OSHA Inspection: BP PRODUCTS N. AMERICA INC.&BP-HUSKY REFINING LLC

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $5,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that the equipment in t
he process complied with recognized and generally accepted good engineering prac
tices:
a.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the Com
pressor Discharge Condenser-Top (PR 543018) in the Alky 1 unit was deficient, in
that, it did not have a grounding cable as required by recognized and generally
accepted good engineering practice. b.BP-Husky Refining, LLC - Oregon, Ohio: On
or about September 10, 2009, the Compressor Discharge Condenser-Btm (PR 543019)
in the Alky 1 unit was deficient, in that, it did not have a grounding cable as
required by recognized and generally accepted good engineering practice. c.BP-H
usky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the Compresso
r Discharge Condenser-Top (PR 543020) in the Alky 1 unit was deficient, in that,
it did not have a grounding cable as required by recognized and generally accep
ted
good engineering practice. d.BP-Husky Refining, LLC - Oregon, Ohio: On or about
September 10, 2009, the Compressor Discharge Condenser-Btm (PR 543021) in the Al
ky 1 unit was deficient, in that, it did not have a grounding cable as required
by recognized and generally accepted good engineering practice. e.BP-Husky Refin
ing, LLC - Oregon, Ohio: On or about September 10, 2009, the Isobutane Tower Ove
rhead Condenser-Top (PR 543023) in the Alky 1 unit was deficient, in that, it di
d not have a grounding cable as required by recognized and generally accepted go
od engineering practice. f.BP-Husky Refining, LLC - Oregon, Ohio: On or about Se
ptember 10, 2009, the Isobutane Tower Overhead Condenser-Btm (PR 543024) in the
Alky 1 unit was deficient, in that, it did not have a grounding cable as require
d by recognized and generally
accepted good engineering practice. g.BP-Husky Refining, LLC - Oregon, Ohio: On
or about September 10, 2009, the Debutanizer Overhead Condenser-East (PR 543027)
in the Alky 1 unit was deficient, in that, it did not have a grounding cable as
required by recognized and generally accepted good engineering practice. h.BP-H
usky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the Debutaniz
er Reboiler (PR 543028) in the Alky 1 unit was deficient, in that, it did not ha
ve a grounding cable as required by recognized and generally accepted good engin
eering practice. i.BP-Husky Refining, LLC - Oregon, Ohio: On or about September
10, 2009, the Debutanizer Overhead Condenser-West (PR 543048) in the Alky 1 unit
was deficient, inthat, it did not have a grounding cable as required by recogni
zed
and generally accepted good engineering practice. j.BP-Husky Refining, LLC - Ore
gon, Ohio: On or about September 10, 2009, the Total Alkylate Cooler (PR 543238)
in the Alky 1 unit was deficient, in that, it did not have a grounding cable as
required by recognized and generally accepted good engineering practice. k.BP-H
usky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the Condensat
e Effluent Exchanger-Top (PR 543596) in the Alky 1 unit was deficient, in that,
it did not have a grounding cable as required by recognized and generally accept
ed good engineering practice. l.BP-Husky Refining, LLC - Oregon, Ohio: On or abo
ut September 10, 2009, the Condensate Effluent Exchanger-Btm (PR 543597) in the
Alky 1 unit was deficient, in
that, it did not have a grounding cable as required by recognized and generally
accepted good engineering practice. m.BP-Husky Refining, LLC - Oregon, Ohio: On
or about September 10, 2009, the Acid Settler/Dry Drum (PR 511383) in the Alky 2
unit was deficient, in that, it did not have a grounding cable as required by r
ecognized and generally accepted good engineering practice. n.BP-Husky Refining,
LLC - Oregon, Ohio: On or about September 10, 2009, the Isobutane Coalescer (PR
511392) in the Alky 2 unit was deficient, in that, it did not have a grounding
cable as required by recognized and generally accepted good engineering practice
. o.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the B
utane Recycle Coalescer (PR 511394) in the Alky 2 unit was deficient, in that, i
t
did not have a grounding cable as required by recognized and generally accepted
good engineering practice. p.BP-Husky Refining, LLC - Oregon, Ohio: On or about
September 10, 2009, the Effluent Coalescer (PR 511399) in the Alky 2 unit was de
ficient, in that, it did not have a grounding cable as required by recognized an
d generally accepted good engineering practice. q.BP-Husky Refining, LLC - Orego
n, Ohio: On or about September 10, 2009, the Caustic Storage Drum (PR 511481) in
the Alky 2 unit was deficient, in that, it did not have a grounding cable as re
quired by recognized and generally accepted good engineering practice. r.BP-Husk
y Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the
Depropanizer Feed Treater (PR 511518) in the Alky 2 unit was deficient, in that,
it didnot have a grounding cable as required by recognized and generally accept
ed good engineering practice. s.BP-Husky Refining, LLC - Oregon, Ohio: On or abo
ut September 10, 2009, the Rerun Tower Bottoms Reboiler (PR 540007) in the Alky
2 unit was deficient, in that, it did not have a grounding cable as required by
recognized and generally accepted good engineering practice. t.BP-Husky Refining
, LLC - Oregon, Ohio: On or about September 10, 2009, the Feed Chiller (PR 54006
1) in the Alky 2 unit was deficient, in that, it did not have a grounding cable
as required by recognized and generally accepted good engineering practice. u.BP
-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the Recycle
Chiller (PR 543558) in the Alky 2 unit was deficient, in that, it did
not have a grounding cable as required by recognized and generally accepted good
engineering practice. v.BP-Husky Refining, LLC - Oregon, Ohio: On or about Sept
ember 10, 2009, the DIB Overhead Receiver (PR 511443) in the Alky 3 unit was def
icient, in that, it did not have a grounding cable as required by recognized and
generally accepted good engineering practice. w.BP-Husky Refining, LLC - Oregon
, Ohio: On or about September 10, 2009, the Hydrocarbon Degasser (PR 511743) in
the Alky 3 unit was deficient, in that, it did not have a grounding cable as req
uired by recognized and generally accepted good engineering practice. x.BP-Husky
Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the
employer did not ensure the Safety Instrumented System bypass functions overseen
in the central control room were password protected or controlled with a keyed
lock which complied with recognized and generally accepted good engineering prac
tices. y.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009,
the employer did not ensure an intervening valve between the relief device and t
he Sour Gas knock out drum (PR511923) was car sealed open and complied with reco
gnized and generally accepted good engineering practices. In accordance with 29
CFR 1903.19(d), abatement certification is required for this violation (using th
e CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation
demonstrating that abatement is complete must be included with your certificatio
n. This documentation may include, but is not limited to, evidence of the purcha
se or repair of the equipment, photographic or video evidence of abatement, or o
ther written
records.t,

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment th
at were outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: On or about September 10, 2009, the Compressor Discharge
Condenser-Top (PR 543018) in the Alky 1 unit was deficient, in that, it did not
have a grounding cable. b.BP-Husky Refining, LLC - Oregon, Ohio: On or about Sep
tember 10, 2009, the Compressor Discharge Condenser-Btm (PR 543019) in the Alky
1 unit was deficient, in that, it did not have a grounding cable. c.BP-Husky Ref
ining, LLC - Oregon, Ohio: On or about September 10, 2009, the Compressor Discha
rge Condenser-Top (PR 543020) in the Alky 1 unit was deficient, in that, it did
not have a grounding cable.
d.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the Com
pressor Discharge Condenser-Btm (PR 543021) in the Alky 1 unit was deficient, in
that, it did not have a grounding cable. e.BP-Husky Refining, LLC - Oregon, Ohi
o: On or about September 10, 2009, the Isobutane Tower Overhead Condenser-Top (P
R 543023) in the Alky 1 unit was deficient, in that, it did not have a grounding
cable. f.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009,
the Isobutane Tower Overhead Condenser-Btm (PR 543024) in the Alky 1 unit was d
eficient, in that, it did not have a grounding cable. g.BP-Husky Refining, LLC -
Oregon, Ohio: On or about September 10, 2009, the Debutanizer Overhead Condense
r-East (PR 543027) in the Alky 1 unit was deficient, in
that, it did not have a grounding cable. h.BP-Husky Refining, LLC - Oregon, Ohio
: On or about September 10, 2009, the Debutanizer Reboiler (PR 543028) in the Al
ky 1 unit was deficient, in that, it did not have a grounding cable. i.BP-Husky
Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the Debutanizer Ov
erhead Condenser-West (PR 543048) in the Alky 1 unit was deficient, in that, it
did not have a grounding cable. j.BP-Husky Refining, LLC - Oregon, Ohio: On or a
bout September 10, 2009, the Total Alkylate Cooler (PR 543238) in the Alky 1 uni
t was deficient, in that, it did not have a grounding cable. k.BP-Husky Refining
, LLC - Oregon, Ohio: On or about September 10, 2009, the Condensate Effluent Ex
changer-Top (PR 543596) in the Alky 1 unit was deficient, in
that, it did not have a grounding cable. l.BP-Husky Refining, LLC - Oregon, Ohio
: On or about September 10, 2009, the Condensate Effluent Exchanger-Btm (PR 5435
97) in the Alky 1 unit was deficient in, that, it did not have a grounding cable
. m.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the A
cid Settler/Dry Drum (PR 511383) in the Alky 2 unit was deficient, in that, it d
id not have a grounding cable. n.BP-Husky Refining, LLC - Oregon, Ohio: On or ab
out September 10, 2009, the Isobutane Coalescer (PR 511392) in the Alky 2 unit w
as deficient, in that, it did not have a grounding cable. o.BP-Husky Refining, L
LC - Oregon, Ohio: On or about September 10, 2009, the Butane Recycle Coalescer
(PR 511394) in the Alky 2 unit was deficient, in that, it
did not have a grounding cable. p.BP-Husky Refining, LLC - Oregon, Ohio: On or a
bout September 10, 2009, the Effluent Coalescer (PR 511399) in the Alky 2 unit w
as deficient, in that, it did not have a grounding cable. q.BP-Husky Refining, L
LC - Oregon, Ohio: On or about September 10, 2009, the Caustic Storage Drum (PR
511481) in the Alky 2 unit was deficient, in that, it did not have a grounding c
able. r.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, t
he Depropanizer Feed Treater (PR 511518) in the Alky 2 unit was deficient, in th
at, it did not have a grounding cable. s.BP-Husky Refining, LLC - Oregon, Ohio:
On or about September 10, 2009, the Rerun
Tower Bottoms Reboiler (PR 540007) in the Alky 2 unit was deficient, in that, it
did not have a grounding cable. t.BP-Husky Refining, LLC - Oregon, Ohio: On or
about September 10, 2009, the Feed Chiller (PR 540061) in the Alky 2 unit was de
ficient, in that, it did not have a grounding cable. u.BP-Husky Refining, LLC -
Oregon, Ohio: On or about September 10, 2009, the Recycle Chiller (PR 543558) in
the Alky 2 unit was deficient, in that, it did not have a grounding cable. v.BP
-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the DIB Ove
rhead Receiver (PR 511443) in the Alky 3 unit was deficient, in that, it did not
have a grounding cable. w.BP-Husky Refining, LLC - Oregon, Ohio: On or about Se
ptember 10, 2009, the
Hydrocarbon Degasser (PR 511743) in the Alky 3 unit was deficient, in that, it d
id not have a grounding cable. x.BP-Husky Refining, LLC - Oregon, Ohio: On or ab
out September 10, 2009, the employer did not ensure the Safety Instrumented Syst
em bypass functions overseen in the central control room were password protected
or controlled with a keyed lock. y.BP-Husky Refining, LLC - Oregon, Ohio: On or
about September 10, 2009, the employer did not ensure an intervening valve betw
een the relief device and the Sour Gas knock out drum (PR511923) was car sealed
open. 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 inc
luded with your certification. This documentation may include, but is not limite
d to, evidence
of the purchase or repair of the equipment, photographic or video evidence of ab
atement, or other written records.t,

