OSHA Inspection: CALCASIEU REFINING CO.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D): Process safety information pertaining to the
technology of the
process does not always include the safe upper and lower limits for such
items as temperatures,
pressures, flows or compositions:
(a) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer had not updated and documented, as part of the process safety
information,
the operating limits of the equipment for the #2 Crude Unit. Operators
reviewing this
information could not utilize the information to accurately meet process,
safe upper and
lower limits. These operating limits include safe upper and lower
temperatures and flow
rates such as;
(1) The overhead #2 unit naphtha & exchangers E-215 and E-1N1-These were
not listed
in the process safety information provided. This section had been left
blank.
(2) The #2 Unit Kerosene Exit & Tray - The upper and lower operating
temperature
limits had been left blank in the process safety information provided.
(3) The #2 Crude Unit Diesel Exit of the Tower - The values of lower and
upper
operating temperature had changed. The process safety information provided
have listed
500 F and it is presently established at 520 F. The upper limit was
labeled as 530 F and
it is presently established at 560 F.
(4) The #2 Unit Unstabilized Naphtha Draw to Treating (flow in BPD) - The
process
safety information provided shows the upper limit was depicted as 3,500
BPD and it is
presently 5,500 BPD.
(5) The #2 Unit Kerosene Pumparound (flow in BPD) - The lower limit was
depicted in
the process safety information as 5,000 BPD. It is presently 2,500 BPD.
The upper limit
was depicted in the process safety information as 17,000 BPD and it is
presently
established as 6,000 BPD.
(6) The #2 Unit Diesel Pumparound (flow in BPD) - The lower limit was
depicted in the
process safety information as 10,000 BPD. It is presently established at
7,500 BPD. The
upper limit was depicted on the process safety information as 18,000 BPD
while it is
presently at 12,000 BPD.
(7) The #2 Unit Diesel Draw to Treating (flow in BPD) - The upper limit is
presently
at 5,000 BPD and the process safety information established it as 9,000
BPD.
This exposed the employees to the hazards of fire and explosion.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that the operational
limits
are updated and
documented as part of the process safety information.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(d)(3)(i)(C):  Process safety information pertaining to the
equipment in the
process did not include the electrical classification:
This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer did not have electrical classification drawings for the area
surrounding the F-
400 flare and knock out pot.  The employer exposed employees to a fire and
explosion
hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that drawings that
detail all locations
designated as hazardous (classified) are developed.  These electrical
classifications, the classified
locations and classified areas surrounding the classified location need to
be
documented.  This
documentation shall be made available to those authorized to design,
install, inspect, maintain,
or operate electric equipment at the location.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $4,900 · Current $4,900

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): Process safety information pertaining to the
equipment in the
process does not include the relief system design and design basis:
(a) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer had no documentation on the relief system design and
calculations based
on a worst case scenario. The company falls under the PSM standard as it
is a crude oil
refining process that contains over 10,000 pounds of naphtha and over
10,000 pounds of
liquefied natural gas (LPG) which are classified as flammable liquids and
gases.  A
release of these materials from the process vessels could cause a
catastrophic event where
employees would suffer burns and/or death.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps that it is taking to ensure that the
process safety information is
collected for each pressure relief valve and utilized in the process
hazard analysis and
mechanical integrity program.
(b) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer failed to have the information for the materials of
construction for PSV-255
included in their process safety information.  This condition exposed
employees to fire
and explosion hazards.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
this standard
including describing the action it is taking to ensure that the materials
of construction are
collected for each pressure relief valve and utilized in the process
hazard analysis and
mechanical integrity program.y

