OSHA Inspection: SUNOCO, INC. (R&M)

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $5000.00 · Current $7000.00

General-duty citation text

29 CFR 1910.119(d)(2)(i)(A): Process safety information pertaining to the
technology of the
process did not include accurate block flow diagram(s) or simplified
process flow diagram(s):
a) Sunoco (MH), 10-4 Plant - The current simplified process flow diagram
#26529A,for
the Fraid Stack did not show that SV-20C relieved to the stack as per P&ID
1-10-4,
26005A, sheet #14.  2/2/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

referenced
pressures.  The control building was not depopulated or structurally
modified to
withstand the anticipated pressure.  Condition noted on or about January
22, 2009.
g.7) Sunoco Inc. Marcus Hook Refinery, Mechanical Center - The employer
did not
document compliance with RAGAGEP.  The employer's stated RAGAGEP was API
Recommended Practice 752 - "Management of Hazards Associated with Location
29 CFR 1910.119(d)(3)(ii):  The employer did not document that the
of
Process Plant Buildings".  Mechanical Center was located in an area which
had
potential exposure to an over pressurization of approximately 1 pound per
square inch
(psi) during a vapor cloud explosion.  The building is a single story
brick building
with high bay areas to accommodate the internal bridge cranes. The first
portion of
the exterior walls is un-reinforced brick and the remaining portion of
equipment in the
approximately
20 feet in height is glass.  The Mechanical Center building was not
depopulated or
process complied with recognized and generally accepted good engineering
practices
(RAGAGEP):
structurally modified to withstand the anticipated pressure.  Condition
noted on or
about January 22, 2009.
g.8) Sunoco Inc. Marcus Hook Refinery, LSGU - The employer did not document
compliance with RAGAGEP.  The employer's stated RAGAGEP was API
Recommended Practice 752 - "Management of Hazards Associated with Location
of
Process Plant Buildings".  The Control Room/Operator Shelter LSG was
located in anarea which had potential exposure to a maximum over
pressurization greater than 1
pound per square inch (psi) during a vapor cloud explosion.  The building
is a single
story  self-framing interlocking steel panel structure for general purpose
exterior use.
API evaluates damage to such a structure between 1.5 and 2.5 psi.  The
building was
constructed in 2004 to 2005 and no engineering evaluation of its adequacy
for the area
in which it was placed was performed, and no special stipulations for
blast resistant
construction is reflected in the construction documents. Condition noted
on or about
January 22, 2009.
g.9) Sunoco Inc. Marcus Hook Refinery, 10-4 FCCU - The employer did not
document compliance with RAGAGEP.  The employer's stated RAGAGEP was API
Recommended Practice 752 - "Management of Hazards Associated with Location
of
Process Plant Buildings".  The Zone 24 shop (10-4 Maintenance Building) was
located in an area which had potential exposure to a maximum over
pressurization of
greater than 1 pounds per square inch (psi) during a vapor cloud
explosion.  The
Maintenance Building is an un-reinforced brick bearing wall structure.
API evaluates
damage to such a structure, as partial collapse of walls at 1 psi.  The
maintenance
building was not depopulated or structurally modified to withstand the
anticipated
pressure.  Condition noted on or about April 16, 2009.
h) Sunoco Inc. Marcus Hook Refinery -  The employer did not document
compliance
with RAGAGEP.  The employer's stated RAGAGEP was API Recommended Practice
752 - "Management of Hazards Associated with Location of Process Plant
Buildings".
Buildings such as but not limited to the Mechanical Center, Lube Service
Center, E &
I Shop, and Control Room H-5 were identified as occupied and having
potential
exposure to Ethylene Oxide (EO) or Hydrogen Sulfide (H2S) from units
containing
these materials.  The employer did not evaluate or identify that
mitigation systems or
emergency response was in place or appropriate. Condition noted on or
about January
22, 2009.
i) 10-4 Plant: Sunoco, Inc. (MH) did not ensure that relief valves were
sized,
selected, and installed in accordance with API-520: Sizing, Selection, and
Installation
of Pressure-relieving Devices in Refineries, and API-521:
Pressure-relieving and
Depressuring Systems.  These relief valves included but were not limited
to:
1) RV-102 associated with E-94A/B (shell sides)
2) RV-159 associated with E-9A (shell side)
3) RV-160 associated with E-9B (shell side)
4) RV-156 associated with E-10 (shell side)
5) RV-109 associated with E-12A/C (shell side)
6) RV-110 associated with E-12B/D (shell side)7) SV-0025 associated with
T-4
The above listed relief valves were still in place and part of the active
process as of
3/11/2009.
j) 10-4 Plant: Sunoco did not implement effective administrative controls
to ensure
that upstream and downstream intervening (block) valves, in line with
relief devices,
remained in the open position.  These relief devices had upstream and/or
downstream
block valves which did not meet the ASME Boiler & Pressure Vessel Code,
Section
VIII, Division 1 requirements in that those block valves did not have
mechanical
locking elements present. The affected relief devices included, but were
not limited
to:
1) SV-23A, SV-23B, SV-23C, SV-23D (V-12)
2) SV-23E, SV-23G, SV-23H, SV-23J (V-12)
3) RV-101, RV-102 (E-94)
4) SV-20C, RV 153 (E-15A)
5) SV-20B, RV-154 (E-15B)
6) SV-20A, RV-155 (E-15C)
7) SV-157 (E-8)
8) RV-131 (V-113)
The above listed block valves were observed not to have mechanical locking
elements
as of 2/12/2009.
k)  Sunoco, Inc. Marcus Hook Refinery - The employer did not document
compliance
with API Standard 521, Pressure-Relieving and Depressuring Systems, as
evident
by
the fact that the design of the 17-2 UDEX Fraid Stack was not designed to
prevent or
safely accommodate liquid overfill.  Condition noted on or about
4/21/2009.
Abatement Note
OSHA does not accept occupancy criteria evaluations (see API 752, Section
2.5.2) as
the basis for an employer's determination that adequate protection has
been provided
for employees in occupied structures which employer's have identified as
being
potentially subject to explosions, fire, ingress of toxic materials or
high energy
releases.
NOTE: DOCUMENTATION OF ABATEMENT OF THESE CONDITIONS IS
REQUIRED
a) Sunoco, Inc. Marcus Hook Refinery , 10-4 FCCU - The employer did not
document compliance with API Recommended Practice 612 Petroleum,
Petrochemical
and Natural Gas Industries-Steam Turbines- Special Purpose Applications,
Section
12.2, as evidenced by the lack of a digital turbine governor on the
Elliott 2EPG7
Steam turbine.  Condition noted on or about March 10, 2009.
b) Sunoco, Inc. Marcus Hook Refinery , 10-4 FCCU - The employer did not
document compliance with API Recommended Practice 617 Axial and Centrifugal
Compressors and  Expander-compressors for Petroleum, Chemical and Gas
Industry
Services, Section 3.4;  Gas Machinery Research Council Southwest Research