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $5,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazard
s of the process: a.BP-Husky Refining, LLC - Oregon, Ohio: On or about September
10, 2009, the employer did not ensure the process hazard analysis for the napht
ha treater furnaces addressed the loss of combustion for the process heater. b.B
P-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employ
er did not ensure the process hazard analysis for the Vac Furnace 1 C firebox di
d not address the loss of combustion for the process heater. c.BP-Husky Refining
, LLC - Oregon, Ohio: On or about September 10, 2009, the employer did not ensur
e the process hazard analysis involving the upper pumparound
cooler (PR543576) addressed the lack of a pressure relief device to provide shel
l side protection. d.BP-Husky Refining, LLC - Oregon, Ohio: On or about Septembe
r 10, 2009, the employer did not ensure the process hazard analysis involving th
e lower pumparound cooler (PR543757) addressed the lack of a pressure relief dev
ice to provide shell side protection. e.BP-Husky Refining, LLC - Oregon, Ohio: O
n or about September 10, 2009, the employer did not ensure the porocess hazard a
nalysis involving the primary absorber lean oil coolers (PR543585) addressed the
lack of a pressure relief device to provide shell side protection. f.BP-Husky R
efining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer did no
t ensure the process hazed analysis involving the primary absorber
lean oil coolers (PR543586) addressed the lack of a pressure relief device to pr
ovide shell side protection. g.BP-Husky Refining, LLC - Oregon, Ohio: On or abou
t September 10, 2009, the employer did not ensure the process hazard analysis in
volving the stripper reboiler condensate pot (PR511134) addressed the lack of a
pressure relief device to provide tube side protection. h.BP-Husky Refining, LLC
- Oregon, Ohio: On or about September 10, 2009, the employer did not ensure the
process hazard analysis involving the stripper steam reboiler (PR543538) addres
sed the lack of a pressure relief device to provide tube side protection. i.BP-H
usky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer
did not ensure the process hazard analysis involving the stripper CHGO
Reboiler (PR543539) addressed the lack of a pressure relief device to provide tu
be side protection. In accordance with 29 CFR 1903.19(d), abatement certificatio
n is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION W
ORKSHEET), and in addition, documentation demonstrating that abatement is comple
te must be included with your certification. This documentation may include, but
is not limited to, evidence of the purchase or repair of the equipment, photogr
aphic or video evidence of abatement, or other written records.t,

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $5,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(6): The employer did not ensure after the initial process haz
ard analysis that the process hazard analysis was updated and revalidated at lea
st every five (5) years by a team meeting the requirements of 29 CFR 1910.119(e)
(4): a.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, th
e employer did not ensure a layer of protection analysis (LOPA) was performed as
part of
the company's process hazard analysis (PHA) revalidation of the FCC unit require
d by the company's PHA guidelines. The PHA for the FCC was conducted in April 20
08, but as of September 10, 2009, the LOPA had not been performed to determine i
f hazards identified in the PHA resulted in recommendations requiring action. b.
BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the emplo
yer did not ensure corporate generic hazard scenarios which may result in a SIL
1 or lower safety instrumented system (SIS), were evaluated for a large number o
f process units. The company received the hazard scenerios in March 2009 and did
not have plans on evaluating the hazard scenarios until May 2015. 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, docum
entation demonstrating that abatement is complete must be included with your
certification. This documentation may include, but is not limited to, evidence o
f the purchase or repair of the equipment, photographic or video evidence of aba
tement, or other written records.

Issued

Mar 8, 2010

Abate by

Mar 8, 2010

Penalty

Initial $5,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written proc
edures to maintain the on-going mechanical integrity of process equipment: a.BP-
Husky Refining, LLC located in Oregon, Ohio: On or about September 2009, the emp
loyer's written mechanical integrity procedures did not reflect the recently ini
tiated practice of changing the piping inspection interval from the thickness me
asurement location (TML) level to the circuit level. In accordance with 29 CFR 1
903.19(d), abatement certification is required for this violation (using the CER
TIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demon
strating that abatement is complete must be included with your certification. Th
is documentation may include, but is not limited to, evidence of the purchase
or repair of the equipment, photographic or video evidence of abatement, or othe
r written records.t,

Issued

Mar 8, 2010

Abate by

Mar 29, 2010

Penalty

Initial $5,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): Inspections and tests were not performed on process eq
uipment to maintain its mechanical integrity: a.BP-Husky Refining, LLC located i
n Oregon, Ohio: On or about September 10, 2009, the employer did not ensure the
pressure gauge for the butylene feed coalescer (PR 51- 1467) located in the Alky
1 unit was calibrated on a periodic basis, per manufacturer guidelines. b.BP-Hu
sky Refining, LLC located in Oregon, Ohio: On or about September 10, 2009, the e
mployer did not ensure the pressure gauges for the recycle isobutane coalescer (
PR 51-1469) located in the Alky 1 unit were calibrated on a periodic basis, per
manufacturer guidelines. In accordance with 29 CFR 1903.19(c), abatement certifi
cation is required for
this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(m)(1): The employer did not investigate each incident which resu
lted in, or could reasonably have resulted in, a catastrophic release of a highl
y hazardous chemical in the workplace: a.BP-Husky Refining, LLC - Oregon, Ohio:
On or about May 17, 2006, the employer failed to initiate an incident investigat
ion following the identification of hydrocarbons in the fire water system in the
Crude 2 Unit. Incident report 2006-IR-1837512 was entered into the computerized
incident tracking system, but it was classified as a near miss, no
incident investigation team was established to investigate, the 'Comprehensive L
ist of Causes' did not contain the source of the cross contamination of hydrocar
bons into the fire water system, there were no findings or causal factors relate
d to the incident, and there were no recommendations made. b.BP-Husky Refining,
LLC - Oregon, Ohio: On or about February 10, 2008, the employer failed to initia
te an incident investigation following the identification of zyme contamination
in the fire water system in the Crude Vac 2 Unit. Incident report 2008- IR-28054
54 was entered into the computerized incident tracking system, but it was classi
fied as a near miss, "no formal investigation at this time" was entered into the
form, there was no identification of factors that contributed to the incident,
the source of the contamination was not identified, and there were no recommenda
tions made.
c.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 29, 2009, the emp
loyer did not conduct an incident investigation for the leak in the flare line a
t the blowdown drum tie-in point in the Alky 1 unit. In accordance with 29 CFR 1
903.19(d), abatement certification is required for this violation (using the CER
TIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demon
strating that abatement is complete must be included with your certification. Th
is 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 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $5,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they had evaluated comp
liance with the provisions of 29 CFR 1910.119 at least every three years to veri
fy that the procedures and practices developed under this standard were adequate
and are being followed: a.BP-Husky Refining, LLC - Oregon, Ohio: On or about Se
ptember 10, 2009, the employer did not certify that a statistically significant
number of pressure vessel inspection records were reviewed during the 2009 compl
iance audit to verify the vessel inspection procedures were adequate and being f
ollowed. b.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009
, the employer did not certify that a statistically significant number of piping
circuit inspection
records during the 2009 compliance audit were reviewed to verify that the piping
inspection procedures were adequate and being followed. c.BP-Husky Refining, LL
C - Oregon, Ohio: On or about September 10, 2009, the employer did not certify t
hat a statistically significant number of instrument control loops were reviewed
during the 2009 compliance audit. In accordance with 29 CFR 1903.19(d), abateme
nt certification is required for this violation (using the CERTIFICATION OF CORR
ECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abat
ement is complete must be included with your certification. This documentation m
ay include, but is not limited to, evidence of the purchase or repair of the equ
ipment, photographic or video evidence of abatement, or other written records.t,

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i): Process safety information pertaining to the equipment
in the process does not include the elements specified in 29 CFR 1910.119(d)(3)
(i)(A) through (H): a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does n
ot maintain a U-1 form for the Isobutane Recycler Coalescer (PR 511468).
Pursuant to 29 CFR 1903.19, within ten (10) calendar days after the abatement da
te, the employer must submit documentation that it has abated the violation. In
addition, under 29 CFR 1903.19(e), the employer shall submit an abatement plan d
escribing the actions it is taking to ensure that it is in compliance with the s
tandard including steps to assure that it has written and accurate process safet
y information for all pressure vessels at the refinery. The abatement plan shall
establish dates during the next three months when surveys shall be completed an
d the information shall be finally compiled. Once the plan has been fully implem
ented, the employer must submit certification of its full compliance with the st
andard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
that PSV- 134 providing pressure relief protection to the Debutanizer Reflux Dru
m in the Alky Unit
complied with recognized and generally accepted good engineering practices in th
at it has an inlet pressure drop greater than 3 PSV-134 was determined to have a
n inlet pressure drop of 3.8 Pursuant to 29 CFR 1903.19, within ten (10) calenda
r days of the abatement date, the employer must submit documentation that it has
abated the hazard. In addition, under 29 CFR 1903.19(e), the employer shall sub
mit an abatement plan describing the actions it is taking to ensure that it is i
n compliance with the standards including documentation that each pressure relie
f valve and associated piping for all process units have been evaluated and, if
necessary, repaired or replaced to ensure inlet pressure drop is limited in acco
rdance with recognized and generally accepted good engineering practices, such a
s API Recommended Practice 520 and the ASME Boiler and Pressure Vessel Code. The
abatement plan shall establish dates during the next three months when the eval
uations, repairs, and replacements shall be completed. Once the
plan has been fully implemented, the employer must submit certification of its f
ull compliance with the standard.e

