OSHA Inspection: CONOCOPHILLIPS BAYWAY REFINERY

Issued

Mar 5, 2009

Abate by

Apr 20, 2009

Penalty

Initial $5,000 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1):  The employer did not develop and implement written
operating
procedures that provided clear instructions for safely conducting
activities in each covered
process consistent with the process safety information and which addressed
the elements
listed in 29 CFR 1910.119(f)(1)(i) through (f)(1)(iv):
a- ISOM2 - ISOM Operating and Emergency Procedure 03.04.01 Pump Flange
Fires
incorrectly identified the use of Emergency Block Valve (EBVs) numbers 13
and 14
in the case of a major fire.  These valves were listed on the Piping and
Instrument
Diagram (P&ID) 104-14LA-1 as Motor Operated Valves (MOVs) and not EBVs.
The
correct valves to be used in this procedure were Emergency Isolation
Valves (EIVs)
numbers 3 and 4.
Condition noted on or about 02/18/09.

Issued

Mar 5, 2009

Abate by

Apr 20, 2009

Penalty

Initial $5,000 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(5):  The employer did not correct deficiencies in
equipment that were
outside acceptable limits (as defined by process information in 29 CFR
1910.119(d)) before
further use or in a safe and timely manner:
a- ISOM2 - The following equipment deficiencies were noted:
1) The P-501A was allowed to operate with a motor that was grossly
overfilled
with oil and there were no means to drain/check the condition of the oil to
include accumulation of water,
2) The drain port on the P-501A seal flange was not plugged,
3) Oil mist connections to the motor on P-501A were installed improperly
with
compression type fittings used without thread sealant,
4) The P-501A motor used an inferior plastic oil cup/reservoir with a
"bullseye" design.
Condition noted on or about 2/17/09

Issued

Mar 5, 2009

Abate by

Apr 20, 2009

Penalty

Initial $5,000 · Current $5,000

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- ISOM2 - The employer failed to perform a management of change (MOC) for
the
following:
1) As part of the 1995 Butamer project the P-501A pump was de-staged and
was found to be operating below its minimum flow design,
2) The oil mist system was initially designed to service 32 users but
prior to
the incident it was supplying the same amount of oil to only 2 users
(P-501A
and P-501B),
3) The P-501A motor was overhauled in 2008 with the vendor installing a
differently designed oiler consisting of a plastic cup/reservoir and
"bullseye" to
monitor oil level.
Condition noted on or about 02/17/09n

Issued

Mar 5, 2009

Abate by

Apr 20, 2009

Penalty

Initial $5,000 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.119(l)(3):  Employees involved in operating a process and
maintenance and
contract employees whose job tasks will be affected by a change in the
process were not
informed of, and trained in, the change prior to start-up of the process
or affected part of the
process:
a- ISOM2 - The P-501A motor was overhauled in 2008 with the vendor
installing a
differently designed oiler consisting of a plastic cup/reservoir and
"bullseye" to
monitor oil level.  Operators were not trained on how to properly read and
maintain
oil levels on the newly installed oiler.  In addition, mechanics were not
instructed on
the operation and maintenance of the above noted oiler.
Condition noted on or about 02/18/09.

Issued

Mar 5, 2009

Abate by

Apr 20, 2009

Penalty

Initial $5,000

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 process
information was
not updated:
a- ISOM2 - The Seal Vent for P-501A/B, noted as Detail C on P&ID
104-14LA-24,
was incorrect and did not reflect the "as built" arrangement on the unit.
Condition
noted on or about 02/17/09.
b- ISOM2 - The Oil Mist Lubrication System found on P&ID 104-14LA-21 was
incorrect and did not reflect conditions on the unit.  The P&ID indicated
that the
system serviced pumps and exchangers to include some 32 users to include
P-502A/B,
P-504A/B, P-509B, P-510B, P-505A/B, P-507A/B, P-601A/B, E-503A-D, E-505A-C,
E-506A/B, E-509, E-513A/B and E-612A/B.  However, it was found that the
system
only serviced 2 users, P-501A/B.
Condition noted on or about 02/17/09.