OSHA Inspection: VALERO ENERGY CORPORATION

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Penalty

Initial $2,500 · Current $6,000

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B):  Process safety information pertaining to the
equipment in the
process did not include the piping and instrument diagrams (P&ID'S):
a)  Unit 23 FCCU - P&ID Number 2004 - 0123 - KD - R051 did not show the
steam
line connected to the atmospheric discharge vent line coming from
23-PSV-969, 23-PSV-
969A, and 23-PSV-970.  This condition was noted on or about January 15,
2009.
b)  Unit 23 FCCU - P&ID Numbers 2004 - 0123 - KD - R052 and 2004 - 0123 -
KD -
R054 did not include the block valve located on line 23-4"-80-38-8A
downstream from
23-PSV-908.  This condition was noted on or about January 15, 2009.
c)  Unit 23 FCCU - P&ID Number 2004 - 0123 - KD - R079 did not contain a
'CSO'
designation on the block valve located downstream from 23-PSV-901.  This
condition
was noted on or about January 15, 2009.
d)  Unit 23 FCCU - P&ID Number 2004 - 0123 - KD - R046 did not contain a
'CSO'
designation of the block valve located upstream from 23-PSV-941.  This
condition was
noted on or about January 15, 2009.
e)  Unit 23 FCCU - P&ID Number 2004 - 0123 - KD - R049 had a rupture disk
on the
water side of 23-E-13B that did not include the device number, the set
pressure, and a
'CSO' designation on its upstream block valve.  This condition was noted
on or about
January 15, 2009.
ABATEMENT DOCUMENTATION REQUIRED

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Penalty

Initial $5,000 · Current $6,000

General-duty citation text

29 CFR 1910.119(e)(5):  The employer did not establish a system to
promptly address the process hazard
analysis team's findings and recommendations:
a)  Unit 23 FCC - The company did not establish a system to address the
finding in the 2007 PHA that
potential aerosol formation, liquid droplets, and vapor clouds could form
as a result of atmospheric
releases from 23-PSV-969, 23-PSV-969A, and 23-PSV-970.  This condition was
noted on or about
January 15, 2009.
ABATEMENT DOCUMENTATION REQUIRED

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Penalty

Initial $2,500 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D):  The employer's written operating procedures
covering the steps for each
operating phase did not address emergency shutdown including the
conditions under which emergency
shutdown is required, and the assignment of shutdown responsibility to
qualified operators to ensure that
emergency shutdown was done in a safe and timely manner:
a)  Unit 23 FCC -  The employer did not ensure that the emergency shutdown
procedures were
adequate in that Emergency Shutdown Procedure (ESP) 051 did not specify an
initiating condition, or
conditions, under which this procedure would be required.  This condition
was noted on or about
January 26, 2009.
ABATEMENT DOCUMENTATION REQUIRED

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Penalty

Initial $5,000 · Current $1,000 Reduced

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Penalty

Initial $2,500 · Current $6,000

General-duty citation text

29 CFR 1910.119(f)(4):  The employer did not develop and implement safe
work practices for employees and
contractor employees to provide for the control of hazards during
operations such as lockout/tagout; confined
space entry; opening process equipment or piping; and control over
entrance into a facility by maintenance,
contractor, laboratory, or other support personnel:
a)  Unit 23 FCC - Spectacle blinds (4XX5382) installed on the inlet and
outlet for exchanger 23-E-
1A/B were not tagged and were not placed on the Blind List, as required by
the company's Standing
Instruction 2.9.1, "Installation and Removal of Blinds."  This condition
was noted on or about
February 10, 2009.
ABATEMENT DOCUMENTATION REQUIRED

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Penalty

Initial $2,500 · Current $6,000

General-duty citation text

29 CFR 1910.119(l)(1):  The employer did not establish and implement
written procedures to manage changes
to process chemicals, technology, equipment, and procedures; and, changes
to facilities that affect a covered
process:
a)  Unit 23 FCC - The company did not implement a Management of Change
(MOC) before disabling
alarms that were listed in the process unit's Master Variable Table (MVT)
as critical alarms.  Alarms
that were disabled include, but are not limited to, 23-FI-1227,
23-FI-1228, 23-FI-1229, 23-FI-1230,
and 23-FI-1231.  This condition was noted on or about February 26, 2008.
ABATEMENT DOCUMENTATION REQUIRED
Valero Energy Corporation was previously cited for a violation of this
occupational safety and health standard,
which was contained in OSHA Inspection Number 310264221, Citation Number
1, Item Number 2, issued on
December 13, 2007.ber