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits [as defined by process information in 29 CFR 1
910.119(d)] before further use or in a safe and timely manner: a.BP-Husky Refini
ng, LLC - Oregon, Ohio: The employer does not ensure PSV-134, located in the Alk
y Unit, has an inlet pressure drop of not more than 3 PSV-134 was determined to
have an inlet pressure drop of 3.8 Pursuant to 29 CFR 1903.19, within ten (10) c
alendar days of the abatement date, the employer must submit documentation that
it has abated the hazard. In addition, under 29 CFR 1903.19(e), the employer sha
ll submit an abatement plan describing the actions it is taking to ensure that i
t is in compliance with the standards including documentation that each pressure
relief valve and associated piping for all process units have been evaluated an
d, if necessary,
repaired or replaced to ensure inlet pressure drop is limited in accordance with
recognized and generally accepted good engineering practices, such as API Recom
mended Practice 520 and the ASME Boiler and Pressure Vessel Code. The abatement
plan shall establish dates during the next three months when the evaluations, re
pairs, and replacements shall be completed. Once the plan has been fully impleme
nted, the employer must submit certification of its full compliance with the sta
ndard.e

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
that PSV-137 providing pressure relief protection to the First Stage Butane Trea
ter Drum in the Alky Unit complied with recognized and generally accepted good e
ngineering practices, in that, it has an inlet pressure drop greater than 3 PSV-
137 was
determined to have an inlet pressure drop of 4.6 Pursuant to 29 CFR 1903.19, wit
hin ten (10) calendar days of the abatement date, the employer must submit docum
entation that it has abated the hazard. In addition, under 29 CFR 1903.19(e), th
e employer shall submit an abatement plan describing the actions it is taking to
ensure that it is in compliance with the standards including documentation that
each pressure relief valve and associated piping for all process units have bee
n evaluated and, if necessary, repaired or replaced to ensure inlet pressure dro
p is limited in accordance with recognized and generally accepted good engineeri
ng practices, such as API Recommended Practice 520 and the ASME Boiler and Press
ure Vessel Code. The abatement plan shall establish dates during the next three
months when the evaluations, repairs, and replacements shall be completed. Once
the plan has been fully implemented, the employer must submit certification of i
ts full compliance with the standard.e

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment
that are 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.BP-Husky Refini
ng, LLC - Oregon, Ohio: The employer does not ensure PSV-137, located in the Alk
y Unit, has an inlet pressure drop of not more than 3 PSV-137 was determined to
have an inlet pressure drop of 4.6 Pursuant to 29 CFR 1903.19, within ten (10) c
alendar days of the abatement date, the employer must submit documentation that
it has abated the hazard. In addition, under 29 CFR 1903.19(e), the employer sha
ll submit an abatement plan describing the actions it is taking to ensure that i
t is in compliance with the standards including documentation that each pressure
relief valve and associated piping for all process units have been evaluated an
d, if necessary, repaired or replaced to ensure inlet pressure drop is limited i
n accordance with recognized and generally accepted
good engineering practices, such as API Recommended Practice 520 and the ASME Bo
iler and Pressure Vessel Code. The abatement plan shall establish dates during t
he next three months when the evaluations, repairs, and replacements shall be co
mpleted. Once the plan has been fully implemented, the employer must submit cert
ification of its full compliance with the standard.e

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
that PSV-447 providing pressure relief protection to the Depropanizer Feed Treat
er Drum in the Alky Unit complies with recognized and generally accepted good en
gineering practices, in that, it has an inlet pressure drop greater than 3 PSV-4
47 was determined to have an inlet pressure drop of 5.4 Pursuant to 29 CFR 1903.
19, within ten (10) calendar days of the abatement date,
the employer must submit documentation that it has abated the hazard. In additio
n, under 29 CFR 1903.19(e), the employer shall submit an abatement plan describi
ng the actions it is taking to ensure that it is in compliance with the standard
s including documentation that each pressure relief valve and associated piping
for all process units have been evaluated and, if necessary, repaired or replace
d to ensure inlet pressure drop is limited in accordance with recognized and gen
erally accepted good engineering practices, such as API Recommended Practice 520
and the ASME Boiler and Pressure Vessel Code. The abatement plan shall establis
h dates during the next three months when the evaluations, repairs, and replacem
ents shall be completed. Once the plan has been fully implemented, the employer
must submit certification of its full compliance with the standard.e

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before
further use or in a safe and timely manner: a.BP-Husky Refining, LLC - Oregon, O
hio: The employer does not ensure PSV-447, located in the Alky Unit, has an inle
t pressure drop of not more than 3 PSV-447 was determined to have an inlet press
ure drop of 5.4 Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the
abatement date, the employer must submit documentation that it has abated the h
azard. In addition, under 29 CFR 1903.19(e), the employer shall submit an abatem
ent plan describing the actions it is taking to ensure that it is in compliance
with the standards including documentation that each pressure relief valve and a
ssociated piping for all process units have been evaluated and, if necessary, re
paired or replaced to ensure inlet pressure drop is limited in accordance with r
ecognized and generally accepted good engineering practices, such as API Recomme
nded Practice 520 and the ASME Boiler and Pressure Vessel Code. The abatement pl
an
shall establish dates during the next three months when the evaluations, repairs
, and replacements shall be completed. Once the plan has been fully implemented,
the employer must submit certification of its full compliance with the standard
.e

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
that PSV-1299 providing relief protection to the Cat Gas Light Oil/BFW Preheater
complies with recognized and generally accepted good engineering practices, in
that, it has an inlet pressure drop greater than 3 PSV-1299 was determined to ha
ve an inlet pressure drop of 5.0 Pursuant to 29 CFR 1903.19, within ten (10) cal
endar days of the abatement date, the employer must submit documentation that it
has abated the hazard. In addition, under 29
CFR 1903.19(e), the employer shall submit an abatement plan describing the actio
ns it is taking to ensure that it is in compliance with the standards including
documentation that each pressure relief valve and associated piping for all proc
ess units have been evaluated and, if necessary, repaired or replaced to ensure
inlet pressure drop is limited in accordance with recognized and generally accep
ted good engineering practices, such as API Recommended Practice 520 and the ASM
E Boiler and Pressure Vessel Code. The abatement plan shall establish dates duri
ng the next three months when the evaluations, repairs, and replacements shall b
e completed. Once the plan has been fully implemented, the employer must submit
certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner:
a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not ensure PSV-1299,
located in the Alky Unit, has an inlet pressure drop of not more than 3 PSV-1299
was determined to have an inlet pressure drop of 5.0 Pursuant to 29 CFR 1903.19
, within ten (10) calendar days of the abatement date, the employer must submit
documentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e
), the employer shall submit an abatement plan describing the actions it is taki
ng to ensure that it is in compliance with the standards including documentation
that each pressure relief valve and associated piping for all process units hav
e been evaluated and, if necessary, repaired or replaced to ensure inlet pressur
e drop is limited in accordance with recognized and generally accepted good engi
neering practices, such as API Recommended Practice 520 and the ASME Boiler and
Pressure Vessel Code. The abatement plan shall establish dates during the next t
hree months when the evaluations, repairs,
and replacements shall be completed. Once the plan has been fully implemented, t
he employer must submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
that PSV-1301 providing pressure relief protection to the FCC Feed Drum in the F
CC Unit complies with recognized and generally accepted good engineering practic
es, in that, it has an inlet pressure drop greater than 3 PSV-1301 was determine
d to have an inlet pressure drop of 6.3 Pursuant to 29 CFR 1903.19, within ten (
10) calendar days of the abatement date, the employer must submit documentation
that it has abated the hazard. In addition, under 29
CFR 1903.19(e), the employer shall submit an abatement plan describing the actio
ns it is taking to ensure that it is in compliance with the standards including
documentation that each pressure relief valve and associated piping for all proc
ess units have been evaluated and, if necessary, repaired or replaced to ensure
inlet pressure drop is limited in accordance with recognized and generally accep
ted good engineering practices, such as API Recommended Practice 520 and the ASM
E Boiler and Pressure Vessel Code. The abatement plan shall establish dates duri
ng the next three months when the evaluations, repairs, and replacements shall b
e completed. Once the plan has been fully implemented, the employer must submit
certification of its full compliance with the standard.e