Institute, "Application Guideline For Centrifugal Compressor Surge Control
Systems", Section 3.3.9; and ASME B19.3b Safety Standard for Compressors
for
Process Industries, as evidenced by the lack of effective and process
integrated surge
control on the Clark 4114 centrifugal compressor.  Condition noted on or
about
March 10, 2009.
c) Sunoco, Inc. Marcus Hook Refinery , 10-4 FCCU - The employer did not
document compliance with API Recommended Practice 553 Refinery Control
Valves,
Section 5, as evidenced by the ineffective operation and inaccessible
location of the
10-4 Wet Gas Compressor Discharge valve at the Exchangers.  Condition
noted on or
about January 29, 2009.
d) Sunoco, Inc. Marcus Hook Refinery , 10-4 FCCU - The employer did not
document compliance with API Recommended Practice 553 Refinery Control
Valves,
Section 5, as evidenced by the ineffective operation and inaccessible
location of the
10-4 Wet Gas Compressor By-Pass valve.   Condition noted on or about March
10,
2009.
e) Sunoco, Inc. Marcus Hook Refinery , 10-4 FCCU - The employer did not
document compliance with API Recommended Practice 553 Refinery Control
Valves,
Section 5, as evidenced by the lack of platform or ladder at the manual
by-pass
valve
and TC-537 control valve.  Condition noted on or about March 10, 2009.
f) Sunoco Inc. Marcus Hook Refinery, 15-2 & 15-2B Alkylation Unit -  The
employer did not document compliance with RAGAGEP.  The employer's stated
RAGAGEP was Sunoco Portable Buildings & Alternative Enclosures Procedure,
Document No. PSM-122.  This procedure referred to API 753 as a source
standard.
A portable tool trailer, owned by J.J. White Incorporated, was placed
within an area
of the 15-2 & 15-2B alkylation unit which had potential exposure to a
maximum over
pressurization of 5 or more pounds per square inch (psi) during a vapor
cloud
explosion.  The trailer was occupied by an employee of J.J. White Inc.
The trailer
was not evaluated for occupancy or prevented from being occupied during
its time atthis location.  Condition noted on or about January 16, 2009.
g) Sunoco Inc. Marcus Hook Refinery, The employer did not document
compliance
with RAGAGEP.  The employer's stated RAGAGEP was API Recommended Practice
752 - "Management of Hazards Associated with Location of Process Plant
Buildings".
The following buildings were located in areas which had potential exposure
to vapor
cloud explosion.  The buildings listed were not depopulated or
structurally modified
to withstand the anticipated pressures.  Some buildings of such concern
are, but are
not limited to the following:
g.1) Sunoco Inc. Marcus Hook Refinery, 10-4 FCCU - The employer did not
document compliance with RAGAGEP.  The employer's stated RAGAGEP was API
Recommended Practice 752 - "Management of Hazards Associated with Location
of
Process Plant Buildings".  The 10-4 Control Building was located in an
area which
had potential exposure to a maximum over pressurization of between 1 and 3
pounds
per square inch (psi) during a vapor cloud explosion.  The control
building is an un-
reinforced masonry bearing wall structure.  API evaluates damage to such a
structure,
from partial collapse of walls to total destruction at the referenced
pressures.  The
control building was not depopulated or structurally modified to withstand
the
anticipated pressure.  Condition noted on or about January 22, 2009.
g.2) Sunoco Inc. Marcus Hook Refinery, 15-1 Plant - The employer did not
document
compliance with RAGAGEP.  The employer's stated RAGAGEP was API
Recommended Practice 752 - "Management of Hazards Associated with Location
of
Process Plant Buildings".  The 15-1 Control Building was located in an
area which
had potential exposure to a maximum over pressurization of between 3 and 5
pounds
per square inch (psi) during a vapor cloud explosion.  The control
building is an un-
reinforced masonry bearing wall structure.  API evaluates damage to such a
structure
at total destruction at the referenced pressures.  The control building
was not
depopulated or structurally modified to withstand the anticipated
pressure.  Condition
noted on or about January 22, 2009.
g.3) Sunoco Inc. Marcus Hook Refinery, 15-2 Plant - The employer did not
document
compliance with RAGAGEP.  The employer's stated RAGAGEP was API
Recommended Practice 752 - "Management of Hazards Associated with Location
of
Process Plant Buildings".  The 15-2 Control Building was located in an
area which
had potential exposure to a maximum over pressurization of between 3 and 5
pounds
per square inch (psi) during a vapor cloud explosion.  The control
building is an un-
reinforced masonry bearing wall structure.  API evaluates damage to such a
structure
at total destruction at the referenced pressures.  The control building
was not
depopulated or structurally modified to withstand the anticipated
pressure.  Condition
noted on or about January 22, 2009.
g.4) Sunoco Inc. Marcus Hook Refinery, 12-3 Plant - The employer did not
document
compliance with RAGAGEP.  The employer's stated RAGAGEP was API
Recommended Practice 752 - "Management of Hazards Associated with Location
ofProcess
Plant Buildings".  The 12-3 Control Building was located in an area which
had potential exposure to a maximum over pressurization of between 1 and 3
pounds
per square inch (psi) during a vapor cloud explosion.  The control
building is an un-
reinforced masonry bearing wall structure.  API evaluates damage to such a
structure,
from partial collapse of walls to total destruction at the referenced
pressures.  The
control building was not depopulated or structurally modified to withstand
the
anticipated pressure.  Condition noted on or about January 22, 2009.
g.5) Sunoco Inc. Marcus Hook Refinery, 17-1 Plant - The employer did not
document
compliance with RAGAGEP.  The employer's stated RAGAGEP was API
Recommended Practice 752 - "Management of Hazards Associated with Location
of
Process Plant Buildings".  The 17-1 Control Building was located in an
area which
had potential exposure to a maximum over pressurization of between 3 and
6.3
pounds per square inch (psi) during a vapor cloud explosion. The control
building
is
an un-reinforced masonry bearing wall structure.  API evaluates damage to
such a
structure at total destruction at the referenced pressures.  The control
building was not
depopulated or structurally modified to withstand the anticipated
pressure.  Condition
noted on or about January 22, 2009.
g.6) Sunoco Inc. Marcus Hook Refinery, Ethylene Complex - The employer did
not
document compliance with RAGAGEP.  The employer's stated RAGAGEP was API
Recommended Practice 752 - "Management of Hazards Associated with Location
of
Process Plant Buildings".  The Ethylene Complex Control Building was
located in an
area which had potential exposure to a maximum over pressurization of
between 1
and 3 pounds per square inch (psi) during a vapor cloud explosion.  The
control
building is an un-reinforced masonry bearing wall structure.  API
evaluates damage to
such a structure, from partial collapse of walls to total destruction at
the

