OSHA Inspection: LIMA REFINING COMPANY A HUSKY ENERGY INC. SUBSIDI.

Issued

Mar 16, 2009

Abate by

Nov 30, 2009

Penalty

Initial $5,000 · Current $3,750 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized hazards that
were likely to cause death or serious physical harm to employees, in that
employees are exposed
to fire and explosion hazards related to the release of storage vessel
contents in the Tank Farm
due to potentially undetected damage mechanisms:
a)  Lima Refining Company - Lima, Ohio:  On or about September 24, 2008
the employer did
not ensure that the Slop Oil Tank (PR 100250) in the Tank Farm was
inspected at the inspection
intervals dictated by recognized and generally accepted good engineering
practices (API 653),
and by the company's internal mechanical integrity program.
b)  Lima Refining Company - Lima, Ohio:  On or about September 24, 2008
the employer did
not ensure that the Light Gas Oil Tank (PR 100235) in the Tank Farm was
inspected
at the
inspection intervals dictated by recognized and generally accepted good
engineering practices
(API 653), and by the company's internal mechanical integrity program.
c)  Lima Refining Company - Lima, Ohio:  On or about September 24, 2008
the employer did
not ensure that the Heavy Naptha Tank (PR 100205) in the Tank Farm was
inspected at the
inspection intervals dictated by recognized and generally accepted good
engineering practices
(API 653), and by the company's internal mechanical integrity program.
d)  Lima Refining Company - Lima, Ohio:  On or about September 24, 2008
the employer did
not ensure that the Crude Oil Tank (PR 100223) in the Tank Farm was
inspected at the
inspection intervals dictated by recognized and generally accepted good
engineering practices
(API 653), and by the company's internal mechanical integrity program.
Abatement Note:  Amongst others, this citation can be abated by following
API Standard 653
(Tank Inspection Repair, Alteration, and Reconstruction), Section 6 for
internal inspections.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Mar 16, 2009

Abate by

Mar 19, 2009

Penalty

Initial $2,125 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D):  Process safety information pertaining to the
equipment in the
process did not include the relief system design and design basis:
a)  Lima Refining Company - A Husky Energy Inc. Subsidiary located in
Lima, Ohio:  On or
about September 24, 2008, the employer did not determine if the residency
time for flammable
gases and vapors in the coker blowdown stack, located in the coker unit,
was adequate to allow
liquids to separate from the gases and vapors prior to the gases and
vapors
exiting the blowdown
stack.
b)  Lima Refining Company - A Husky Energy Inc. Subsidiary located in
Lima, Ohio:  On or
about September 24, 2008, the employer did not determine if the exit
velocities of flammable
hydrocarbon vapors and gases exiting the coker blowdown stack, located in
the coker unit, were
adequate to safely disperse to material upon exit from the stack during
various upset conditions.
c)  Lima Refining Company - A Husky Energy Inc. Subsidiary located in
Lima, Ohio:  On or
about September 24, 2008, the employer did not determine the capacity of
the process sewers
in handling liquid hydrocarbon and water discharge from the coker blowdown
stack, located in
the coker unit, during various upset conditions.
No additional abatement information is needed for this item.

Issued

Mar 16, 2009

Abate by

Jun 30, 2009

Penalty

Initial $2,125 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E):  Process safety information pertaining to the
equipment in the
process did not include the ventilation system design:
a)  Husky Refining - Lima, Ohio:  The employer did not compile written
process safety
information calculating required air flow rates in pressurized control
buildings and block houses
through all openings capable of being opened in these buildings.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Mar 16, 2009

Abate by

Apr 30, 2009

Penalty

Initial $2,125 · Current $2,000 Reduced

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:
Lima Refining Company - A Husky Energy Inc. Subsidiary located in Lima,
Ohio:  On or about
September 24, 2009 the employer did not ensure that RAGAGEP was followed
with
respect to
pressurized control building, in that:
a)  Pressures in the SRU and AWWT control buildings were not maintained at
a level of at least
25 Pa (0.1 inches of water) with all openings closed.
b)  The employer could not ensure that positive pressure was maintained in
the Boiler House
control room was not detectable due to the lack of an indicator or alarm.
c)  The employer could not document that the metal shell of the coker
furnace knockout drum
was able to withstand the effects of the 900 degree incoming crude and
still maintain its
structural integrity.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to,
evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Mar 16, 2009

Abate by

Mar 19, 2009

Penalty

Initial $2,125 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(1):  The process hazard analysis was not appropriate to
the complexity of
the process and did not identify, evaluate, and address the control of the
hazards involved in the
process:
a)  Lima Refining Company - A Husky Energy Inc. Subsidiary located in
Lima, Ohio:  On or
about September 24, 2008, the employer's process hazard analysis did not
address the hazard
of hydrogen sulfide being released from the coker blowdown stack during
upset conditions.
b)  Lima Refining Company - A Husky Energy Inc. Subsidiary located in
Lima, Ohio:  On or
about September 24, 2008, the employer's process hazard analysis did not
address the hazard
of hydrocarbon vapor being released from the coker blowdown stack during
upset conditions.
No additional abatement information is needed for this item.