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not ensure PSV-1301,
located in the Alky Unit, has an inlet pressure drop of not more than 3 PSV-1301
was determined to have an inlet pressure drop of 6.3 Pursuant to 29 CFR 1903.19
, within ten (10) calendar days of the abatement date, the employer must submit
documentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e
), the employer shall submit an abatement plan describing the actions it is taki
ng to ensure that it is in compliance with the standards including documentation
that each pressure relief valve and associated piping for all process units hav
e been evaluated and, if necessary, repaired or replaced to ensure inlet pressur
e drop is limited in accordance with recognized and generally accepted good engi
neering practices, such as API Recommended Practice 520 and the ASME Boiler and
Pressure Vessel Code. The abatement plan shall establish dates during the next t
hree months when the evaluations, repairs, and replacements
shall be completed. Once the plan has been fully implemented, the employer must
submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
that PSV-1321 providing pressure relief protection to the Fractionator Tower in
the FCC Unit complies with recognized and generally accepted good engineering pr
actices, in that, it has an inlet pressure drop greater than 3 PSV-1321 was dete
rmined to have an inlet pressure drop of 3.2 Pursuant to 29 CFR 1903.19, within
ten (10) calendar days of the abatement date, the employer must submit documenta
tion that it has abated the hazard. In addition, under 29 CFR 1903.19(e), the em
ployer shall submit an abatement plan describing the actions
it is taking to ensure that it is in compliance with the standards including doc
umentation that each pressure relief valve and associated piping for all process
units have been evaluated and, if necessary, repaired or replaced to ensure inl
et pressure drop is limited in accordance with recognized and generally accepted
good engineering practices, such as API Recommended Practice 520 and the ASME B
oiler and Pressure Vessel Code. The abatement plan shall establish dates during
the next three months when the evaluations, repairs, and replacements shall be c
ompleted. Once the plan has been fully implemented, the employer must submit cer
tification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not ensure PSV-1321,
located in the Alky Unit, has an inlet pressure drop of not more than 3 PSV-1321
was determined to have an inlet pressure drop of 3.2 Pursuant to 29 CFR 1903.19
, within ten (10) calendar days of the abatement date, the employer must submit
documentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e
), the employer shall submit an abatement plan describing the actions it is taki
ng to ensure that it is in compliance with the standards including documentation
that each pressure relief valve and associated piping for all process units hav
e been evaluated and, if necessary, repaired or replaced to ensure inlet pressur
e drop is limited in accordance with recognized and generally accepted good engi
neering practices, such as API Recommended Practice 520 and the ASME Boiler and
Pressure Vessel Code. The abatement plan shall establish dates during the next t
hree months when the evaluations, repairs, and replacements
shall be completed. Once the plan has been fully implemented, the employer must
submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
that PSV-1338A providing pressure relief protection to the First Stage Drum in t
he FCC Unit complies with recognized and generally accepted good engineering pra
ctices, in that, it has an inlet pressure drop greater than 3 PSV-1338A was dete
rmined to have an inlet pressure drop of 3.2 Pursuant to 29 CFR 1903.19, within
ten (10) calendar days of the abatement date, the employer must submit documenta
tion that it has abated the hazard. In addition, under 29 CFR 1903.19(e), the em
ployer shall submit an abatement plan describing the actions
it is taking to ensure that it is in compliance with the standards including doc
umentation that each pressure relief valve and associated piping for all process
units have been evaluated and, if necessary, repaired or replaced to ensure inl
et pressure drop is limited in accordance with recognized and generally accepted
good engineering practices, such as API Recommended Practice 520 and the ASME B
oiler and Pressure Vessel Code. The abatement plan shall establish dates during
the next three months when the evaluations, repairs, and replacements shall be c
ompleted. Once the plan has been fully implemented, the employer must submit cer
tification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not ensure PSV-
1338A, located in the FCC Unit, has an inlet pressure drop of not more than 3 PS
V-1338A was determined to have an inlet pressure drop of 3.2 Pursuant to 29 CFR
1903.19, within ten (10) calendar days of the abatement date, the employer must
submit documentation that it has abated the hazard. In addition, under 29 CFR 19
03.19(e), the employer shall submit an abatement plan describing the actions it
is taking to ensure that it is in compliance with the standards including docume
ntation that each pressure relief valve and associated piping for all process un
its have been evaluated and, if necessary, repaired or replaced to ensure inlet
pressure drop is limited in accordance with recognized and generally accepted go
od engineering practices, such as API Recommended Practice 520 and the ASME Boil
er and Pressure Vessel Code. The abatement plan shall establish dates during the
next three months when the evaluations, repairs, and replacements shall be comp
leted. Once the plan has been fully implemented, the employer must
submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
that PSV-1280 providing pressure relief protection to the FCC Feed Drum in the F
CC Unit complies with recognized and generally accepted good engineering practic
es, in that, it has an inlet pressure drop greater than 3 PSV-1280 was determine
d to have an inlet pressure drop of 7.7 Pursuant to 29 CFR 1903.19, within ten (
10) calendar days of the abatement date, the employer must submit documentation
that it has abated the hazard. In addition, under 29 CFR 1903.19(e), the employe
r shall submit an abatement plan describing the actions it is
taking to ensure that it is in compliance with the standards including documenta
tion that each pressure relief valve and associated piping for all process units
have been evaluated and, if necessary, repaired or replaced to ensure inlet pre
ssure drop is limited in accordance with recognized and generally accepted good
engineering practices, such as API Recommended Practice 520 and the ASME Boiler
and Pressure Vessel Code. The abatement plan shall establish dates during the ne
xt three months when the evaluations, repairs, and replacements shall be complet
ed. Once the plan has been fully implemented, the employer must submit certifica
tion of its full compliance with the standard.e