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $5000.00 · Current $5000.00

General-duty citation text

29 CFR 1910.119(e)(3)(ii):  The process hazard analysis did not identify
any previous incident
which had a likely potential for catastrophic consequences in the
workplace:
a)  Sunoco Marcus Hook Refinery, 10 Plant:  The employer did not
incorporate
information from a prior incident with a likelihood for potentially
catastrophic
consequences into the next PHA conducted after the incident.  This is
evident by the fact
that incident #200210834 "High 10-4 Reactor Pressure from Water Addition"
occurred
on 5/02/2002, and information from the incident was not incorporated into
the PHA
conducted in 2006, on or about 1/28/2009.
b)  Sunoco Marcus Hook Refinery, 10 Plant:  The employer did not
incorporate
information from a prior incident with a likelihood for potentially
catastrophic
consequences into the next PHA conducted after the incident.  This is
evident by the fact
that incident #200310156 Low Instrument Air Problems at 10-4" occurred on
01/18/2003, and the incident was not incorporated into the PHA conducted
in 2006, on
or about 1/28/2009.
c)  Sunoco Marcus Hook Refinery, 10 Plant:  The employer did not
incorporate
information from a prior incident with a likelihood for potentially
catastrophic
consequences into the next PHA conducted after the incident.  This is
evident by the fact
that incident #200311893 "10-4 Emergency Shutdown", occurred on
07/07/2003, and the
incident was not incorporated into the PHA conducted in 2006, on or about
1/28/2009.
d)  Sunoco Marcus Hook Refinery, 10 Plant:  The employer did not
incorporate
information from a prior incident with a likelihood for potentially
catastrophic
consequences into the next PHA conducted after the incident.  This is
evident by the fact
that incident #200416378 "10-4 Bafco Power Supply Failure" occurred on
03/17/2004,
and the incident was not incorporated into the PHA conducted in 2006, on
or about
1/28/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $5000.00 · Current $7000.00