Issued

Mar 16, 2009

Abate by

Sep 1, 2009

Penalty

Initial $2,125 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(v):  The process hazard analysis did not address
facility siting:
a)  Husky Refining - Lima, Ohio:  The employer's process hazard analyses
did not address
facility siting hazards of processes, in that the PHA's for the
Isocracker, ISOM, and HPU
operating units did not address the stack height positioning for control
rooms and block houses.
Consideration of the building ventilation systems is required to ensure
that air intakes are
situated away from areas that may be affected, and to ensure that there is
no air intake during
a release of toxic or flammable gases or vapors.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement,
or other
written records.

Issued

Mar 16, 2009

Abate by

Sep 30, 2012

Penalty

Initial $5,000 · Current $3,750 Reduced

General-duty citation text

29 CFR 1910.119(e)(5):  the employer did 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:
Husky Refining - Lima, Ohio:  Action items identified in the employer's
Process Hazard
Analyses (PHA's) were not addressed in a timely manner.  The list of
action items includes, but
is not limited to:
a)  Hardening the Aromatics and FCC control buildings so that they can
withstand blast
overpressures of more than 3 psi.
b)  Installation of the prefabricated North and South LIU Block Houses
built to withstand blast
overpressures of more than 3 psi.
c)  The employer had not performed toxic dispersion modeling to show how
hydrogen sulfide
would disperse if a release occurred.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Mar 16, 2009

Abate by

May 15, 2009

Penalty

Initial $2,125 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1):  The employer did not develop and implement written
operating
procedures that provided clear instructions for safety conducting
activities in each covered
process consistentwith the process safety information and which addressed
the elements listed
in 29 CFR 1910.119(f)(1)(i) through (f)(1)(v):
a)  Husky Refining - Lima, Ohio:  The employer did not develop and
implement effective
written operating procedures for all control buildings that provided clear
instructions
for shutting
down HVAC systems in the event of a product release outside of these
buildings.  The list of
buildings includes, but is not limited to: FCC Control Building, LIU
Control Building, AWWT,
Coker/SRU Control Building, Boiler House Control Building.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Mar 16, 2009

Abate by

Jul 1, 2009

Penalty

Initial $2,125 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(A):  The employer's written operating procedures
covering the
operating limits did not address consequences of deviation beyond such
operating limits:
a)  Husky Refining - Lima, Ohio:  The employer did not develop and
implement written
operating procedures that provided clear instructions for observing and
responding to indicators
to detect pressure losses in pressurized analyzer cabinets within the Lima
Integrated Unit (LIU),
and the consequences of deviation from acceptable parameters.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Mar 16, 2009

Abate by

Mar 19, 2009

Penalty

Initial $5,000 · Current $3,750 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)  Lima Refining Company - Lima, Ohio:  On or about October 21, 2008 the
employer failed
to ensure that contractors working on Tank 201 were informed of potential
fire hazards
associated with residual flammable liquids in the tank.  A fire resulted
when a cutting torch used
in a seal repair project ignited residual flammable liquids at the roof on
the tank.
In accordance with 29 CFR 1903.19(c), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Mar 16, 2009

Abate by

Mar 19, 2009

General-duty citation text

29 CFR 1910.252(a)(2)(xiii)[D]:  The employer did not recognize its
responsibility for the safe
usage of cutting or welding equipment, and did not advise all contractors
about flammable
materials or hazardous conditions of which they may not be aware:
a)  Lima Refining Company - Lima, Ohio:  On or about October 21, 2008 the
employer failed
to ensure that contractors working on Tank 201 were informed of potential
fire hazards
associated with residual flammable liquids in the tank.  A fire resulted
when a cutting torch used
in a seal repair project ignited residual flammable liquids at the roof on
the tank.
In accordance with 29 CFR 1903.19(c), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Mar 16, 2009

Abate by

Mar 19, 2009

Penalty

Initial $1,500 · Current $1,125 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(v):  The employer did not periodically evaluate the
performance of
contract employers in fulfilling their obligations as specified in 29 CFR
1910.119(h)(3):
a)  Lima Refining Company - Lima, Ohio:  On or about September 23, 2008
the employer failed
to follow their written contractor safety program, which requires a
periodic evaluation of the
safety performance of the contract employers that work at the facility.
Specifically,
Matrix
Service Industrial Contractors, Inc. was not evaluated on a five year
basis, as required, using
the Contractor CCQ form since April of 1997.
No additional abatement information is needed for this item.