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not ensure PSV-1280, located in the FCC
Unit, has an inlet pressure drop of not more than 3 PSV-1280
was determined to have an inlet pressure drop of 7.7 Pursuant to 29 CFR 1903.19,
within ten (10) calendar days of the abatement date, the employer must submit d
ocumentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e)
, the employer shall submit an abatement plan describing the actions it is takin
g to ensure that it is in compliance with the standards including documentation
that each pressure relief valve and associated piping for all process units have
been evaluated and, if necessary, repaired or replaced to ensure inlet pressure
drop is limited in accordance with recognized and generally accepted good engin
eering practices, such as API Recommended Practice 520 and the ASME Boiler and P
ressure Vessel Code. The abatement plan shall establish dates during the next th
ree months when the evaluations, repairs, and replacements shall be completed. O
nce the plan has been fully implemented, the employer must submit
certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
that PSV-1281 providing pressure relief protection to the FCC Feed Drum in the F
CC Unit complies with recognized and generally accepted good engineering practic
es, in that, it has an inlet pressure drop of greater than 3 PSV-1281 was determ
ined to have an inlet pressure drop of 7.7 Pursuant to 29 CFR 1903.19, within te
n (10) calendar days of the abatement date, the employer must submit documentati
on that it has abated the hazard. In addition, under 29 CFR 1903.19(e), the empl
oyer shall submit an abatement plan describing the actions it is taking to ensur
e that it is in compliance with the standards including documentation
that each pressure relief valve and associated piping for all process units have
been evaluated and, if necessary, repaired or replaced to ensure inlet pressure
drop is limited in accordance with recognized and generally accepted good engin
eering practices, such as API Recommended Practice 520 and the ASME Boiler and P
ressure Vessel Code. The abatement plan shall establish dates during the next th
ree months when the evaluations, repairs, and replacements shall be completed. O
nce the plan has been fully implemented, the employer must submit certification
of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not ensure PSV-1281, located in the FCC
Unit, has an inlet pressure drop of not more than 3 PSV-1281
was determined to have an inlet pressure drop of 7.7 Pursuant to 29 CFR 1903.19,
within ten (10) calendar days of the abatement date, the employer must submit d
ocumentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e)
, the employer shall submit an abatement plan describing the actions it is takin
g to ensure that it is in compliance with the standards including documentation
that each pressure relief valve and associated piping for all process units have
been evaluated and, if necessary, repaired or replaced to ensure inlet pressure
drop is limited in accordance with recognized and generally accepted good engin
eering practices, such as API Recommended Practice 520 and the ASME Boiler and P
ressure Vessel Code. The abatement plan shall establish dates during the next th
ree months when the evaluations, repairs, and replacements shall be completed. O
nce the plan has been fully implemented, the employer must submit
certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
that PSV-1332 providing pressure relief protection to the Stripper Tower in the
FCC Unit complies with recognized and generally accepted good engineering practi
ces, in that, it has an inlet pressure drop greater than 3 PSV-1332 was determin
ed to have an inlet pressure drop of 8.8 Pursuant to 29 CFR 1903.19, within ten
(10) calendar days of the abatement date, the employer must submit documentation
that it has abated the hazard. In addition, under 29 CFR 1903.19(e), the employ
er shall submit an abatement plan describing the actions it is taking to ensure
that it is in compliance with the standards including documentation
that each pressure relief valve and associated piping for all process units have
been evaluated and, if necessary, repaired or replaced to ensure inlet pressure
drop is limited in accordance with recognized and generally accepted good engin
eering practices, such as API Recommended Practice 520 and the ASME Boiler and P
ressure Vessel Code. The abatement plan shall establish dates during the next th
ree months when the evaluations, repairs, and replacements shall be completed. O
nce the plan has been fully implemented, the employer must submit certification
of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not ensure PSV-1332, located in the FCC
Unit, has an inlet pressure drop of not more than 3 PSV-1332
was determined to have an inlet pressure drop of 8.8 Pursuant to 29 CFR 1903.19,
within ten (10) calendar days of the abatement date, the employer must submit d
ocumentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e)
, the employer shall submit an abatement plan describing the actions it is takin
g to ensure that it is in compliance with the standards including documentation
that each pressure relief valve and associated piping for all process units have
been evaluated and, if necessary, repaired or replaced to ensure inlet pressure
drop is limited in accordance with recognized and generally accepted good engin
eering practices, such as API Recommended Practice 520 and the ASME Boiler and P
ressure Vessel Code. The abatement plan shall establish dates during the next th
ree months when the evaluations, repairs, and replacements shall be completed. O
nce the plan has been fully implemented, the employer must submit
certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
that PSV-440 providing pressure relief protection to the Rerun Tower in the Alky
Unit complies with recognized and generally accepted good engineering practices
, in that, it has an inlet pressure drop greater than 3 PSV-440 was determined t
o have an inlet pressure drop of 6.8 Pursuant to 29 CFR 1903.19, within ten (10)
calendar days of the abatement date, the employer must submit documentation tha
t it has abated the hazard. In addition, under 29 CFR 1903.19(e), the employer s
hall submit an abatement plan describing the actions it is taking to ensure that
it is in compliance with the standards including documentation
that each pressure relief valve and associated piping for all process units have
been evaluated and, if necessary, repaired or replaced to ensure inlet pressure
drop is limited in accordance with recognized and generally accepted good engin
eering practices, such as API Recommended Practice 520 and the ASME Boiler and P
ressure Vessel Code. The abatement plan shall establish dates during the next th
ree months when the evaluations, repairs, and replacements shall be completed. O
nce the plan has been fully implemented, the employer must submit certification
of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not ensure PSV-440, located in the Alky
Unit, has an inlet pressure drop of not more than 3 PSV-440
was determined to have an inlet pressure drop of 6.8 Pursuant to 29 CFR 1903.19,
within ten (10) calendar days of the abatement date, the employer must submit d
ocumentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e)
, the employer shall submit an abatement plan describing the actions it is takin
g to ensure that it is in compliance with the standards including documentation
that each pressure relief valve and associated piping for all process units have
been evaluated and, if necessary, repaired or replaced to ensure inlet pressure
drop is limited in accordance with recognized and generally accepted good engin
eering practices, such as API Recommended Practice 520 and the ASME Boiler and P
ressure Vessel Code. The abatement plan shall establish dates during the next th
ree months when the evaluations, repairs, and replacements shall be completed. O
nce the plan has been fully implemented, the employer must submit
certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
compliance with recognized and generally accepted good engineering practices by
ensuring PSV-115, located in the Alky Unit, is properly designed. PSV-115 provid
es protection to the Recycle Isobutane Coalescer by relieving hydrocarbons to th
e flare and was determined to be undersized and does not have an adequate reliev
ing rate during relief scenarios. Pursuant to 29 CFR 1903.19, within ten (10) ca
lendar days of the abatement date, the employer must submit documentation that i
t has abated the hazard. In addition, under 29 CFR 1903.19(e), the employer must
submit an abatement plan describing the actions it is taking to ensure that it
is in compliance with the standards for all pressure vessels in the refinery,
including documentation that each pressure vessel is evaluated and protected by
pressure-relieving device(s) that is appropriate for the vessel in accordance wi
th recognized and generally accepted good engineering practices, such as the ASM
E Boiler and Pressure Vessel Code. The abatement plan shall establish dates duri
ng the next three months when the evaluations and installation of adequate overp
ressure protection shall be completed. Once the plan has been fully implemented,
the employer must submit certification of its full compliance with the standard
.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not ensure PSV-115, located in the Alky
Unit, is properly designed. PSV-115 provides protection to the
Recycle Isobutane Coalescer by relieving hydrocarbons to the flare and was deter
mined to be undersized and does not have an adequate relieving rate during relie
f scenarios. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the ab
atement date, the employer must submit documentation that it has abated the haza
rd. In addition, under 29 CFR 1903.19(e), the employer must submit an abatement
plan describing the actions it is taking to ensure that it is in compliance with
the standards for all pressure vessels in the refinery, including documentation
that each pressure vessel is evaluated and protected by pressure-relieving devi
ce(s) that is appropriate for the vessel in accordance with recognized and gener
ally accepted good engineering practices, such as the ASME Boiler and Pressure V
essel Code. The abatement plan shall establish dates during the next three month
s when the evaluations and installation of adequate overpressure protection shal
l be completed. Once the plan has been fully implemented,
the employer must submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
compliance with recognized and generally accepted good engineering practices by
ensuring PSV-124, located in the Alky Unit, is properly designed. PSV-124 provid
es protection to the Isobutane Product Coalescer by relieving hydrocarbons to th
e flare and was determined to be undersized and does not have an adequate reliev
ing rate during relief scenarios. Pursuant to 29 CFR 1903.19, within ten (10) ca
lendar days of the abatement date, the employer must submit documentation that i
t has abated the hazard. In addition, under 29 CFR 1903.19(e), the employer must
submit an abatement plan describing the actions it is taking to ensure that it
is in compliance with the standards for all pressure vessels in the refinery, in
cluding documentation that each pressure vessel is evaluated and protected by pr
essure-relieving device(s) that is appropriate for the vessel in accordance with
recognized and generally accepted good engineering practices, such as the ASME
Boiler and Pressure Vessel Code. The abatement plan shall establish dates during
the next three months when the evaluations and installation of adequate overpre
ssure protection shall be completed. Once the plan has been fully implemented, t
he employer must submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not ensure PSV-124,
located in the Alky Unit, is properly designed. PSV-124 provides protection to t
he Isobutane Product Coalescer by relieving hydrocarbons to the flare and was de
termined to be undersized and does not have an adequate relieving rate during re
lief scenarios. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the
abatement date, the employer must submit documentation that it has abated the h
azard. In addition, under 29 CFR 1903.19(e), the employer must submit an abateme
nt plan describing the actions it is taking to ensure that it is in compliance w
ith the standards for all pressure vessels in the refinery, including documentat
ion that each pressure vessel is evaluated and protected by pressure-relieving d
evice(s) that is appropriate for the vessel in accordance with recognized and ge
nerally accepted good engineering practices, such as the ASME Boiler and Pressur
e Vessel Code. The abatement plan shall establish dates during the next three mo
nths when the evaluations and installation of
adequate overpressure protection shall be completed. Once the plan has been full
y implemented, the employer must submit certification of its full compliance wit
h the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
compliance with recognized and generally accepted good engineering practices by
ensuring PSV-136, located in the Alky Unit, is properly designed. PSV-136 provid
es protection to the Second Stage Butane Treater Drum by relieving hydrocarbons
to the flare and was determined be undersized and does not have an adequate reli
eving rate during relief scenarios. Pursuant to 29 CFR 1903.19, within ten (10)
calendar days of the abatement date, the employer must submit documentation that
it has abated the hazard. In addition, under
29 CFR 1903.19(e), the employer must submit an abatement plan describing the act
ions it is taking to ensure that it is in compliance with the standards for all
pressure vessels in the refinery, including documentation that each pressure ves
sel is evaluated and protected by pressure-relieving device(s) that is appropria
te for the vessel in accordance with recognized and generally accepted good engi
neering practices, such as the ASME Boiler and Pressure Vessel Code. The abateme
nt plan shall establish dates during the next three months when the evaluations
and installation of adequate overpressure protection shall be completed. Once th
e plan has been fully implemented, the employer must submit certification of its
full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner:
a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not ensure PSV-136, l
ocated in the Alky Unit, is properly designed. PSV-136 provides protection to th
e Second Stage Butane Treater Drum by relieving hydrocarbons to the flare and wa
s determined to be undersized and does not have an adequate relieving rate durin
g relief scenarios. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of
the abatement date, the employer must submit documentation that it has abated t
he hazard. In addition, under 29 CFR 1903.19(e), the employer must submit an aba
tement plan describing the actions it is taking to ensure that it is in complian
ce with the standards for all pressure vessels in the refinery, including docume
ntation that each pressure vessel is evaluated and protected by pressure-relievi
ng device(s) that is appropriate for the vessel in accordance with recognized an
d generally accepted good engineering practices, such as the ASME Boiler and Pre
ssure Vessel Code.
The abatement plan shall establish dates during the next three months when the e
valuations and installation of adequate overpressure protection shall be complet
ed. Once the plan has been fully implemented, the employer must submit certifica
tion of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
compliance with recognized and generally accepted good engineering practices by
ensuring PSV- 1280, a conventional relief valve, has a back pressure of less tha
n or equal to 10of its set pressure. This relief device provides protection to t
he FCC Feed Drum, and relieves hydrocarbons to the flare. Pursuant to 29 CFR 190
3.19, within ten (10) calendar days of the abatement date, the employer
must submit documentation that it has abated the hazard. In addition, under 29 C
FR 1903.19(e), the employer shall submit an abatement plan describing the action
s it is taking to ensure that it is in compliance with the standards including d
ocumentation that each pressure relief valve and associated piping for all proce
ss units have been evaluated and, if necessary, repaired or replaced to ensure b
ackpressure is limited in accordance with recognized and generally accepted good
engineering practices, such as API Recommended Practice 520/521 and the ASME Bo
iler and Pressure Vessel Code. The abatement plan shall establish dates during t
he next three months when the evaluations, repairs, and replacements shall be co
mpleted. Once the plan has been fully implemented, the employer must submit cert
ification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner:
a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not ensure PSV-1280,
a conventional relief valve, has a back pressure of less than or equal to 10% of
its set pressure. This relief device provides inadequate protection to the FCC
Feed Drum, and relieves hydrocarbons to the flare. Pursuant to 29 CFR 1903.19, w
ithin ten (10) calendar days of the abatement date, the employer must submit doc
umentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e),
the employer shall submit an abatement plan describing the actions it is taking
to ensure that it is in compliance with the standards including documentation th
at each pressure relief valve and associated piping for all process units have b
een evaluated and, if necessary, repaired or replaced to ensure backpressure is
limited in accordance with recognized and generally accepted good engineering pr
actices, such as API Recommended Practice 520/521 and the ASME Boiler and
Pressure Vessel Code. The abatement plan shall establish dates during the next t
hree months when the evaluations, repairs, and replacements shall be completed.
Once the plan has been fully implemented, the employer must submit certification
of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
compliance with recognized and generally accepted good engineering practices by
ensuring PSV- 1281, a conventional relief valve, has a back pressure of less tha
n or equal to 10of its set pressure. This relief device provides inadequate prot
ection to the FCC Feed Drum, and relieves hydrocarbons to the flare. Pursuant to
29 CFR 1903.19, within ten (10) calendar days of the abatement date, the employ
er must submit documentation that it has abated the hazard. In addition, under
29 CFR 1903.19(e), the employer shall submit an abatement plan describing the ac
tions it is taking to ensure that it is in compliance with the standards includi
ng documentation that each pressure relief valve and associated piping for all p
rocess units have been evaluated and, if necessary, repaired or replaced to ensu
re backpressure is limited in accordance with recognized and generally accepted
good engineering practices, such as API Recommended Practice 520/521 and the ASM
E Boiler and Pressure Vessel Code. The abatement plan shall establish dates duri
ng the next three months when the evaluations, repairs, and replacements shall b
e completed. Once the plan has been fully implemented, the employer must submit
certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner:
a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not ensure PSV-1281,
a conventional relief valve, had a back pressure of less than or equal to 10% of
its set pressure. This relief device provides inadequate protection to the FCC
Feed Drum, and relieves hydrocarbons to the flare. Pursuant to 29 CFR 1903.19, w
ithin ten (10) calendar days of the abatement date, the employer must submit doc
umentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e),
the employer shall submit an abatement plan describing the actions it is taking
to ensure that it is in compliance with the standards including documentation th
at each pressure relief valve and associated piping for all process units have b
een evaluated and, if necessary, repaired or replaced to ensure backpressure is
limited in accordance with recognized and generally accepted good engineering pr
actices, such as API Recommended Practice 520/521 and the ASME Boiler and Pressu
re Vessel Code. The abatement plan shall establish dates during the next
three months when the evaluations, repairs, and replacements shall be completed.
Once the plan has been fully implemented, the employer must submit certificatio
n of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
compliance with recognized and generally accepted good engineering practices by
ensuring PSV- 1301, a conventional relief valve, has a back pressure of less tha
n or equal to 10of its set pressure. This relief device provides inadequate prot
ection to the FCC Feed Drum, and relieves hydrocarbons to the flare. Pursuant to
29 CFR 1903.19, within ten (10) calendar days of the abatement date, the employ
er must submit documentation that it has abated the hazard. In addition, under 2
9 CFR 1903.19(e),
the employer shall submit an abatement plan describing the actions it is taking
to ensure that it is in compliance with the standards including documentation th
at each pressure relief valve and associated piping for all process units have b
een evaluated and, if necessary, repaired or replaced to ensure backpressure is
limited in accordance with recognized and generally accepted good engineering pr
actices, such as API Recommended Practice 520/521 and the ASME Boiler and Pressu
re Vessel Code. The abatement plan shall establish dates during the next three m
onths when the evaluations, repairs, and replacements shall be completed. Once t
he plan has been fully implemented, the employer must submit certification of it
s full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not ensure PSV-1301,
a conventional relief valve, has a back pressure of less than or equal to 10% of
its set pressure. This relief device provides inadequate protection to the FCC
Feed Drum, and relieves hydrocarbons to the flare. Pursuant to 29 CFR 1903.19, w
ithin ten (10) calendar days of the abatement date, the employer must submit doc
umentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e),
the employer shall submit an abatement plan describing the actions it is taking
to ensure that it is in compliance with the standards including documentation th
at each pressure relief valve and associated piping for all process units have b
een evaluated and, if necessary, repaired or replaced to ensure backpressure is
limited in accordance with recognized and generally accepted good engineering pr
actices, such as API Recommended Practice 520/521 and the ASME Boiler and Pressu
re Vessel Code. The abatement plan shall establish dates during the next three m
onths