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F):  Process safety information pertaining to the
equipment does not
include the design codes and standards employed:
(a)  This violation occurred on or about January 27, 2009, and times prior
thereto, where the
process safety information did not include the design of the pressure
relieving system for the #2
Crude Unit and the entire facility.  This would include the relief valves,
the header system, the
knock out pot and the flare. This condition exposed employees to fire and
explosion hazards.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that process safety
information
is collected
for each pressure relief valve, header system, knock out pot, and flare
and is utilized in the
process hazard analysis and mechanical integrity program.
(b)  This violation occurred  on or about January 27, 2009, and times
prior thereto, where the
process safety information did not include the design codes for the
following pressure vessels;
1)V-202 Crude Reflux Accumulator - The employer could not provide:
Rerating Calculations (Code ASME)
Heat Treatment Results (Code ASME)
Post Weld Heat Treatment Results (Code API 510)
Welding Performance Qualifications (PQR) (Code ASME)
Welding Procedure Specification (WPS) (Code ASME)
Repair & Alteration Reports (R-1) (Code API 510)
2)V-201 #2 Crude Unit Main Frac Tower - The employer could not provide:
Manufacturers Data Report (U-1, U-2 Reports) (Code ASME)
Heat Treatment Results (Code ASME)
Post Weld Heat Treatment Results (Code API 510)
Welding Performance Qualifications (PQR) (Code ASME)
Welding Procedure Specification (WPS) (Code ASME)
Thickness Measurement Locations (TML) (Code API 572)
3)E-211B Diesel Product Desalted Crude Heat Exchanger - The employer could
not
provide:
Welding Performance Qualifications (PQR) (Code ASME)
Repair & Alteration Reports (R-1) (Code ASME)
4)V-204 Diesel Stripper - The employer could not provide:
Manufacturers Data Report (U-1, U-2 Reports)(Code ASME)
Code Calculations (Code API)
Rerating Calculations (Code ASME)
Heat Treatment Results for vessel (Code API 510)
MI/NDE Test Results (MT, UT, RT, etc) for vessel
Post Weld Heat Treatment Results (Code API 510)
TML Historical Readings (Code API 510)
Welding Performance Qualifications (PQR) (Code ASME)
Welding Procedure Specification (WPS) (Code ASME)
Repair & Alteration Reports (R-1) (Code API 510)
Failure to maintain the process safety information of the #2 Crude Unit
pressure vessels could
result in risk of exposure to fire and explosion to employees.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that an up-to-date
evaluation is being
conducted and that the process safety information is updated.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the
equipment in the process
complied with recognized and generally accepted good engineering practices:
(a) This violation occurred on or about January 27, 2009, and times prior
thereto,where
the employer did not comply with RAGAGEP (i.e. API 521 Sec. 4.3, 4.4, 4.5)
when it
failed to evaluate (e.g., calculations and/or plume dispersion model
modeling) whether
releases from relief system equipment discharged to safe locations. The
worst case
flammable vapor cloud scenario was not evaluated to determine if the
pressure relief
valve on the LPG Storage Tank 201 vented to a safe location.  The LPG Tank
has a
maximum capacity of 72,700 gallons (water capacity) with a pressure relief
valve located
on the top of the pressure vessel. A parking area, abandoned
administrative building,
operator's break room, and operator's control room are within 236 feet of
the LPG
storage tank. This condition exposed employees to a fire and explosion
hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the
standard,
including describing the steps it is taking to ensure that LPG Tank 201
vents to a safe
location.
(b) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer located its steam discharge for the pressure relief valve of
steam line E-D-
2-118 eight inches from an employee work area.  The discharge point was
approximately
four feet above the work location and plant steam is 135 Pounds. If the
pressure relief
valve functioned as designed scalding steam could be released into the
employees work
areas.  Employees could suffer burns from the discharging steam plume.
This condition
exposed employees to the hazard of burns from steam.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the
standard,
including describing the steps it is taking to ensure that the pressure
relief valve from steam
discharge line E-D-2-118 does not discharge into an employee work area.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(e)(1): The process hazard analysis is not appropriate to
the complexity of the
process and does not identify, evaluate, and address the control of the
hazards involved in the
process:
(a)This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer's process hazard analysis's conducted in 1994,1999 and 2009 for
the LPG Storage
Tank 201 (installed on July 1990) did not address whether or not the
pressure relief valve vented
to a safe location. The employer did not conduct a plume dispersion model
or calculations of the
worst case flammable vapor cloud scenario to determine if the pressure
relief valve on the LPG
Storage Tank 201 vented to a safe location.  The LPG Tank has a maximum
capacity
of 72,700
gallons (water capacity) with a pressure relief valve located on the top
of the pressure vessel.
A parking area, abandoned administrative building and operators break room
is within 236 feet
of the LPG storage tank.  This condition exposed employees to a fire and
explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that LPG Tank 201
vents to a safe location
and how this information will be included in the PHA.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(e)(3)(ii):  The process hazard analysis did not identify
any previous incident
which had a likely potential for catastrophic consequences in the
workplace:
This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer's process hazard analysis (1995, 1997, 2001 and 2006) conducted
for the #2
Crude Unit did not address any previous incidents which had a likely
potential for a
catastrophic consequence in the workplace.  This condition exposed
employees to a fire
and explosion hazards.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that previous
incidents that could have an
effect on a covered process are collected  and utilized in the process
hazard analysis and
mechanical integrity program.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(e)(3)(iii):  The process hazard analysis does 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) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer's process hazard analysis (1995, 1997, 2001 and 2006)
conducted for the
#2 Crude Unit did not address any controls and devices to provide early
warning of
releases.  The Company has 6 LEL monitors (Sensor 1 to 6), 6 hydrogen
sulfide
monitors (A1-710, A1-710B, A1-712A A1-745, A1-106-N, A1-106S), 2 flare
(F-400)
pilot temperature transmitters ( Flare T1 and T2), 4 level transmitters (
2 high level and
2 low level on 2 level gages (Flare Knock-out Pot D-514 and Flare Level
Gage) which
were not considered in the PHA's.  This condition exposed employees to a
fire and
explosion hazards.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that the process
safety
information is
collected for each detection device and utilized in the process hazard
analysis and mechanical
integrity program

