safely conducting
activities involved in each
covered process consistent with the process safety information and
addresses safety systems
and their function:
(a) On or about December 3, 2009 and at times prior thereto, ExxonMobil
Billings Refinery,
700 ExxonMobil Road, Billings, MT, did not develop and implement written
operating
procedures which safely address the safety system and its function for the
reclassification of
the Crude Unit Shelter from a Class I, Div. 2 location to an unclassified
location by
maintaining a positive ventilation pressure of at least 0.10 inches of
water inside the shelter
and alarming at an occupied location when such pressure is insufficient.
Interim safety
procedures were not included to prevent employee exposure to Class 1,
Division 2, Group D
hazards while the ventilation pressure is insufficient (e.g., while
waiting for the HVAC
repair). Employees in the shelter are exposed to fire and explosion
hazards due to the
reclassification of the shelter to a Class I, Div. 2 location when the
positive pressure is
insufficient.
One feasible means of abatement would be for the employer to include in
their written
operating procedures a description of the safety system and its function
for the positive
pressure ventilation and alarm system in the Crude Unit shelter and
address alternative
measures to protect employees in the shelter when such positive pressure
is insufficient.

Issued

Feb 19, 2010

Abate by

Feb 24, 2010

Penalty

Initial $1,000 · Current $1,500

General-duty citation text

29 CFR 1904.4(a) The employer, who was required to keep records of
fatalities, injuries and
illnesses, did not record each fatality, injury and illness that:
(1) Is work-related; and
(2) Is a new case; and
(3) Meets one or more of the general recording criteria of 29 CFR 1904.7:
(a) ExxonMobil Billings Refinery, 700 ExxonMobil Road, Billings, MT, did
not record the
injury of an employee's left knee on their OSHA 300 forms, or equivalent
forms, for 2008
or by August 31, 2009.  The employee's first injury incident occurred on
May 5, 2008, with
a potential aggravation of the injury occurring on December 15, 2008. The
employee
underwent surgery on or about May 18, 2009 for the injury.