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Penalty

Initial $5,000 · Current $6,000

General-duty citation text

29 CFR 1910.119(l)(4):  A change covered by 29 CFR 1910.119(l) resulted in
a change in the process safety
information required by 29 CFR 1910.119(d) and the process information was
not updated:
a)  Unit 23 FCC - The company did not update the relief design information
for 23-PSV-900 when
this relief valve was reset from 150 psig to 175 psig in conjunction with
the re-rating of heat
exchanger 23-E-2A, as described in MOC M2007210-001. This condition was
noted on or about
March 10, 2009.
ABATEMENT DOCUMENTATION REQUIRED

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Penalty

Initial $5,000 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(m)(3):  The incident investigation team did not consist of
at least one person knowledgeable
in the process involved, including a contract employee if the incident
involved work of the contractor, and
other persons with appropriate knowledge and experience to thoroughly
investigate and analyze the incident:
a)  Unit 23 FCC: The employer did not develop an incident investigation
team that included a
contractor employee when the incident involved the work of the contractor.
An incident occurred
where a contractor incorrectly installed the protective refractory lining
inside the Riser during the 2004
unit turnaround. This resulted in hot spots on the Riser that could have
resulted in metal failure and a
release of hydrocarbons into the air.  This condition was noted on or
about February 20, 2009.
ABATEMENT DOCUMENTATION REQUIRED

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

General-duty citation text

29 CFR 1910.119(m)(4)(iv):  The report prepared at the conclusion of the
investigation of an incident which
resulted in, or could have reasonably resulted in a catastrophic release
of highly hazardous chemical in the
workplace, did not include the factors that contributed to the incident:
a)  Unit 23 FCC: The employer did not develop an investigation report that
identified the root cause(s)
of an incident where a contractor incorrectly installed the protective
refractory lining inside the Riser
during the 2004 unit turnaround. This resulted in hot spots on the Riser
that could have resulted in
metal failure and a release of hydrocarbons into the air.  This condition
was noted on or about
February 20, 2009.
ABATEMENT DOCUMENTATION REQUIRED

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Penalty

Initial $25,000 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D):  Process safety information pertaining to the
equipment in the process did not
include the relief system design and design basis:
a)  Unit 23 FCCU - The company's Process Safety Information relating to
23-PSV-969, 23-PSV-
969A, and 23-PSV-970 did not include design information relating to the
safe discharge of flammable
hydrocarbon from these relief valves through a common manifold.  This
condition was noted on or
about January 15, 2009.
ABATEMENT DOCUMENTATION REQUIRED
The company was previously cited for a violation of this occupational
safety & health standard, which was
contained in OSHA Inspection Number 310263504, Citation Number 1, Item
Number 2a, issued on April 15,
2008, at its Port Arthur, Texas refinery.

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Penalty

Initial $12,500 · Current $22,500

General-duty citation text

29 CFR 1910.119(e)(3)(iv):  The process hazard analysis did not address
the consequences of failure of
engineering and administrative controls:
a)  Unit 23 FCCU - The 2007 Process Hazard Analysis did not address the
possibility that block
valves located upstream or downstream of pressure relief valves could be
closed while the process was
operating.  This condition was noted on or about January 15, 2009.
ABATEMENT DOCUMENTATION REQUIRED
The company was previously cited for a violation of this occupational
safety and health standard, which was
contained in OSHA Inspection Number 310690086, Citation Number 1, Item
Number 1, issued on August 13,
2007, at its Sunray, Texas refinery.