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(e)(3)(v):  The process hazard analysis does not address
facility siting:
This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer failed to conduct a facility siting and risk study for the 2006
#2 Crude Unit
PHA, the purpose being, to determine the destructive potential of escaping
highly
hazardous chemicals on employee occupied structures (i.e. vapor cloud
release, vessel
explosion). Failure to conduct this study could potentially expose
employees to the
hazards of fire and explosion.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the
standard,
including describing the steps it is taking to ensure that facility siting
has adequately been
addressed through a facility siting study which will be incorporated into
the process hazard
analysis.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(e)(3)(vii) The process hazard analysis does not include a
qualitative evaluation
of a range of the possible safety and health effects of failure of
controls on employees in the
workplace:
This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer's process hazard analysis (1995, 1997, 2001 and 2006) conducted
for the #2
Crude Unit did not address a qualitative evaluation of the possible safety
and health
effects of failure of controls on employees in the workplace.  This
condition exposed
employees to a fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that control failure
has adequately been
addressed and will be incorporated into the process hazard analysis.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(e)(5):  The employer does not establish a system to assure
that the process
hazard analysis team's recommendations are resolved in a timely manner and
that the resolution
is documented:
This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer failed to document completion of safety and health
recommendations resulting
from process analyses conducted in 1995,1997, 2001 and 2006. This
condition exposed
employees to a fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation,
the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that all process
hazard analysis's
recommendations have been resolved and documented.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(e)(6):  The employer does not update the PHA
(update/revalidation) within
five years of the initial PHA:
This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer failed to consider in its PHA update/revaluations in  1997, 2001
and 2006 for
the #2 Crude Unit, the throughput increase and any potential effects the
increase might
have on the adequacy of the current process, including the relief system.
The #2 Crude
Unit had a throughput increase from 15,000 barrels per day in 1995 to
17,000 barrels
per day in 1997, from 17,000 barrels per day in 1997 to 21,000 barrels per
day in 2001
and a throughput increase from 21,000 barrels per day in 2001 to 25,000
barrels per day
in 2006.  This condition exposed employees to a fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that a process
hazard analysis will evaluate
throughput increase and relief system adequacy.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

General-duty citation text

29 CFR 1910.119(l)(1):  The employer does 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:
This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer's #2 Crude Unit had a throughput increase from 10,000 barrels per
day in 1979
to 15,000 barrels per day in 1995.  The # 2 Crude Unit had a throughput
increase
from
15,000 barrels per day in 1995 to 17,000 barrels per day in 1997.  A
written procedure
to manage these changes was not implemented.  This condition exposed
employees to a
fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure a management of
change procedure will be
used to evaluate all throughput increase and relief system adequacy.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(f)(1): The employer does not develop and implement written
operating
procedures that provided clear instructions for safely conducting
activities involved in each
covered process consistent with the process safety information and which
addressed the elements
listed in 29 CFR 1910.119(f)(1)(i) through (f)(1)(iv):
(a) This violation occurred on or about January 27, 2009, and times prior
thereto,
where the
employer did not develop or implement operating procedures for the
administrative control of
Car Seal's installed on all relief valves within #2 Crude Unit. The
company has Car Seals
installed on all relief valves but does not have a regular inspection
program to verify Car Seals
are in place. The Car Seal program has never been monitored to assure it
is effective and
working as designed.  This condition exposed employees to a fire and
explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that pressure relief
devices and the Car Seal
Program are being operated effectively.
(b)This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer did not develop written operating procedures in the #2 crude unit
for
all pressure relief
valve discharge into the pressure relieving system.  This condition
exposed employees to a fire
and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that a written
operating procedure is
developed and implemented that details how pressure relief valve
discharge, knock out pot
operation and flare operations will be handled at the #2 Crude Unit.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $4,900 · Current $4,900