when the evaluations, repairs, and replacements shall be completed. Once the pla
n has been fully implemented, the employer must submit certification of its full
compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
the need for over pressure protection on pressure vessels as required by recogni
zed and generally accepted good engineering practices. The Upper Pumparound Cool
er (PR543576) is not protected by pressure relieving devices that would prevent
the pressure inside the vessel from rising above acceptable limits. Pursuant to
29 CFR 1903.19, within ten (10) calendar days of the abatement date, the employe
r must submit documentation that it has abated the hazard. In addition, under 29
CFR 1903.19(e), the employer must submit an abatement plan describing the actio
ns it is taking
to ensure that it is in compliance with the standards for all pressure vessels,
including documenting that each pressure vessel has been evaluated and is protec
ted by pressure-relieving device(s) in accordance with recognized and generally
accepted good engineering practices, such as the ASME Boiler and Pressure Vessel
Code. The abatement plan shall establish dates during the next three months whe
n the evaluations and installations of overpressure protection shall be complete
d. Once the plan has been fully implemented, the employer must submit certificat
ion of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not address the need for over pressure
protection on pressure vessels. The Upper Pumparound Cooler
(PR543576) is not protected by pressure relieving devices that would prevent the
pressure inside the vessel from rising above acceptable limits. Pursuant to 29
CFR 1903.19, within ten (10) calendar days of the abatement date, the employer m
ust submit documentation that it has abated the hazard. In addition, under 29 CF
R 1903.19(e), the employer must submit an abatement plan describing the actions
it is taking to ensure that it is in compliance with the standards for all press
ure vessels, including documenting that each pressure vessel has been evaluated
and is protected by pressure-relieving device(s) in accordance with recognized a
nd generally accepted good engineering practices, such as the ASME Boiler and Pr
essure Vessel Code. The abatement plan shall establish dates during the next thr
ee months when the evaluations and installations of overpressure protection shal
l be completed. Once the plan has been fully implemented, the employer must subm
it certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
the need for over pressure protection on pressure vessels as required by recogni
zed and generally accepted good engineering practices. The Lower Pumparound Cool
er (PR543757) is not protected by pressure relieving devices that would prevent
the pressure inside the vessel from rising above acceptable limits. Pursuant to
29 CFR 1903.19, within ten (10) calendar days of the abatement date, the employe
r must submit documentation that it has abated the hazard. In addition, under 29
CFR 1903.19(e), the employer must submit an abatement plan describing the actio
ns it is taking to ensure that it is in compliance with the standards for all pr
essure vessels, including documenting that each pressure vessel has been evaluat
ed and is protected by pressure-relieving device(s)
in accordance with recognized and generally accepted good engineering practices,
such as the ASME Boiler and Pressure Vessel Code. The abatement plan shall esta
blish dates during the next three months when the evaluations and installations
of overpressure protection shall be completed. Once the plan has been fully impl
emented, the employer must submit certification of its full compliance with the
standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not address the need for over pressure
protection on pressure vessels. The Lower Pumparound Cooler (PR543757) is not pr
otected by pressure relieving devices that would prevent the pressure inside the
vessel from rising above acceptable limits.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the abatement date,
the employer must submit documentation that it has abated the hazard. In additi
on, under 29 CFR 1903.19(e), the employer must submit an abatement plan describi
ng the actions it is taking to ensure that it is in compliance with the standard
s for all pressure vessels, including documenting that each pressure vessel has
been evaluated and is protected by pressure-relieving device(s) in accordance wi
th recognized and generally accepted good engineering practices, such as the ASM
E Boiler and Pressure Vessel Code. The abatement plan shall establish dates duri
ng the next three months when the evaluations and installations of overpressure
protection shall be completed. Once the plan has been fully implemented, the emp
loyer must submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process
complies with recognized and generally accepted good engineering practices: a.BP
-Husky Refining, LLC - Oregon, Ohio: The employer does not document the need for
over pressure protection on pressure vessels as required by recognized and gene
rally accepted good engineering practices. The Primary Absorber Lean Oil Cooler
(PR543585) is not protected by pressure relieving devices that would prevent the
pressure inside the vessel from rising above acceptable limits. Pursuant to 29
CFR 1903.19, within ten (10) calendar days of the abatement date, the employer m
ust submit documentation that it has abated the hazard. In addition, under 29 CF
R 1903.19(e), the employer must submit an abatement plan describing the actions
it is taking to ensure that it is in compliance with the standards for all press
ure vessels, including documenting that each pressure vessel has been evaluated
and is protected by pressure-relieving device(s) in accordance with recognized a
nd generally accepted good engineering practices, such as the ASME Boiler
and Pressure Vessel Code. The abatement plan shall establish dates during the ne
xt three months when the evaluations and installations of overpressure protectio
n shall be completed. Once the plan has been fully implemented, the employer mus
t submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not address the need for over pressure
protection on pressure vessels. The Primary Absorber Lean Oil Cooler (PR543585)
is not protected by pressure relieving devices that would prevent the pressure i
nside the vessel from rising above acceptable limits. Pursuant to 29 CFR 1903.19
, within ten (10) calendar days of the abatement date, the employer
must submit documentation that it has abated the hazard. In addition, under 29 C
FR 1903.19(e), the employer must submit an abatement plan describing the actions
it is taking to ensure that it is in compliance with the standards for all pres
sure vessels, including documenting that each pressure vessel has been evaluated
and is protected by pressure-relieving device(s) in accordance with recognized
and generally accepted good engineering practices, such as the ASME Boiler and P
ressure Vessel Code. The abatement plan shall establish dates during the next th
ree months when the evaluations and installations of overpressure protection sha
ll be completed. Once the plan has been fully implemented, the employer must sub
mit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
the
need for over pressure protection on pressure vessels as required by recognized
and generally accepted good engineering practices. The Primary Absorber Lean Oil
Cooler (PR543586) is not protected by pressure relieving devices that would pre
vent the pressure inside the vessel from rising above acceptable limits. Pursuan
t to 29 CFR 1903.19, within ten (10) calendar days of the abatement date, the em
ployer must submit documentation that it has abated the hazard. In addition, und
er 29 CFR 1903.19(e), the employer must submit an abatement plan describing the
actions it is taking to ensure that it is in compliance with the standards for a
ll pressure vessels, including documenting that each pressure vessel has been ev
aluated and is protected by pressure-relieving device(s) in accordance with reco
gnized and generally accepted good engineering practices, such as the ASME Boile
r and Pressure Vessel Code. The abatement plan shall establish dates during the
next three months when the evaluations and installations of overpressure protect
ion shall be completed.
Once the plan has been fully implemented, the employer must submit certification
of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not address the need for over pressure
protection on pressure vessels. The Primary Absorber Lean Oil Cooler (PR543586)
is not protected by pressure relieving devices that would prevent the pressure i
nside the vessel from rising above acceptable limits. Pursuant to 29 CFR 1903.19
, within ten (10) calendar days of the abatement date, the employer must submit
documentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e
),
the employer must submit an abatement plan describing the actions it is taking t
o ensure that it is in compliance with the standards for all pressure vessels, i
ncluding documenting that each pressure vessel has been evaluated and is protect
ed by pressure-relieving device(s) in accordance with recognized and generally a
ccepted good engineering practices, such as the ASME Boiler and Pressure Vessel
Code. The abatement plan shall establish dates during the next three months when
the evaluations and installations of overpressure protection shall be completed
. Once the plan has been fully implemented, the employer must submit certificati
on of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
the need for over pressure protection on pressure vessels as required by recogni
zed and
generally accepted good engineering practices. The Stripper Reboiler Condensate
Pot (PR511134) is not protected by pressure relieving devices that would prevent
the pressure inside the vessel from rising above acceptable limits. Pursuant to
29 CFR 1903.19, within ten (10) calendar days of the abatement date, the employ
er must submit documentation that it has abated the hazard. In addition, under 2
9 CFR 1903.19(e), the employer must submit an abatement plan describing the acti
ons it is taking to ensure that it is in compliance with the standards for all p
ressure vessels, including documenting that each pressure vessel has been evalua
ted and is protected by pressure-relieving device(s) in accordance with recogniz
ed and generally accepted good engineering practices, such as the ASME Boiler an
d Pressure Vessel Code. The abatement plan shall establish dates during the next
three months when the evaluations and installations of overpressure protection
shall be completed. Once the
plan has been fully implemented, the employer must submit certification of its f
ull compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not address the need for over pressure
protection on pressure vessels. The Stripper Reboiler Condensate Pot (PR511134)
is not protected by pressure relieving devices that would prevent the pressure i
nside the vessel from rising above acceptable limits. Pursuant to 29 CFR 1903.19
, within ten (10) calendar days of the abatement date, the employer must submit
documentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e
), the employer must submit an abatement plan describing the actions it is takin
g
to ensure that it is in compliance with the standards for all pressure vessels,
including documenting that each pressure vessel has been evaluated and is protec
ted by pressure-relieving device(s) in accordance with recognized and generally
accepted good engineering practices, such as the ASME Boiler and Pressure Vessel
Code. The abatement plan shall establish dates during the next three months whe
n the evaluations and installations of overpressure protection shall be complete
d. Once the plan has been fully implemented, the employer must submit certificat
ion of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
the need for over pressure protection on pressure vessels as required by recogni
zed and generally
accepted good engineering practices. The Stripper Steam Reboiler (PR543538) is n
ot protected by pressure relieving devices that would prevent the pressure insid
e the vessel from rising above acceptable limits. Pursuant to 29 CFR 1903.19, wi
thin ten (10) calendar days of the abatement date, the employer must submit docu
mentation that it has abated the hazard. In addition, under 29 CFR 1903.19(e), t
he employer must submit an abatement plan describing the actions it is taking to
ensure that it is in compliance with the standards for all pressure vessels, in
cluding documenting that each pressure vessel has been evaluated and is protecte
d by pressure-relieving device(s) in accordance with recognized and generally ac
cepted good engineering practices, such as the ASME Boiler and Pressure Vessel C
ode. The abatement plan shall establish dates during the next three months when
the evaluations and installations of overpressure protection shall be completed.
Once the plan has been fully implemented, the employer must submit certificatio
n of its
full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not address the need for over pressure
protection on pressure vessels. The Stripper Steam Reboiler (PR543538) is not pr
otected by pressure relieving devices that would prevent the pressure inside the
vessel from rising above acceptable limits. Pursuant to 29 CFR 1903.19, within
ten (10) calendar days of the abatement date, the employer must submit documenta
tion that it has abated the hazard. In addition, under 29 CFR 1903.19(e), the em
ployer must submit an abatement plan describing the actions it is taking to ensu
re that it is in compliance with the standards for all pressure vessels, includi
ng documenting
that each pressure vessel has been evaluated and is protected by pressure-reliev
ing device(s) in accordance with recognized and generally accepted good engineer
ing practices, such as the ASME Boiler and Pressure Vessel Code. The abatement p
lan shall establish dates during the next three months when the evaluations and
installations of overpressure protection shall be completed. Once the plan has b
een fully implemented, the employer must submit certification of its full compli
ance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
the need for over pressure protection on pressure vessels as required by recogni
zed and generally accepted good engineering practices. The Stripper CHGO Reboile
r (PR543539) is not
protected by pressure relieving devices that would prevent the pressure inside t
he vessel from rising above acceptable limits. Pursuant to 29 CFR 1903.19, withi
n ten (10) calendar days of the abatement date, the employer must submit documen
tation that it has abated the hazard. In addition, under 29 CFR 1903.19(e), the
employer must submit an abatement plan describing the actions it is taking to en
sure that it is in compliance with the standards for all pressure vessels, inclu
ding documenting that each pressure vessel has been evaluated and is protected b
y pressure-relieving device(s) in accordance with recognized and generally accep
ted good engineering practices, such as the ASME Boiler and Pressure Vessel Code
. The abatement plan shall establish dates during the next three months when the
evaluations and installations of overpressure protection shall be completed. On
ce the plan has been fully implemented, the employer must submit certification o
f its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before further use or in a safe and timely manner: a.BP-Husky Refinin
g, LLC - Oregon, Ohio: The employer does not address the need for over pressure
protection on pressure vessels. The Stripper CHGO Reboiler (PR543539) is not pro
tected by pressure relieving devices that would prevent the pressure inside the
vessel from rising above acceptable limits. Pursuant to 29 CFR 1903.19, within t
en (10) calendar days of the abatement date, the employer must submit documentat
ion that it has abated the hazard. In addition, under 29 CFR 1903.19(e), the emp
loyer must submit an abatement plan describing the actions it is taking to ensur
e that it is in compliance with the standards for all pressure vessels, includin
g documenting that each pressure vessel has been evaluated and is protected by p
ressure-relieving device(s)
in accordance with recognized and generally accepted good engineering practices,
such as the ASME Boiler and Pressure Vessel Code. The abatement plan shall esta
blish dates during the next three months when the evaluations and installations
of overpressure protection shall be completed. Once the plan has been fully impl
emented, the employer must submit certification of its full compliance with the
standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
the need for over pressure protection on pressure vessels as required by recogni
zed and generally accepted good engineering practices. The Steam Slurry Generato
r (PR543565) is not protected by pressure relieving devices that would prevent t
he pressure inside the vessel
from rising above acceptable limits. Pursuant to 29 CFR 1903.19, within ten (10)
calendar days of the abatement date, the employer must submit documentation tha
t it has abated the hazard. In addition, under 29 CFR 1903.19(e), the employer m
ust submit an abatement plan describing the actions it is taking to ensure that
it is in compliance with the standards for all pressure vessels, including docum
enting that each pressure vessel has been evaluated and is protected by pressure
-relieving device(s) in accordance with recognized and generally accepted good e
ngineering practices, such as the ASME Boiler and Pressure Vessel Code. The abat
ement plan shall establish dates during the next three months when the evaluatio
ns and installations of overpressure protection shall be completed. Once the pla
n has been fully implemented, the employer must submit certification of its full
compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are
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.BP-Husky Refining, LLC -
Oregon, Ohio: The employer does not address the need for over pressure protecti
on on pressure vessels. The Steam Slurry Generator (PR543565) is not protected b
y pressure relieving devices that would prevent the pressure inside the vessel f
rom rising above acceptable limits. Pursuant to 29 CFR 1903.19, within ten (10)
calendar days of the abatement date, the employer must submit documentation that
it has abated the hazard. In addition, under 29 CFR 1903.19(e), the employer mu
st submit an abatement plan describing the actions it is taking to ensure that i
t is in compliance with the standards for all pressure vessels, including docume
nting that each pressure vessel has been evaluated and is protected by pressure-
relieving device(s) in accordance with recognized and generally accepted good en
gineering practices, such as the
ASME Boiler and Pressure Vessel Code. The abatement plan shall establish dates d
uring the next three months when the evaluations and installations of overpressu
re protection shall be completed. Once the plan has been fully implemented, the
employer must submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
the need for over pressure protection on pressure vessels as required by recogni
zed and generally accepted good engineering practices. The Cat Heavy Gas Oil Coo
ler (PR543567) is not protected by pressure relieving devices that would prevent
the pressure inside the vessel from rising above acceptable limits.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the abatement date,
the employer must submit documentation that it has abated the hazard. In additi
on, under 29 CFR 1903.19(e), the employer must submit an abatement plan describi
ng the actions it is taking to ensure that it is in compliance with the standard
s for all pressure vessels, including documenting that each pressure vessel has
been evaluated and is protected by pressure-relieving device(s) in accordance wi
th recognized and generally accepted good engineering practices, such as the ASM
E Boiler and Pressure Vessel Code. The abatement plan shall establish dates duri
ng the next three months when the evaluations and installations of overpressure
protection shall be completed. Once the plan has been fully implemented, the emp
loyer must submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer does not correct deficiencies in equipment t
hat are outside acceptable limits (as defined by process information in 29 CFR 1
910.119(d) before
further use or in a safe and timely manner: a.BP-Husky Refining, LLC - Oregon, O
hio: The employer does not address the need for over pressure protection on pres
sure vessels. The Cat Heavy Gas Oil Cooler (PR543567) is not protected by pressu
re relieving devices that would prevent the pressure inside the vessel from risi
ng above acceptable limits. Pursuant to 29 CFR 1903.19, within ten (10) calendar
days of the abatement date, the employer must submit documentation that it has
abated the hazard. In addition, under 29 CFR 1903.19(e), the employer must submi
t an abatement plan describing the actions it is taking to ensure that it is in
compliance with the standards for all pressure vessels, including documenting th
at each pressure vessel has been evaluated and is protected by pressure-relievin
g device(s) in accordance with recognized and generally accepted good engineerin
g practices, such as the ASME Boiler and Pressure Vessel Code. The abatement pla
n shall establish dates during the
next three months when the evaluations and installations of overpressure protect
ion shall be completed. Once the plan has been fully implemented, the employer m
ust submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer does not document that the equipment in
the process complies with recognized and generally accepted good engineering pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
compliance with recognized and generally accepted good engineering practices by
ensuring combustion safeguards are provided on the Crude Heater A+B firebox. Pur
suant to 29 CFR 1903.19, within ten (10) calendar days of the abatement date, th
e employer must submit documentation that it has abated the hazard. In addition,
under 29 CFR 1903.19(e), the employer must submit an abatement plan describing
the actions it is taking to ensure that it
is in compliance with the standards for all fired heaters, including documenting
that fired heater has been evaluated and is protected by combustion safeguards
in accordance with recognized and generally accepted good engineering practices,
such as the API 556. The abatement plan shall establish dates during the next t
hree months when the evaluations and installations of combustion safeguards shal
l be completed. Once the plan has been fully implemented, the employer must subm
it certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