Issued

Mar 16, 2009

Abate by

Mar 19, 2009

Penalty

Initial $2,125 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii):  The frequency of inspections and tests of
process equipment to
maintain its mechanical integrity, was not consistent with applicable
manufacturers'
recommendations and good engineering practices, or more frequently
determined to be necessary
by prior operating experience:
a)  Lima Refining Company - Lima, Ohio:  On or about September 24, 2008
the employer failed
to ensure that the Reactor Effluent Condenser (PR 153437) in the
Isomerization Unit was
inspected at the inspection intervals dictated by recognized and generally
accepted good
engineering practices (API 570), and by the company's internal mechanical
integrity program.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Mar 16, 2009

Abate by

May 31, 2009

Penalty

Initial $5,000 · Current $3,750 Reduced

General-duty citation text

29 CFR 1910.119(j)(5):  The employer did not correct deficiencies in
equipment that were
outside acceptable limits (as defined by process information in 29 CFR
1910.119(d) before
further use or in a safe and timely manner:
a)  Lima Refining Company - Lima, Ohio:  On or about September 24, 2008
the employer failed
to ensure that the inspection records for the 1st Stage Isocracker Reactor
(PR164066) contained
information describing a fitness for service evaluation on the crack on
the inlet nozzle groove,
to demonstrate that the crack had been evaluated to ensure that it was
within acceptable limits
to assure that the vessel could continue to be operated safely.
b)  The employer did not correct deficiencies in equipment that were
outside acceptable limits,
in that control rooms and block houses were not equipped with permanently
mounted gas
detection equipment to sense concentrations of flammable gases.  The list
of buildings lacking
this equipment includes, but is not limited to:  FCC & SRU control
buildings; North and South
LIU block houses.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Mar 16, 2009

Abate by

Mar 19, 2009

Penalty

Initial $5,000

General-duty citation text

29 CFR 1910.119(k)(2):  The hot work permit did not document that the fire
prevention and
protection requirements in 29 CFR 1910.252(a) had been implemented prior
to beginning the
hot work operations:
a)  Lima Refining Company - Lima, Ohio:  On or about October 21, 2008 the
employer failed
to ensure that the hot work permit and program were followed so that all
elements of
1910.252(a) were followed, including but not limited to the storage tank
being adequately
cleaned, purged, or otherwise prepared for hot work and contractor
notification of the hazards
of residual flammable liquids still in the tank.  A fire resulted when a
cutting torch used in a seal
repair project ignited residual flammable liquids at the roof on the tank.
In accordance with 29 CFR 1903.19(c), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Mar 16, 2009

Abate by

Jun 30, 2009

Penalty

Initial $2,125 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.147 (f)(3)(ii) (D): A personal lockout or tagout device(s) was
not affixed to the
group lockout device, group lockbox or comparable mechanism when he or she
began work (and
to be removed when work stops) on the machine or equipment serviced and/or
maintained:
Lima Refining Company - Lima, Ohio: The employer did not ensure that
procedures required
each authorized employee to affix personal lockout devices during group
lockout situations:
a)On or about October 30, 2008 a North LIU Blender Operator blanked a cat
light gas line
and locked out his end of the line, and an OMS Area Operator blanked his
end of the line,
locked out the line at his end.using locks from their area lockout boards;
the OM & S Area
Operator then gave his lockout key to the North LIU Bender Operator.  The
single key for the
locks was hung on the lockout board and the contractor applied a lock on
the board but the
operator did not apply a "personal lock" on the lockout board to secure
the key;
b)On or about November 10, 2008 a South LIU (Isocracker) "A" Operator
locked out a
reformate splitter bottom pump (which contains a flow of benzene during
normal operation), for
an outside contractor (pipefitter) using the locks from the area lockout
board. The single key for
the locks was hung on the lockout board and the contractor applied a lock
on the board but the
operator did not apply a "personal lock" on the lockout board to secure
the key;
c)On or about November 27, 2008 a South LIU (Isocracker) "A" Operator
locked out a
reformate splitter bottom pump (which contained gasoline blending stock
during normal
operation) for an outside contractor. The "A" Operator placed the single
key for the locks on
the lockout board and the outside contractors applied a lock on the
lockout board but the
operator did not apply a "personal" lock on the lockout board to secure
the key;
d)On or about December 3, 2008 an Aromatics (ISOM/HPU) "A" Operator locked
out
an
instrument air dryer for changeout of a heating element. The operator used
four locks to lockout
the piece of equipment and placed the key for the locks on the lockout
board. Maintenance
craftsmen applied their locks on the lockout board but the operator did
not apply a "personal"
lock on the board to secure the keys.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Mar 16, 2009