General-duty citation text

29 CFR 1910.119(f)(1)(i)(C):  The employer's written operating procedures
covering the steps
for each operating phase does not address temporary operations:
(a) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer did not establish written operating procedures in the #2
Crude Unit for
operation of the flare when the pilots have been extinguished.  This
condition exposed
employees to a fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that a  written
operating procedure is
developed and implemented that details how operations will be handled when
the flare pilots
have been extinguished.
(b) The employer violated this standard on or about January 27, 2009, and
times prior
thereto, where the employer did not establish written operating procedures
in the #2
Crude Unit for the relighting of the flare if the pilots and flare should
be extinguished.
The flare is a component of the Calcasieu Refining Company's pressure
relieving system.
The flare has thermocouples, pilots and a manual relight system. The flare
is designed
to burn continuously. Operating procedures should outline the steps to
take if these
devices fail, and the procedure to manually re-light the flare.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that a written
operating procedure is
developed and implemented that details how operations will be handled if
the flare should be
extinguished.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

General-duty citation text

29 CFR 1910.119(f)(1)(i)(E):  The employer's written operating procedures
covering the steps
for each operating phase does not address emergency operations:
This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer did not establish written operating procedures in the #2 Crude
Unit for knock
out pot operation (D-514 Flare KO Drum) which is a component of the
pressure relieving
system.  The knock out pot has three alarms low, high and high/high. The
values
assigned to these levels and the steps to take if the levels are exceeded
were not detailed
in the operating procedures. This condition exposed employees to a fire
and explosion
hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that the written
operating procedures for
pumping out the knock out pot are developed and implemented.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

General-duty citation text

29 CFR 1910.119(f)(1)(ii):  The employer's written operating procedures do
not provide clear
instructions for safely conducting activities, consistant with the process
safety information for
the operating limits:
(a) The employer violated this standard on or about January 27, 2009 and
times prior
thereto, where the employer failed to address the following operating
limits
of the #2
Crude Unit within the operating procedures. The employer was only able to
provide one
document titled; "Crude Standard Operating Limits/Consequences of
Deviation"
Subpoena item #57:
1) #2 Crude Tower V-201 - The upper and lower operating pressure had
changed from
what was indicated on the document.
2) The overhead #2 unit naphtha & exchangers E-215 and E-1N1- The operator
provided
the upper and lower limits. These were not listed in the document. This
section had been
left blank.
3) The #2 Unit Kerosene Exit & Tray - The operator filled in the blank
with the updated
upper and lower operating temperature limits. This information had been
left blank.
4) The #2 Crude Unit Diesel Exit of the Tower - The values of lower and
upper
operating temperature had changed. The document listed 500 F as the lower
limit and the
operator provided that it was 520 F. The upper limit was labeled as 530 F
and the
operator provided that it was 560 F.
5) The #2 Unit Unstabilized Naphtha Draw to Treating (flow in BPD) - The
document
shows the upper limit was depicted as 3,500 BPD and the operator
established that it was
presently 5,500 BPD.
6) The #2 Unit Kerosene Pumparound (flow in BPD) - The lower limit was
depicted as
5,000 BPD. The operator established it as 2,500 BPD. The upper limit was
depicted as
17,000 BPD and the operator established it as 6,000 BPD.
7) The #2 Unit Diesel Pumparound (flow in BPD) - The lower limit was
depicted as
10,000 BPD. The operator established that it is presently at 7,500. The
upper limit was
depicted as 18,000 BPD while the operator established that it is presently
at 12,000 BPD.
8) The #2 Unit Diesel Draw to Treating (flow in BPD) - The upper limit is
depicted at
5,000 BPD and the operator established it as presently 9,000 BPD.
This condition exposed employees to a fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that the operating
procedures are beingrevised to reflect the present operating limits.ng

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $4,900 · Current $4,900

General-duty citation text

29 CFR 1910.119(f)(1)(iv):  The employer's written operating procedures do
not address
requirements for the safety systems and their functions:
This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer failed to address the applicable safety systems (i.e.
uninterruptible
power
supply, safety relief devices) within the operating procedures for the #2
Crude Unit. This
condition exposed employees to a fire and explosion hazards.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that information
pertaining to the safety
systems integral in operating procedures are contained within the
operating procedures.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $4,900 · Current $4,900