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) Sunoco, Inc. Marcus Hook Refinery, 10-4 FCCU - The employer did ensure
that
the 1996 process hazard analysis (PHA) addressed the consequences of
closing a valve
on a vent discharge of a relief device.  This is evidenced by the fact
that the PHA did
not identify the potential for closed vent valves on balanced bellows
relief valves,
including SV5085 through SV 5088, located on the V-12 overhead receiver.
Condition noted on or about February 18, 2009.
b) Sunoco, Inc. Marcus Hook Refinery, 10-4 FCCU - The employer did ensure
that
the 2001 process hazard analysis (PHA) addressed the consequences of
closing a valve
on a vent discharge of a relief device.  This is evidenced by the fact
that the PHA did
not identify the potential for closed vent valves on balanced bellows
relief valves,
including SV5085 through SV 5088, located on the V-12 overhead receiver.
Condition noted on or about February 18, 2009.
c) Sunoco, Inc. Marcus Hook Refinery, 10-4 FCCU - The employer did ensure
that
the 2006 process hazard analysis (PHA) addressed the consequences of
closing a valve
on a vent discharge of a relief device.  This is evidenced by the fact
that the PHA did
not identify the potential for closed vent valves on balanced bellows
relief valves,
including SV5085 through SV 5088, located on the V-12 overhead receiver.
Condition noted on or about February 18, 2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $5000.00 · Current $5500.00

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not effectively
address human
factors:
a) Sunoco, Inc. Marcus Hook Refinery, 10-4 FCCU - The employer did not
ensure
that the 1996 PHA effectively addressed human factors, as evident by the
fact that the
PHA did not address the inaccessible location, lack of position indicator,
and inability
of the operators to visually or tactually verify  the position of the 10-4
Wet Gas
Compressor By-Pass valve.   Condition noted on or about March 10, 2009.
b) Sunoco, Inc. Marcus Hook Refinery, 10-4 FCCU - The employer did not
ensure
that the 2001 PHA effectively addressed human factors, as evident by the
fact that the
PHA did not address the inaccessible location, lack of position indicator,
and
inability
of the operators to visually or tactually verify  the position of the 10-4
Wet Gas
Compressor By-Pass valve.   Condition noted on or about March 10, 2009.
c) Sunoco, Inc. Marcus Hook Refinery, 10-4 FCCU - The employer did not
ensure
that the 2006 PHA effectively addressed human factors, as evident by the
fact that the
PHA did not address the inaccessible location, lack of position indicator,
and inability
of the operators to visually or tactually verify  the position of the 10-4
Wet Gas
Compressor By-Pass valve.   Condition noted on or about March 10, 2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $5000.00 · Current $5000.00

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly
address the teams
findings and recommendations; assure that the recommendations are resolved
in a timely manner
and that the resolution is documented; and document what actions are to be
taken:
a) Sunoco, Inc. Marcus Hook Refinery - The employer did not assure that
Process.
Hazard Analyses (PHA) recommendations were resolved in a timely manner and
that the
resolution was documented, as evident by the fact that two (2) PHA's were
performed
for the addition of the No. 3 CO Boiler, between October, 1999 and
January, 2000, and
findings and recommendations provided by the PHA team were not resolved,
or the
resolution was not documented, on or about 3/16/2009.
b) Sunoco, Inc. Marcus Hook Refinery - The employer did not assure that
Process
Hazard Analyses (PHA) recommendations were resolved and that the
resolutions was
documented.  A PHA was performed in 1996 for the 10 Plant FCCU, and
findings and
recommendations provided by the PHA team were not resolved, or the
resolution was
not documented. On or about 3/16/2009.
c) Sunoco, Inc. Marcus Hook Refinery - The employer did not assure that
Process
Hazard Analyses (PHA) recommendations were resolved in a timely manner and
that the
resolution was documented, as evident by the fact that a PHA was performed
in 2001 for
the 10 Plant FCCU, and findings and recommendations provided by the PHA
team were
not resolved, or the resolution was not resolved in a timely manner, or
the resolution was
not documented, on or about 3/16/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $5000.00 · Current $7000.00