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 pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
compliance with follow recognized and generally accepted good engineering practi
ces by ensuring combustion safeguards are provided on the Vac Tower Furnace C fi
rebox.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the abatement date,
the employer must submit documentation that it has abated the hazard. In additi
on, under 29 CFR 1903.19(e), the employer must submit an abatement plan describi
ng the actions it is taking to ensure that it is in compliance with the standard
s for all fired heaters, including documenting that fired heater has been evalua
ted and is protected by combustion safeguards in accordance with recognized and
generally accepted good engineering practices, such as the API 556. The abatemen
t plan shall establish dates during the next three months when the evaluations a
nd installations of combustion safeguards shall be completed. Once the plan has
been fully implemented, the employer must submit certification of its full compl
iance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

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 pra
ctices: a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document
compliance
with recognized and generally accepted good engineering practices by ensuring co
mbustion safeguards are provided on the Naphtha Treater Furnace. Pursuant to 29
CFR 1903.19, within ten (10) calendar days of the abatement date, the employer m
ust submit documentation that it has abated the hazard. In addition, under 29 CF
R 1903.19(e), the employer must submit an abatement plan describing the actions
it is taking to ensure that it is in compliance with the standards for all fired
heaters, including documenting that fired heater has been evaluated and is prot
ected by combustion safeguards in accordance with recognized and generally accep
ted good engineering practices, such as the API 556. The abatement plan shall es
tablish dates during the next three months when the evaluations and installation
s of combustion safeguards shall be completed. Once the plan has been fully impl
emented, the employer must submit certification of its full compliance with the
standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer does not establish a system to assure that t
he process
hazard analysis team's recommendations are resolved in a timely manner and that
the resolution is documented: a.BP-Husky Refining, LLC - Oregon, Ohio: The emplo
yer does not document the actions to be taken, develop a schedule to implement t
he actions, and execute the actions necessary to control hazards associated with
building collapse and damage due to explosion overpressures to the WGI Insulato
rs Building (PR-532430), which could result in serious or fatal injuries to the
building occupants. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of
the abatement date, the employer must submit documentation that it has abated t
he hazard. In addition, under 29 CFR 1903.19(e), the employer, must submit an ab
atement plan describing the actions it is taking to ensure that it is in complia
nce with the standard. The abatement plan shall establish dates during the next
three months to determine when the recommendations and resolution of overpressur
e
hazards to occupied buildings will be abated. Once the plan has been fully imple
mented, the employer must submit certification of its full compliance with the s
tandard.e

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer does not establish a system to assure that t
he process hazard analysis team's recommendations are resolved in a timely manne
r and that the resolution is documented: a.BP-Husky Refining, LLC - Oregon, Ohio
: The employer does not document the actions to be taken, develop a schedule to
implement the actions, and execute the actions necessary to control hazards asso
ciated with building collapse and damage due to explosion overpressures to the B
lender control room (PR-532354), which could result in serious or fatal injuries
to the building occupants. Pursuant to 29 CFR 1903.19, within ten (10) calendar
days of the abatement date, the employer must submit documentation that it has
abated the hazard. In addition, under 29 CFR 1903.19(e),
the employer, must submit an abatement plan describing the action it is taking t
o ensure that it is in complinace with the standard. The abatement plan shall es
tablish dates during the next three months to determine when the recommendations
and resolution of overpressure hazards to occupied buildings will be abated. On
ce the plan has been fully implemented, the employer must submit certification o
f its full compliance with the standard.e