General-duty citation text

29 CFR 1910.119(f)(3):  The employer does not certify annually that the
operating procedures
are current and accurate:
(a)This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer did not certify annually that the following operating
procedures for the #2
Crude Unit were up-to-date:
1)  Start-Up After Turnaround - Last reviewed: No date
2)  #2 Unit Crude Tower Bottoms Transition from Circulation to Vacuum Unit
Charge
Feed Circuit - Last reviewed: No date, No name of certifier.
3) Transition #2 Crude Tower Bottoms from Vacuum Unit Charge To #2
Circulation
Circuit - Last reviewed: No date, No name of certifier
4) #2 Crude Shutdown For Turnaround - Last reviewed: No date
5) Bypassing Crude Side of (E-207) #2 Crude Exchanger - Last reviewed: No
date, No
name of certifier
6) Initial Start-Up #2 Crude Unit - Last Reviewed: 1/22/07
7) Line Up Natural Gas to Fuel Gas KO Vessel (V-210) - Last Reviewed:
11/26/07
8) Emergency Shutdown Due to Loss of Steam - Last reviewed: 1/22/07
Failure to certify the operating procedures could risk employees to the
hazards of fire and
explosion.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that the operating
procedures are annually
reviewed and certified.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(f)(4):  The employer did not develop and implement safe
work practices for
employees and contractor employees to provide for the control of hazards
during operations such
as lockout/tagout; confined space entry; opening process equipment or
piping; and control over
entrance into a facility by maintenance, contractor, laboratory, or other
support personnel:
This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer did not assure that non-intrinsically safe motorized equipment
was not allowed
to enter an area classified as Class 1 Division II. The company policy was
that the
classified area extended 20 feet from the base of the F-400 flare.
Motorized vehicle
tracks were noted within four feet of the F-400 flare base.  This
condition exposed
employees to a fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that drawings that
detail all locations
designated as hazardous (classified) are prepared and that electrical
classifications, the classified
location and classified areas surrounding the classified location are
documented.  The employer
must also submit a plan showing that documentation shall be made available
to those authorized
to design, install, inspect, maintain, or operate electric equipment at
the location. The employer
must also develop and describe policies and procedures to prevent
employees and contractors
from entering classified areas with non-classified equipment.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(g)(1)(i): The employer does not initially train each
employee, presently
involved in operating a process, in an overview of the process and in the
operating procedures
as specified in 29 CFR 1910.119(f).
(a)  This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer did not initially train each employee presently involved in
operating a process, in the
operating procedures for the #2 Crude Unit pressure relief system which
includes the pressure
relief valves, the knockout pot and the flare.  This condition exposed
employees to a fire and
explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that written
operating procedures are
developed and implemented that detail how pressure relief valve discharge,
knock out pot
operation and flare operations will be handled at the #2 Crude Unit. In
addition operators of the
unit must review the operating procedures, be trained on the procedures
and the employer must
ascertain if each employee involved in operating the process has received
and understood the
training.d

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $4,900 · Current $4,900

General-duty citation text

29 CFR 1910.119(j)(2): The employer does not establish and implement
written procedures to
maintain the on-going mechanical integrity of process equipment:
(a) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer failed to develop a written procedure for the inspection for
corrosion
under
insulation for pressure vessels in Crude Unit #2. This condition exposed
employees to
a fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that an inspection
procedure for the
determination of corrosion under insulation is developed and implemented.
(b) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer did not implement a Mechanical Integrity Procedure that
required piping
inspections to be based on a classification system that prioritizes piping
inspections based
on consequences of failure. Product piping circuits in Crude Unit #2 such
as, but not
limited to, Kerosene piping lines (3"-K-20176, 4"-K-20179, 4"-20193, and
3"-K-20201);
Diesel piping lines (4"-D-20177, 3"-D-20178, 4"-D20194, 3"-D-20185,
8"-D-50360, and
8"-D-50361); Light Naphtha piping lines (6"-LN-20149, 4"-LN-20150,
3"-LN-20151,
3"-LN-20152, 3"-HN-20224 and 3"-HN-20225) were not given a consequence of
failure
classification (Class 1, Class 2 or Class 3) as prescribed by API 570 -
Piping Inspection
code to determine the extent and frequency of inspection. This condition
exposed
employees to a fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that a piping
inspection procedure is
developed and implemented that ensures piping circuit mechanical integrity
inspections include
a consequence of failure classification system.
(c) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer did not have the complete owner's equipment manuals for pumps
P202A&B-Overhead Reflux & Product Pumps, in Crude Unit #2 which provides
minimum preventive maintenance requirements.  This condition exposed
employees to
a fire and explosion hazards.
(d) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer did not have complete owner's equipment manuals for pumps
P2HN1&P2HN2-Heavy Naphtha Pumps, Crude Unit which provides minimum
preventive maintenance requirements. This condition exposed employees to a
fire and
explosion hazards.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that the owner's
equipment manuals are being
assembled in their entirety.
(e) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer did not outline the training and qualifications each employee
would be
required to have to maintain the on-going integrity of process equipment.
There was no
standard training program for I&E Technicians, mechanics and millwrights
working in
the covered process.  This condition exposed employees to a fire and
explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that the employer
completely develops a
written mechanical integrity program, that outlines in detail what
training will be required and
provided to I&E Technicians, mechanics and millwrights.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $4,900 · Current $4,900