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)  Sunoco Marcus Hook Refinery - The employer did not ensure that Sunoco
employees
and contract employees followed established procedures for entering and
exiting the 10
Plant, as evident by the fact that the Visitor's Logs for the 10 Plant,
including those from
approximately 12/04/2008 to approximately 2/20/2009, contained numerous
deficiencies,
including the failure to log the time in, time out, specific location in
the unit, and date,
exposing employees to the potential of not being located in the event of
an emergency.
Violation documented on or about 2/20/2009.
b)  Sunoco Marcus Hook Refinery -  The employer did not ensure that Sunoco
employees
and contract employees followed established procedures for opening process
equipment
or piping, as evident by the fact that a contract employee attempted to
remove a ball
valve in the 15-2 Plant, on 12/30/2008, and the employer did not ensure
the contractor
followed the procedures detailed in Sunoco Safety Standard #19 "Draining,
Unplugging,
Opening, and Blanking/Blinding Lines, Vessels, and Process Equipment" and
Sunoco
Safety Standard #17 Personal Protective Equipment and Safety Equipment."
The
employee was splashed with acid resulting in first and second degree burns
to the face
and neck.  Violation documented on or about 01/13/2009.
c)  Sunoco Marcus Hook Refinery -  The employer did not ensure that Sunoco
employees
and contract employees followed established procedures for opening process
equipment
or piping, as evident by the fact that a contract employee attempted to
remove a ball
valve in the 15-2 Plant, on 12/30/2008, and the employer did not ensure
the contractor
followed the procedures detailed in Sunoco Safety Standard #55 "Job Safety
Analysis
Card Use."   Violation documented on or about 01/13/2009.
d)  Sunoco Marcus Hook Refinery -  The employer did not ensure that Sunoco
employees
and contract employees followed established procedures for opening process
equipment
or piping, as evident by the fact that a contract employee attempted to
remove a ball
valve in the 15-2 Plant, on 12/30/2008, and the employer did not ensure
the contractor
followed the procedures detailed in Sunoco Heath and Safety Procedure
Number 3052
"Permit System Rules."  Violation documented on or about 01/13/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

General-duty citation text

29 CFR 1910.119(h)(2)(iv):  The employer did not develop and implement
safe work practices
consistent with paragraph (f)(4) of this section, to control the entrance,
presence and exit of
contract employers and contract employees in covered process areas:
a) Sunoco Marcus Hook Refinery - The employer did not ensure that contract
employees
followed established procedures for entering and exiting the 10 Plant, as
evident by the
fact that the Visitor's Logs for the 10 Plant, including those from
approximately
12/04/2008 to approximately 2/20/2009, contained numerous deficiencies,
including the
failure to log the time in, time out, specific location in the unit, and
date, exposing
employees to the potential of not being located in the event of an
emergency, on or about
2/20/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $5000.00 · Current $5000.00

General-duty citation text

29 CFR 1910.119(g)(3):  The employer did not prepare a means of verifying
that the employee
had received and understood the training required by 29 CFR 1910.119(g):
a)  Sunoco Marcus Hook Refinery, 10 Plant:   The employer did not ensure
that
employees received and understood training on new or revised operating
procedures, as
evident by the fact that a Board Operator in the 10 Plant was not trained
on, and the
employer did not verify that the employee understood, Procedure Number
104D.240
"Putting the New Ejector for the Wet Gas Compressor Seals in Service.", on
or about
4/21/2009.
b) Sunoco Marcus Hook Refinery, 10 Plant:   The employer did not enure that
employees received and understood training on new or revised operating
procedures, as
evident by the fact that the employer did not require a Shift Supervisor
to demonstrate
proficiency on all procedures for which the employee was qualified, on or
about
2/19/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIREDN

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $5000.00 · Current $7000.00

General-duty citation text

29 CFR 1910.119(i)(2)(i): The pre-startup safety review did not confirm
that prior to the
introduction of highly hazardous chemicals to the process, that
construction and equipment were
in accordance with design specifications:
a)  Sunoco Marcus Hook Refinery:  The employer did not complete the PSSR
before
implementing a change to equipment in a covered process, as evident by the
fact
that
temporary MOC 10-420050415-2 was completed and approved for operation, and
the
PSSR was marked completed, on 05/09/2005, but the change was in place and
the
temporary MOC was marked removed on 5/06/2005.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIREDN

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

29 CFR 1910.119(j)(4)(ii):  Inspections and testing procedures performed
on process equipment
to maintain its mechanical integrity, did not follow recognized and
generally accepted good
engineering practices:
a) Sunoco Marcus Hook Refinery, Ethylene Complex:  The employer did not
follow
recognized and generally accepted good engineering practices (RAGAGEP), as
evident
by the fact that Ethylene Sphere TK-1001, used to store and transfer
liquid ethylene, was
placed into continuous service since 1961, and the employer did not
conduct inspections
of the inner aluminum shell of the sphere.  On or about 3/12/2009.
b) Sunoco Marcus Hook Refinery, Ethylene Complex:  The employer did not
follow
recognized and generally accepted good engineering practices (RAGAGEP), as
evident
by the fact that Ethylene Sphere TK-1002, used to store and transfer
liquid ethylene, was
placed into continuous service since 1967, and the employer did not
conduct inspections
of the inner aluminum shell of the sphere.  On or about 3/12/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $5000.00 · Current $7000.00