Abate by

Mar 19, 2009

Penalty

Initial $5,000 · Current $3,750 Reduced

General-duty citation text

29 CFR 1910.252(a)(2)(vi)(C):  Cutting or welding was permitted in the
presence of explosive
atmospheres (mixture of flammable gases, vapors, liquids, or dusts with
air), or explosive
atmospheres that could develop inside uncleaned or improperly prepared
tanks
or equipment
which had previously contained such materials, or that could develop in
areas with an
accumulation of combustible dusts:
a)  Lima Refining Company - Lima, Ohio:  On or about October 21, 2008 the
employer did not
prohibit torch cutting to take place on Tank 201 until thorough cleaning
and preparation had
taken place to ensure that a flammable atmosphere would not develop during
the cutting
operations.   A fire resulted when a cutting torch used in a seal repair
project ignited residual
flammable liquids at the roof on the tank.
No additional abatement information is needed for this item.

Issued

Mar 16, 2009

Abate by

Mar 19, 2009

General-duty citation text

29 CFR 1910.252(a)(3)(i):  Welding, cutting, or other hot work was
performed on used drums,
barrels, tanks, or other containers that had not been cleaned so
thoroughly as to make absolutely
certain there were no flammable materials present or any substances such
as greases, tars, acids,
or other materials which where subjected to heat, might produce flammable
or toxic vapors:
a)  Lima Refining Company - Lima, Ohio:  On or about October 21, 2008 the
employer did not
prohibit torch cutting to take place on Tank 201 until thorough cleaning
and preparation had
taken place to ensure that a flammable atmosphere would not develop during
the cutting
operations.   A fire resulted when a cutting torch used in a seal repair
project ignited residual
flammable liquids at the roof on the tank.
No additional abatement information is needed for this item.

Issued

Mar 16, 2009

Abate by

Mar 19, 2009

General-duty citation text

29 CFR 1910.252(a)(3)(ii):  All hollow spaces, cavities, or containers
were not vented to permit
the escape of air or gases before preheating, cutting, or welding was
performed:
a)  Lima Refining Company - Lima, Ohio:  On or about October 21, 2008 the
employer did not
prohibit torch cutting to take place on Tank 201 until thorough cleaning
and preparation had
taken place to ensure that a flammable atmosphere would not develop during
the cutting
operations.   A fire resulted when a cutting torch used in a seal repair
project
ignited residual
flammable liquids at the roof on the tank.
No additional abatement information is needed for this item.

Issued

Mar 16, 2009

Abate by

Apr 30, 2009

Penalty

Initial $5,000

General-duty citation text

29 CFR 1910.307(c):  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)  Husky Refining - Lima, Ohio:  General purpose electrical equipment was
in use within
control buildings that did not follow NFPA 496 for purged and positive
pressure requirements.
The list of general purpose electrical equipment includes, but is not
limited to computer
equipment and cooking appliances.
1)A manometer was not installed in the Boiler House control room to detect
pressure within
the room.
2)The SRU control building was not maintained at or above 0.1" water
pressure according
to the manometer inside the building.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in
addition, documentation demonstrating that abatement is complete must be
included with
your certification.  This documentation may include, but is not limited
to, evidence of the
purchase or repair of the equipment, photographic or video evidence of
abatement, or other
written records.

Issued

Mar 16, 2009

Abate by

Apr 9, 2009

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)  Lima Refining Company - Lima, Ohio:  On or about September 24, 2008
the employer failed
to ensure that a management of change procedure was implemented for an
increase in the
corrosion allowance for shell walls for four lube oil coolers (PR 153224,
153225, 153228,
153229) in the Isocracker Unit.  The process safety information was not
updated with a U-1 A
form (or equivalent) to show the change in the PSI.
In accordance with 29 CFR 1903.19(c), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Mar 16, 2009

Abate by

Mar 19, 2009

General-duty citation text

29 CFR 1910.119(m)(4)(iv):  The report prepared at the conclusion of the
investigation of an
incident which resulted in, or could have reseasonably have resulted in a
catastrophic release of
highly hazardous chemical in the workplace, did not include the factors
that contributed to the
incident:
a)  Lima Refining Company - Lima, Ohio: On or about August 1, 2007 the
employer did not
list causal factors in the incident report related to a hydrogen sulfide
leak occurring during
maintenance work being performed on the Isomerization compressor.  The
causal factors were
identified during the investigation, but not included in the final report.
In accordance with 29 CFR 1903.19(c), abatement certification is required
for this violation
(using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).