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) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer failed to inspect, per the manufacturer's recommendations,
P205A-Service
Pre-fractionation Overhead Reflux Pump, Serial # P58514-01/02 in Crude
Unit #2,
mechanical seal for wear, wear rings, or worn surfaces; the impeller for
cavitation
damage, extreme corrosion on the casing and casing cover; seal flush
piping for any
foreign material or blockages.
b) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer did not inspect P218A-Light Naphtha Product Pump, serial
#05RLCP006601001/02 in Crude Unit #2 mechanical seal for wear, wear rings
for
grooved or worn surfaces, the impeller for cavitation damage, extreme
corrosion on the
casing and casing cover, seal flush piping for any foreign material or
blockages, and the
driver as per the manufacturer's recommendations. This condition exposed
employees to
a fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 days of the calendar date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that the appropriate
inspection and testing
is being implemented for pumps.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $4,900 · Current $4,900

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)  This violation occurred on or about January 27, 2009, and at times
prior thereto,
where the employer did not inspect all piping circuits in Crude Unit #2,
such as but not
limited to, Kerosene piping lines (3"-K-20176, 4"-K-20179, 4"-20193, and
3"-K-20201);
Diesel piping lines (4"-D-20177, 3"-D-20178, 4"-D-20194, 3"-D-20185,
8"-D-50360,
and 8"-D-50361); Light Naphtha piping lines (6"-LN-20149, 4"-LN-20150,
3"-LN-
20151, 3"-LN-20152, 3"-LN-20153, and 3"-LN-20158); and Heavy Naphtha
piping lines
(6"-HN-20222, 6"-HN-20223; 3"-HN-20224, and 3"-HN-20225) for
Corrosion-Under-
Insulation (CUI) as prescribed by API 570 -Piping Inspection Code.  This
condition
exposed employees to a fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that all CUI
inspections are being properly
documented.
b) This violation occurred on or about January 27, 2009, and at times
prior thereto,
where the employer did not establish thickness measurement location (TMLs)
for
injection points in Crude Unit #2, such as but not limited to injection
points: &CR-IP2
(Neutrilizer) and 2CR-IP3 (Filmer) as prescribed by API 570 - Piping
Inspection Code.
This condition exposed employees to a fire and explosion hazard.
Pursuant to 29 CFR 1903(d), within 10 calendar days of the date of this
citation, the employer
must submit documentation showing that it is in compliance with the
standard,
including
describing the steps it is taking to ensure that all CUI inspections are
being properly
documented.
(c) This violation occurred on or about January 27, 2009, and at times
prior thereto,
where the employer failed to use qualified inspectors to inspect process
piping in Crude
unit #2 as required by API 570, Section 4.2, API Authorized Piping
Inspector
Qualification and Certification and as specified in CRC's work procedure
for piping
inspections. This condition exposed employees to a fire and explosion
hazard.
(d) This violation occurred on or about January 27, 2009, and at times
prior
thereto, where the employer failed to ensure that inspectors performing
ultrasonic
thickness (UT) testing on piping in Crude Unit #2 were UT Level II, UT
Level
III, or UTT certified to inspect process piping as per American Society for
Nondestructive Testing (ASNT) document SNT-TC-1A and met the requirements
as described in CRC's work procedure for performing baseline thickness
measurements.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that site piping
inspectors are properly trained
and certified.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $4,900 · Current $4,900

General-duty citation text

maintain its mechanical integrity, is not consistent with applicable
manufacturers'
recommendations and good engineering practices, and more frequently if
determined to be
necessary by prior operating experience:
(a) This violation occurred on or about January 27, 2009, and at times
prior thereto,
where the employer did not inspect piping in Crude Unit #2, including the
following
existing crude oil pipe lines: 4"-C-20104-B2_1-H2", 4"-C-20125-B2_1-H2",
3"-C-20214-
B2_1-H2" and 4"-C-20124-B2_1-H3", with the frequency as prescribed by API
570 -
Piping Inspection Code.  This condition exposed employees to a fire and
explosion
hazards.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that inspections for
process
piping systems
are performed on the prescribed/recommended frequency as per API 570.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $4,900 · Current $4,900