General-duty citation text

29 CFR 1910.119(j)(4)(iii):  The frequency of inspections and tests of
process equipment to
maintain its mechanical integrity, was not consistent with applicable
manufacturers'
recommendations and good engineering practices, or more frequently
determined to be necessary
by prior operating experience:
a) Sunoco, Inc. Marcus Hook Refinery , 10-4 FCCU - The employer did not
document
compliance with API Standard 653, Tank Inspection, Repair, Alteration, and
Reconstruction, as evident by the fact that the 10 Plant Fraid Stack was
not inspected by
the employer at the frequency required in Sections 4.3 and 4.4., and did
not maintain
construction, inspection, and repair/alteration records in accordance with
Section 4.8.
Condition noted on or about 4/15/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIREDN

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

General-duty citation text

29 CFR 1910.119(j)(4)(iv):  The documentation of the inspection or test
that been performed on
process equipment to maintain its mechanical integrity did not identify
the date of the inspection
or test, the serial number or other identifier of the equipment on which
the inspection or test was
performed, a description of the inspection or test, and the results of the
inspection or test:
a)  Sunoco Marcus Hook Refinery, 10 Plant FCCU - The employer's
documentation of
inspections conducted of the 10 Plant Fraid Stack did not include the date
of
the test, the
name of the inspector, and a description of the inspection of test, for
inspection
conducted in 1996 and 2000.  Violation noted on or about 4/15/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $5000.00 · Current $7000.00

General-duty citation text

29 CFR 1910.119(m)(5):  The employer did not establish a system to
promptly and
effectively address and resolve the incident report findings and
recommendations:
a) Sunoco, Inc. Marcus Hook Refinery,10-4 FCCU - The employer did not
promptly
and effectively address the incident investigation findings and
recommendations
regarding the inability of the Operators to access and operate the wet gas
discharge
valve located at the exchangers.  Condition noted on or about January 29,
2009.
b) Sunoco, Inc. Marcus Hook Refinery, 10-4 FCCU - The employer did not
promptly
and effectively address the incident investigation findings and
recommendations
regarding the inability of the Operators to access and operate the wet gas
compressor
by-pass valve. Condition noted on or about March 10, 2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $5000.00 · Current $7000.00

General-duty citation text

29 CFR 1910.119(o)(4):  The employer did not promptly determine and
document an
appropriate response to each of the findings of the compliance audit, and
document that
deficiencies have been corrected:
a)  Sunoco Marcus Hook Refinery:  The employer conducted a PSM audit of the
refinery in August, 2007, and did not promptly resolve and document the
resolution
of finding number PM9, on or about 01/13/2009.
B)  Sunoco Marcus Hook Refinery:  The employer conducted a PSM audit of the
refinery in August, 2007, and did not promptly resolve and document the
resolution
of finding number PM10, on or about 01/13/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-07-27 00:00:00

Penalty

Initial $2500.00 · Current $2500.00

General-duty citation text

29 CFR 1910.132(a):  Protective equipment was not provided, used and
maintained in a sanitary
and reliable condition when necessary whenever hazards capable of causing
injury and
impairment were encountered:
a) Sunoco, Marcus Hook, 6 Oil Loading Rack, Riser #3 - An employee of Lee
Transport
Systems, LLC was exposed to a fall hazard of approximately 12 feet while
standing atop
the tanker trailer loading it with oil and not utilizing any means of fall
protection.
Observed 3/31/2009.
CERTIFICATION OF ABATEMENT OF THIS VIOLATION IS REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $2500.00 · Current $2500.00

General-duty citation text

29 CFR 1910.151(c):  Where employees were exposed to injurious corrosive
materials, suitable
facilities for quick drenching or flushing of the eyes and body were not
provided
within the work
area for immediate emergency use:
a)  Sunoco, Inc. Marcus Hook Refinery - The employer did not ensure a
suitable
emergency eyewash and shower was provided for employee's exposed to
corrosive
materials, as evident by the fact that a J.J. White contract employee,
performing work
at the 15-2 Alky Unit, was splashed with sulfuric acid, and the shower
provided to the
employee for immediate first aid response was not equipped with tepid
water, causing
the premature cessation of first aid treatment to the employee.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED
ABATEMENT NOTE:  American National Standards Institute (ANSI) standard
Z358.1-
1998, Appendix B, Section 6 identifies the hazard of prolonged exposure to
cold fluids
in emergency showers, and recommends the provision of "flushing fluid at
temperatures
conductive to use for the recommended irrigation period" as an "integral
part of
providing suitable facilities."  To abate this hazard, where emergency
showers are
required the employer must provide showers equipped with tepid water.