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer does not establish a system to assure that t
he process hazard analysis team's recommendations are resolved in a timely manne
r and that the resolution is documented: a.BP-Husky Refining, LLC - Oregon, Ohio
: The employer does not document the actions to be taken, develop a schedule to
implement the actions, and execute the actions necessary to control hazards asso
ciated with building collapse and damage due to explosion overpressures to the B
oiler Shop (PR-532473), which could result in serious or fatal injuries to the b
uilding occupants.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the abatement date,
the employer must submit documentation that it has abated the hazard. In additi
on, under 29 1903.19(e), the employer, must submit an abatement plan describing
the actions it is taking to ensure that it is in compliance with the standard. T
he abatement plan shall establish dates during the next three months to determin
e when the recommendations and resolution of overpressure hazards to occupied bu
ildings will be abated. Once the plan has been fully implemented, the employer m
ust submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer does not establish a system to assure that t
he process hazard analysis team's recommendations are resolved in a timely manne
r and that the resolution is documented: a.BP-Husky Refining, LLC - Oregon, Ohio
: The employer does not document the
actions to be taken, develop a schedule to implement the actions, and execute th
e actions necessary to control hazards associated with building collapse and dam
age due to explosion overpressures to the E&I Shop (PR-532419), which could resu
lt in serious or fatal injuries to the building occupants. Pursuant to 29 CFR 19
03.19, within ten (10) calendar days of the abatement date, the employer must su
bmit documentation that it has abated the hazard. In addition, under 29 CFR 1903
.19(e), the employer, must submit an abatement plan describing the actions it is
taking to ensure that it is in compliance with the standard. The abatement plan
shall establish dates during the next three months to determine when the recomm
endations and resolution of overpressure hazards to occupied buildings will be a
bated. Once the plan has been fully implemented, the employer must submit certif
ication of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

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 mann
er and that the resolution is documented: a.BP-Husky Refining, LLC - Oregon, Ohi
o: The employer does not document the actions to be taken, develop a schedule to
implement the actions, and execute the actions necessary to control hazards ass
ociated with building collapse and damage due to explosion overpressures to the
HSEQ Building (PR-532380), which could result in serious or fatal injuries to th
e building occupants. Pursuant to 29 CFR 1903.19, within ten (10) calendar days
of the abatement date, the employer must submit documentation that it has abated
the hazard. In addition, under 29 CFR 1903.19(e), the employer, must submit an
abatement plan describing the actions it is taking to ensure that it is in compl
iance with the standard. The abatement plan shall establish dates during the nex
t
three months to determine when the recommendations and resolution of overpressur
e hazards to occupied buildings will be abated. Once the plan has been fully imp
lemented, the employer must submit certification of its full compliance with the
standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer does not establish a system to assure that t
he process hazard analysis team's recommendations are resolved in a timely manne
r and that the resolution is documented: a.BP-Husky Refining, LLC - Oregon, Ohio
: The employer does not document the actions to be taken, develop a schedule to
implement the actions, and execute the actions necessary to control hazards asso
ciated with building collapse and damage due to explosion overpressures to the L
aboratory (PR-532490), which could result in serious or fatal injuries to the bu
ilding occupants. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of t
he abatement date, the employer
must submit documentation that it has abated the hazard. In addition, under 29 C
FR 1903.19(e), the employer, must submit an abatement plan describing the action
s it is taking to ensure that it is in compliance with the standard. The abateme
nt plan shall establish dates during the next three months to determine when the
recommendations and resolution of overpressure hazards to occupied buildings wi
ll be abated. Once the plan has been fully implemented, the employer must submit
certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer does not establish a system to assure that t
he process hazard analysis team's recommendations are resolved in a timely manne
r and that the resolution is documented: a.BP-Husky Refining, LLC - Oregon, Ohio
: The employer does not document the actions to be taken, develop a schedule to
implement the actions, and execute the actions necessary to control hazards asso
ciated with building collapse and damage due to
explosion overpressures to the Main Office Building (PR-532399/532400), which co
uld result in serious or fatal injuries to the building occupants. Pursuant to 2
9 CFR 1903.19, within ten (10) calendar days of the abatement date, the employer
must submit documentation that it has abated the hazard. In addition, under 29
CFR 1903.19(e), the employer, must submit an abatement plan describing the actio
ns it is taking to ensure that it is in compliance with the standard. The abatem
ent plan shall establish dates during the next three months to determine when th
e recommendations and resolution of overpressure hazards to occupied buildings w
ill be abated. Once the plan has been fully implemented, the employer must submi
t certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer does not establish a system to assure that t
he process hazard analysis team's recommendations are resolved in a timely manne
r and that the resolution is documented:
a.BP-Husky Refining, LLC - Oregon, Ohio: The employer does not document the acti
ons to be taken, develop a schedule to implement the actions, and execute the ac
tions necessary to control hazards associated with building collapse and damage
due to explosion overpressures to the WGI Administrative Offices (PR-532480), wh
ich could result in serious or fatal injuries to the building occupants. Pursuan
t to 29 CFR 1903.19, within ten (10) calendar days of the abatement date, the em
ployer must submit documentation that it has abated the hazard. In addition, und
er 29 CFR 1903.19(e), the employer, must submit an abatement plan describing the
actions it is taking to ensure that it is in compliance with the standard. The
abatement plan shall establish dates during the next three months to determine w
hen the recommendations and resolution of overpressure hazards to occupied build
ings will be abated. Once the plan has been fully implemented, the employer must
submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer does not establish a system to assure that t
he process hazard analysis team's recommendations are resolved in a timely manne
r and that the resolution is documented: a.BP-Husky Refining, LLC - Oregon, Ohio
: The employer does not document the actions to be taken, develop a schedule to
implement the actions, and execute the actions necessary to control hazards asso
ciated with building collapse and damage due to explosion overpressures to the W
GI Electricians Building (PR-532416), which could result in serious or fatal inj
uries to the building occupants. Pursuant to 29 CFR 1903.19, within ten (10) cal
endar days of the abatement date, the employer must submit documentation that it
has abated the hazard. In addition, under 29 CFR 1903.19(e), the employer, must
submit an abatement plan describing the actions it is taking to ensure that it
is in compliance with the standard. The abatement plan shall establish dates
during the next three months to determine when the recommendations and resolutio
n of overpressure hazards to occupied buildings will be abated. Once the plan ha
s been fully implemented, the employer must submit certification of its full com
pliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(ii): Inspections and testing procedures performed on proce
ss equipment to maintain its mechanical integrity, do not follow recognized and
generally accepted good engineering practices: a. BP-Husky Refining, LLC - Orego
n, Ohio: In the FCC and Alky units, the employer does not follow RAGAGEP (recogn
ized and generally accepted good engineering practices) when they do not conduct
thorough pressure vessel inspections by failing to take thickness readings at a
specific designated test point within a TML (thickness measurement location). b
. BP-Husky Refining, LLC - Oregon, Ohio: In the FCC and Alky units, the employer
does
not follow RAGAGEP (recognized and generally accepted good engineering practices
) when they do not conduct thorough piping inspections by failing to take thickn
ess readings at a specific designated test point within a TML (thickness measure
ment location)/CML (condition monitoring location). c. BP-Husky Refining, LLC -
Oregon, Ohio: The employer does not conduct additional piping inspections on the
Alky flare header/subheader when historical inspections indicate flare header t
hinning and leaks. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of
the abatement date, the employer must submit documentation that it has abated th
e hazard. In addition, under 29 CFR 1903.19(e), the employer must submit an abat
ement plan describing the actions it is taking to ensure that it is in complianc
e with the standards for pressure vessels and associated piping in accordance wi
th recognized and generally accepted good engineering practices, such as API 570
and 572. The abatement plan shall establish dates during the next three months i
ndicating when specific designated test points within a TML will be determined a
nd when additional piping inspections associated with known thinning and leaks s
hall be completed. Once the plan has been fully implemented, the employer must s
ubmit certification of its full compliance with the standard.e

Issued

Mar 8, 2010

Abate by

Apr 19, 2010

Penalty

Initial $70,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process eq
uipment to maintain its mechanical integrity, is not consistent with applicable
manufacturers' recommendations and good engineering practices, or more frequentl
y determined to be necessary by prior operating experience: a. BP-Husky Refining
, LLC - Oregon, Ohio: Thickness measurements at TML 0260, 0310, 0350, 0360, 0410
, 0470, 0475, 0620, 0700, and 0740 on piping circuit 00840 in the Alky 1 unit ar
e not taken at intervals that do not exceed the lesser of one half the remaining
life determined from the corrosion rate or the specified maximum interval of 5
years for a Class
1 circuit. b. BP-Husky Refining, LLC - Oregon, Ohio: Thickness measurements at T
ML 0140, 0150, 0160, 0270, 0350, 0470, 0490, 0500, 0560, and 0580 on piping circ
uit 00160 in the FCC unit are not taken at intervals that do not exceed the less
er of one half the remaining life determined from the corrosion rate or the spec
ified maximum interval of 10 years for a Class 2 circuit. c. BP-Husky Refining,
LLC - Oregon, Ohio: Tthickness measurements at TML 0010, 0090, 0120, 0300, and 0
320 on piping circuit 01040 in the Cat Poly unit are not taken at intervals that
do not exceed the lesser of one half the remaining life determined from the cor
rosion rate or the specified maximum interval of 5 years for a Class 1 circuit.
d. BP-Husky Refining, LLC - Oregon, Ohio: Thickness measurements at TML 0010SD,
0020SD, and 0030SD on piping circuit 00430 in the Reformer 1 unit are not taken
at intervals that do not exceed the lesser of one half the remaining life determ
ined from the corrosion rate or the specified maximum interval of 5 years for a
Class 1 circuit. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of th
e abatement date, the empoyer must submit documentation that it has abated the h
azard. In addition, under 29 CFR 1903.19(e), the employer must submit an abatmen
t plan describing the actions it is taking to ensure that it is in compliance wi
th the standards for process equipment testing frequencies
in accordance with recognized and generally accepted good engineering practices,
such as API 570. The abatement plan shall establish dates during the next three
months that indicate when the intervals for thickness measurements will be impl
emented in accordance with RAGAGEP. Once the plan has been fully implemented, th
e employer must submit certification of its full compliance with the standard.

Issued

Mar 8, 2010

Abate by

Apr 5, 2010

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(c)(1): The employer did not develop a written plan of action reg
arding the implementation of the employee participation required by 29 CFR 1910.
119: a.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, th
e plan for employee participation stated that employees update and check process
P&IDs but the employer did not document how this would be accomplished. b.BP-Hu
sky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the plan for e
mployee participation stated that employees participate in conducting the contra
ctor
orientation training but the employer could not document how this would be accom
plished. c.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009
, the plan for employee participation stated that employees participate in the w
riting of maintenance procedures but the employer could not document how this wo
uld be accomplished. d.BP-Husky Refining, LLC - Oregon, Ohio: On or about Septem
ber 10, 2009, the plan for employee participation stated that employees particip
ate in the PSM audits and that employees conduct the permit audits but the emplo
yer could not document what involvement employees would have on the team. e.BP-H
usky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the plan for
employee participation made no mention of how employees will be consulted on the
need for refresher training.
f.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the pla
n for employee participation made no mention of how suggestions will be solicite
d from employees for safety improvements in mechanical 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, docume
ntation demonstrating that abatement is complete must be included with your cert
ification. This documentation may include, but is not limited to, evidence of th
e purchase or repair of the equipment, photographic or video evidence of abateme
nt, or other written records.t,