General-duty citation text

29 CFR 1910.119(j)(4)(iv):  The documentation of the inspection or test
that been performed on
process equipment to maintain its mechanical integrity does not identify
the date of the inspection
or test, the serial number or other identifier of the equipment on which
the inspection or test was
performed, a description of the inspection or test, and the results of the
inspection or test:
(a) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer performed a vibration analysis and did not have the name of
the person
performing the analysis and interpretation of the results for the
P218A-Light Naphtha
Product Pump, in Crude Unit #2. This condition exposed employees to a fire
and
explosion hazards.
(b) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer performed a vibration analysis and did not have the name of
the person
performing the analysis and the interpretation of the results for the
P205A-Service Pre-
Fractionation Overhead Product Pump, in Crude Unit #2. This condition
exposed
employees to a fire and explosion hazards.
(c) This violation occurred on or about January 27, 2009, and at times
prior thereto,
where the employer did not have the original thickness measurements needed
to calculate
short-term and long-term corrosion rates for existing piping circuits in
Crude Unit #2
such as, but not limited to, Kerosene piping lines (3"-K-20176,
4"-K-20179, 4"-20193,
and 3"-K-20201); Diesel piping lines (4"-D-20177, 3"-D-20178, 4"-D-20194,
3"-D-
20185, 8"-D-50360, and 8"-D-50361); Light Naphtha piping lines
(6"-LN-20149, 4"-LN-
20150, 3"-LN-20151, 3"-LN-20152, 3"-LN-20153, and 3"-LN-20158); and Heavy
Naphtha piping lines (6"-HN-20222, 6"-HN-20223; 3"-HN-20224, and
3"-HN-20225)
as prescribed by API 570 - Piping Inspection Code.  This condition exposed
employees
to a fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that the Inspection
and Testing of pumps and
piping circuits are being properly documented.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(m)(4)(v):  The report prepared at the conclusion of the
investigation of an
incident which resulted in, or could have reasonably resulted in a
catastrophic release of highly
hazardous chemical in the workplace, does not include any recommendations
resulting from the
investigation team:
This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer did not develop recommendations for the incident that occurred on
March 21,
2006, in the #2 Crude Unit that required an incident investigation as
outlined in
1910.119(m).  This condition exposed employees to a fire and explosion
hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that all incidents
in a covered process which
resulted in, or could reasonably have resulted in a catastrophic release
of a highly hazardous
chemical in the workplace are investigated and meet the requirements
outlined in 1910.119(m).

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(n):  The employer's emergency action plan does not include
procedures for
handling small releases:
(a) This violation occurred on or about January 27, 2009, and at times
prior thereto,
where the employer did not include a detailed procedure in its EAP that
instructs
employees on how to distinguish between small releases/spills and large
releases/spills
and what actions to take in the event that an incident occurs.  The roles
and
responsibilities for employees designated as Local Responders when
responding to
spills/releases of hazardous and/or flammable materials in process units,
such as but not
limited to Crude Unit #2, were not clearly defined by the employer.  This
condition
exposed employees to a fire and explosion hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that procedures are
in place to handle small
or large spills/releases that may occur at the facility.
(b) The employer violated this standard on or about January 27, 2009, and
at times prior
thereto, where the employer's Emergency Action Plan (EAP) did not include
a plan to
designate and train employees to assist in the safe and orderly evacuation
of
other
employees and ensure that emergency evacuation procedures were being
effectively
followed.  29 CFR 1910.119(n) requires that the employer has an EAP in
accordance
with the provisions of 29 CFR 1910.38.
Pursuant to 29 CFR 1903.19(d), within 10 days of the receipt of this
citation, the employer must
submit an abatement plan describing the action it is taking to ensure that
safe and orderly
evacuations of employees is to be performed in the event of an emergency
situation.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(o)(4):  The employer does not determine and document an
appropriate
response to each of the findings of the compliance audit required by 29
CFR 1910.119(o)(1),
and document that the deficiencies have been corrected:
This violation occurred on or about January 27, 2009, and times prior
thereto, where
Calcasieu Refining Company performed a compliance audit in 1998 and
September 2001
and did not document that all the deficiencies observed in the audit were
corrected.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that a system is in
place to correct all
compliance audit deficiencies in a timely fashion and follow the
corrections from start to
completion.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.165(b)(2):  The employee alarm can not be perceived above
ambient noise or light
levels by all employees in the affected portions of the workplace:
This violation occurred on or about January 27, 2009, and times prior
thereto, where the
employer failed to maintain an audible alarm system used to notify
employees of fires
and other emergency situations. The alarm system could not be heard in the
north and
south maintenance shops.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that an employee
alarm system is in-place
that is capable of being perceived above ambient noise levels by all
employees in all the affected
portions of the workplace.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $700 · Current $700