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $25000.00 · Current $7000.00 Reduced

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) Sunoco, Marcus Hook, 10-4 Plant - Sunoco did not ensure that the P&IDs
accurately
represented the following equipment for the process:
1) Various vessel and exchanger information tables did not include each
vessel's/exchanger's design and operating pressures and/or temperatures.
These
vessels/exchangers included but were not limited to:
A) V-17 & V113 on P&ID:26005A, sheet 02
B) E-7 & E-9A/B on P&ID:26005A, sheet 10
C) V-15 & V22 on P&ID: 25005A, sheet 26
D) E-15A/B/C on P&ID:26005A, sheet 14
E) E-8A/B & T-3 on P&ID:26005A, sheet 13
F) E94A/B on P&ID:26005A, sheet 08
G) V-11 & V-12 on P&ID:26005A, sheet 04
H) E-16 & T-4 on P&ID:26005A, sheet 01
2) Various intervening block valves upstream & downstream of relief valves
which had
been identified by Sunoco as being part of the car-seal program, were not
identified as
such on the P&IDs as being car-sealed open.  Intervening block valves not
identified on
the P&IDs as being car-sealed included but were not limited to:
A) Block valves for RV-101, P&ID:26005A, sheet 08
B) Block valves for RV-102, P&ID: 26005A, sheets 04 &08
C) Block valve for Flare Header, P&ID:A-28409, sheet 01
D) Upstream block for SV-31, P&ID: 26005A, sheet 13
E) Downstream block valve for SV-157, P&ID:26005A, sheet 13
F) Downstream block valve for SV-20C, P&ID:26005A, Sheet 14
G) Downstream block valve for SV-20B, P&ID:26005A, Sheet 14
H) Downstream block valve for SV-20A, P&ID:26005A, Sheet 14
I) Block valves for RV-155, P&ID:26005A, Sheet 14
J) Downstream block valve for RV-153, P&ID:26005A, Sheet 14
K) Downstream block valve for RV-154, P&ID:26005A, Sheet 14
L) Upstream block valve for SV-17A, P&ID:26005A, Sheet 26
M) Upstream block valve for SV-17B, P&ID:26005A, Sheet 26
N) Block valves for RV-158, P&ID:26005A, Sheet 10
O) Block valves for SV-21, P&ID:26005A, Sheet 10
P) Block valves for RV-159, P&ID:26005A, Sheet 10
Q) Block valves for RV-22B, P&ID:26005A, Sheet 10
R) Downstream block valve for RV-22A, P&ID:26005A, Sheet 10
S) Downstream block valve for RV-159, P&ID:26005A, Sheet 10
T) Downstream block valve for RV-160, P&ID:26005A, Sheet 10
U) Block valves for RV-131, P&ID: 26005A, sheet 02
3) Various relief valves located on P&IDs did not have any set pressure
values identified.
Those relief valves included but were not limited to:
A) SV-24A, P&ID: 26005A, sheet 02 (Gas Compressor Discharge Drum, V-17)
B) SV-24B, P&ID: 26005A, sheet 02 (Gas Compressor Discharge Drum, V-17)
C) RV-158, P&ID: 26005A, sheet 10 (E-7, Shell side)
D) RV-121, P&ID: 26005A, sheet 16 (E-96C/D, shell side)
E) RV-???, P&ID: 26007A, sheet 09 (R28 Separator)
F) RV-???, P&ID: 26007A, sheet 09 (R29 Separator)
4) Downstream block valves of relief valves were not identified on the
P&IDs. These
unidentified downstream block valves included but were not limited to:
A) Block valve downstream of SV-20C, P&ID: 26005A, sheet 14
B) Block valve downstream of SV-20B, P&ID: 26005A, sheet 14
5) Relief valves are not identified on the P&IDs.  These valves include,
but are not
limited to:
A) E-16 exchanger on P&ID: 26005A sheet 1
B) R28 Separator on P&ID 26007A, sheet 9
C) R29 Separator on P&ID 26007A, sheet 9
6) Specific relief valves identified in the P&IDs do not have accurately
corresponding
serial numbers within the PCMS & Marlin systems.  Such valves included but
were not
limited to:
A) E-94:
1) RV-101, tube side relief, is wrongly identified (PCMS) as having valve
SV-2576 installed with actual valve being SV-4312
2) RV-102, shell side relief, is wrongly identified (PCMS) as having valve
SV-2578 installed with actual valve being SV-2576
B) E-15A:
1) RV-153, shell side relief, is wrongly identified (PCMS) as having valve
SV-0962 installed with actual valve being SV-6062
2) SV-20C, tube side relief, is wrongly identified (PCMS) as having valve
SV-2062 installed with actual valve being SV-0962
C) E-15B:
1) On the PCMS SV-3429 is identified as being for both tube & shell side
relief valves (RV-154 & SV-20B)
2) RV-154, shell side relief, is wrongly identified (PCMS) as having valve
SV-2315 installed with actual valve being SV-2439
D) E-15C:
1) SV-20C, shell side relief, is wrongly identified (PCMS) as having valve
SV-2068 installed with actual valve being SV-6068
Deficiencies listed above were observed & documented between 2/2/2009 and
4/27/2009.
Sunoco, Inc. was previously cited for a violation of this Occupational
Safety and
Health Standard or its equivalent standard, which was contained in OSHA
Inspection: #312716386, Citation #1, Item #1A and affirmed as a final
order on
1/21/2008, with respect to a workplace located at the Philadelphia plant.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $25000.00 · Current $7000.00 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 involved in each
covered process consistent with the process safety information:
a) Sunoco Marcus Hook Refinery - The employer did not implement Safety
Standard
#64, Appendix D, "Temporary Alarm System Changes", which identified the
steps
required to manage temporary alarm changes, as evident by the fact that
the approval
forms used to authorize and manage alarm changes were not properly
initiated, approved,
authorized, and maintained in the 10 Plant Control Room.  On or about
2/19/2009.
Sunoco, Inc. was previously cited for a violation of this Occupational
Safety and
Health Standard or its equivalent standard, which was contained in OSHA
Inspection: #312716386, Citation #1, Item #3A and affirmed as a final
order on
1/21/2008, with respect to a workplace located at the Philadelphia plant.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $25000.00 · Current $25000.00