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Penalty

Initial $25,000 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i):  Inspections and tests were not performed on
process equipment to maintain its
mechanical integrity:
(a)  Unit 23 FCC - The company did not inspect all instrumentation it
credited as a safeguard in its
Process Hazard Analysis of the unit in that the Low Level Alarm 23-LAL-748
on the 23-D-8 Surge
Drum did not have a history of any inspections done to assure it was
capable of functioning as
intended.  This condition was noted on or about February 26, 2009.
(b)  Unit 23 FCC - The company did not inspect all instrumentation it
credited as a safeguard in its
Process Hazard Analysis of the unit in that the temperature indicating
loop 23-TI-502 on the outlet of
23-E-4A Slurry Cooler Heat Exchanger did not have a history of any
inspections done to assure it was
capable of functioning as intended.  This condition was noted on or about
February 26, 2009.
(c)  Unit 23 FCC - The company did not inspect all instrumentation it
credited as a safeguard in its
Process Hazard Analysis of the unit in that the temperature indicating
loop 23-TI-505 on a bypass line
for 23-E-4A through C Slurry Cooler Heat Exchangers did not have a history
of any inspections done
to assure it was capable of functioning as intended.  This condition was
noted on or about February
26, 2009.
(d)  Unit 23 FCC - The company did not inspect all instrumentation it
credited as a safeguard in its
Process Hazard Analysis of the unit in that the temperature indicating
loop 23-TI-549A on Tray 2 of
the Fractionator did not have a history of any inspections done to assure
it was capable of functioning
as intended.  This condition was noted on or about February 26, 2009.
(e)  Unit 23 FCC - The company did not inspect all instrumentation it
credited as a safeguard in its
Process Hazard Analysis of the unit in that the temperature indicating
loop 23-TI-549B on Tray 2 of
the Fractionator did not have a history of any inspections done to assure
it was capable of functioning
as intended.  This condition was noted on or about February 26, 2009.
(f)  Unit 23 FCC - The company did not inspect all instrumentation it
credited as a safeguard in its
Process Hazard Analysis of the unit in that the High Pressure Alarm
24-PC-302B on the Wet Gas
Compressor Suction did not have a history of any inspections done to
assure it was capable of
functioning as intended.  This condition was noted on or about February
26, 2009.
(g)  Unit 23 FCC - The company did not inspect all instrumentation it
credited as a safeguard in its
Process Hazard Analysis of the unit in that the Pressure Indicator
23-PI-414 on the Reactor did not
have a history of any inspections done to assure it was capable of
functioning as intended.  This
condition was noted on or about February 26, 2009.
(h)  Unit 23 FCC - The company did not inspect all instrumentation it
credited as a safeguard in its
Process Hazard Analysis of the unit in that the Low Level Alarm 23-LAL-741
on the 23-D-5
Fractionator Overhead Receiver did not have a history of any inspections
done to assure it was capable
of functioning as intended.  This condition was noted on or about February
26, 2009.
(i)  Unit 23 FCC - The company did not inspect all instrumentation it
credited as a safeguard in its
Process Hazard Analysis of the unit in that the Low Level Alarm 23-LAL-735
on the Regenerator did
not have a history of any inspections done to assure it was capable of
functioning as intended.  This
condition was noted on or about February 26, 2009.
ABATEMENT DOCUMENTATION REQUIRED
The company was previously cited for a violation of this occupational
safety and health standard, which was
contained in OSHA Inspection Number 310265830, Citation Number 1, Item
Number 2, issued on April 15,
2008, at its Port Arthur, Texas refinery.

Issued

Jun 30, 2009

Abate by

Aug 2, 2009

Penalty

Initial $12,500 · Current $22,500

General-duty citation text

29 CFR 1910.119(j)(4)(iv):  The employer did not document each inspection
and test that had been performed
on process equipment to maintain its mechanical integrity:
(a)  Unit 23 FCC - The company did not develop inspection documentation
that included the date of
the inspection or test, the name of the person who performed the
inspection or test, and the results of
the inspection or test.  Inspection documentation was not developed for
high temperature alarm loops
such as, but not limited to, the high temperature alarms on the riser,
23-TI-4500A and B, which are
listed as safeguards in the Process Hazard Analysis for the unit.  This
condition was noted on or about
February 26, 2009.
ABATEMENT DOCUMENTATION REQUIRED
The company was previously cited for a violation of this occupational
safety and health standard, or its
equivalent standard 29 CFR 1910.119(j)(2),which was contained in OSHA
Inspection Number 310263504,
Citation Number 1, Item Number 13, issued on April 15, 2008, at its Port
Arthur, Texas refinery.

Issued

Jun 30, 2009

Abate by

Jul 6, 2009

General-duty citation text

29 CFR 1910.119(f)(3):  The employer did not certify annually that the
operating procedures
are current and accurate:
a)  Unit 23 FCC - The company did not ensure that the annual certification
for operating
procedures was current and accurate in that Emergency Operating procedure
022, "Loss
of 24-P-4A & B," Emergency Shutdown Procedure 055, "FCCU Emergency Shutdown
CO Boiler Outage," and Emergency Shutdown Procedure 056, "Gas Plant
Supplement:
Emergency Shutdown CO Boiler," were omitted from the 2008-2009 annual
certification
list.  This condition was noted on or about January 20, 2009.ry