General-duty citation text

29 CFR 1910.119(c)(2): The employer does not consult with employees and
their representative
on the development of the Mechanical Integrity (MI) element requirements
of process safety
management:
This violation occurred on or about January 27, 2009, and at times prior
thereto, where
the employer did not consult employees when it developed the Mechanical
Integrity (MI)
element requirements. The employer could not demonstrate that there was a
dialogue
between management and employees, in which the employer encouraged employee
participation and responded to employees' concerns and suggestions as it
related to the
development and implementation of the company's MI program.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
this standard,
including describing how it will consult with employees on the development
of the MI element
of PSM.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $700 · Current $700

General-duty citation text

29 CFR 1910.119(h)(2)(i): The employer, when selecting a contractor, does
not obtain and
evaluate information regarding the contract employer's safety performance
and programs:
This violation occurred on or about January 27, 2009, and at times prior
thereto, where
the employer did not obtain and evaluate all contractor's (such as, but
not limited to, Ron
Williams Construction, Inc.) safety information and programs before
allowing them to
work on or near process units.  Through work request forms initiated by
CRC,
employees of Ron Williams Construction perform various maintenance and
construction
activities throughout the facility, in and around PSM covered processes
including Crude
Unit #2.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that all evaluations
of contractors' safety
information and programs are being maintained and properly documented.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

General-duty citation text

29 CFR 1910.119(h)(2)(v):  The employer does not periodically evaluate the
performance of
contract employers in fulfilling their obligations as specified in 29 CFR
191.119(h)(3):
This violation occurred on or about January 27, 2009, and at times prior
thereto, where
the employer did not periodically evaluate the performance of all
contractors
(such as,
but not limited to, Ron Williams Construction, Inc.) to ensure that the
contractors were
complying with all contract employer responsibilities required when
working in covered
process areas at the site, including Crude Unit #2.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that all performance
requirements stipulated
under 29 CFR 1910.119(h)(3) are completed and maintained.(3)

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $700 · Current $700

General-duty citation text

29 CFR 1910.119(h)(2)(vi): The employer does not maintain a contract
employee injury and
illness log related to contractor's work in process areas:
(a) This violation occurred on or about January 27, 2009, and at times
prior thereto,
where the employer failed to maintain information/documentation on all
contract
employee injuries and/or illnesses occurring in process areas at the site
from years 2006
to present.  CRC did not maintain copies of Ron Williams Construction,
Inc.'s OSHA
300 Logs or document all their employee' injury/illness cases occurring in
process units
such as, but not limited to, Crude Unit #2.
To abate this violation, the employer must maintain contractor's OSHA 300
Logs and/or a listing
documenting all contract employees' injuries and illnesses occurring in
the workplace.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure that a log of all
contractor employees'
injuries and/or illnesses occurring at CRC are being properly documented
and maintained.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $700 · Current $700

General-duty citation text

29 CFR 1910.119(m)(1):  The employer does not investigate each incident
which results in, or
can reasonably result in, a catastrophic release of a highly hazardous
chemicals in the workplace:
(a)  This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer did not investigate incidents on September 10, 2004,  March
21, 2006, and
September 13, 2007 in the #2 Crude Unit that required an incident
investigation as
outlined in 1910.119(m).  This condition exposed employees to a fire and
explosion
hazard.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps that it is taking to ensure that a complete
investigation, as outlined
in 1910.119(m), is conducted for all incidents that may have resulted in a
catastrophic release
of highly hazardous chemicals.

Issued

Jul 27, 2009

Abate by

Aug 13, 2009

Penalty

Initial $700 · Current $700

General-duty citation text

29 CFR 1910.119(o)(1): The employer does not certify that it has evaluated
compliance with the
provisions of 29 CFR 1910.119 at least every three years to verify that
the procedures and
practices developed under this standard are adequate and are being
followed:
(a) This violation occurred on or about January 27, 2009,and times prior
thereto,where
the employer performed a compliance audit in September 2001 but did not
perform
compliance audits in September of 2004 and September of 2007.  This
condition exposed
employees to a fire and explosion hazard.
(b) This violation occurred on or about January 27, 2009, and times prior
thereto, where
the employer did not develop or implement an audit program for the Car
Seals installed
on all relief valves. The company has Car Seals installed on all relief
valves but does not
have a regular inspection program to verify Car Seals are in place. The
Car Seal program
has never been monitored to assure it is effective and working as
designed. This
condition exposed employees to a fire and explosion hazard.
To abate this violation, the employer must ensure that compliance audits
are conducted
every three years to verify that the procedures and practices developed
under the OSHA
standard are adequate and are being followed.
Pursuant to 29 CFR 1903.19(d), within 10 calendar days of the date of this
citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including describing the steps it is taking to ensure a compliance audit
will be conducted every
three years.