General-duty citation text

29 CFR 1910.119(j)(2):  The employer did not establish and implement
written procedures to
maintain the on-going mechanical integrity of process equipment:
a)  Sunoco Marcus Hook Refinery:  The employer did not establish and
implement a
written procedure for maintaining the on-going mechanical integrity of
ethylene storage
spheres TK-1001 and TK-1002, including but not limited to a procedure for
monitoring
the annular purge for potential hydrocarbon contamination,  and no
procedure for internal
inspections.  On or about 3/13/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED
Sunoco, Inc. was previously cited for a violation of this Occupational
Safety and
Health Standard or its equivalent standard, which was contained in OSHA
Inspection: #310720263, Citation #1, Item #1A and affirmed as a final
order on
09/15/2008, with respect to a workplace located at the Marcus Hook plant.

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $25000.00 · Current $25000.00

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) Sunoco Marcus Hook Refinery - The employer did not conduct a Management
Of
Change (MOC) to manage changes to a covered process, as evident by the
fact that the
17-1P was operated in "partial reverse mode", and the employer did not
conduct an
MOC, on or about 1/21/2009.
b) Sunoco Marcus Hook Refinery - The employer did not conduct a Management
Of
Change (MOC) to manage changes to equipment in a covered process, as
evident by the
fact that a 2000 gallon skid-mounted ammonia storage tank with vaporizer
and associated
piping was installed in the 10-Plant on or about March 24, 2004, and the
temporary
MOC #10-420040323-2 associated with this change was not extended, removed,
or made
permanent, and the equipment was placed into operation before the
Pre-Startup Safety
Review (PSSR) was complete, and the equipment remained in operation
approximately
five years later, on or about 3/11/2009.
c) Sunoco Marcus Hook Refinery - The employer did not conduct a Management
Of
Change (MOC) to manage changes to equipment in a covered process, as
evident by the
fact that a temporary MOC was initiated on 4/15/2005, for the installation
of a new
injection point and the modification of piping for the ammonia tank in 10
Plant, and the
temporary change was complete and the MOC was removed before the
Pre-Startup
Safety
Review (PSSR) was completed, on or about 3/11/2009.
d) Sunoco Marcus Hook Refinery -  The employer did not conduct a
Management Of
Change (MOC) to manage changes to equipment in a covered process, as
evident by the
fact that the 2,000 gallon skid-mounted ammonia storage tank was replaced
in 2008, and
the change included a change in how inventory of the storage tank was
controlled, and
the employer did not conduct an MOC to manage the change, on or about
5/05/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED
Sunoco, Inc. was previously cited for a violation of this Occupational
Safety and
Health Standard or its equivalent standard, which was contained in OSHA
Inspection: #312716386, Citation #1, Item #4D and affirmed as a final
order on
1/21/2008, with respect to a workplace located at the Philadelphia plant.

Issued

2009-07-08 00:00:00

Abate by

2009-08-10 00:00:00

Penalty

Initial $25000.00 · Current $7000.00 Reduced

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) Sunoco Marcus Hook Refinery - The employer conducted Management of
Change
(MOC) Number 10-420040323-2, for the installation of a 2,000 gallon
anhydrous
ammonia storage tank and associated piping, and the P&ID was not updated
to reflect
the change, on or about 01/09/2009.
b) Sunoco Marcus Hook Refinery - The employer conducted Management of
Change
(MOC) Number 10-420040629-1, for the installation of an additional
injection quill on
the ammonia injection system, and the P&ID was not updated to reflect the
change, on
or about 01/09/2009.
NOTE: DOCUMENTATION OF ABATEMENT OF THIS CONDITION IS
REQUIRED
Sunoco, Inc. was previously cited for a violation of this Occupational
Safety and
Health Standard or its equivalent standard, which was contained in OSHA
Inspection: #312716386, Citation #1, Item #1B and affirmed as a final
order on
1/21/2008, with respect to a workplace located at the Philadelphia plant.