OSHA Inspection: LION OIL COMPANY, INC.

Issued

Oct 19, 2009

Abate by

Nov 23, 2009

Penalty

Initial $2,250 · Current $2,250

General-duty citation text

29 CFR 1910.23(a)(2):  Ladderway floor opening(s) or platform(s) were not
provided with
swinging gates or were not so offset that a person could not walk directly
into the opening:
a.On or about June 2, 2009, and at times prior thereto and thereafter, at
the facility
located at 1000 McHenry in El Dorado, Arkansas, at the Fluid Catalytic
Cracking
Unit #7 (FCCU#7), the ladderway opening to the fixed ladder on the west
side
of the overhead condenser level was equipped with a single chain across
the top
of the opening.  This condition exposed employees walking and working in
the
area to the hazard of falls from elevation.
b.On or about June 2, 2009, and at times prior thereto and thereafter, at
the facility
located at 1000 McHenry in El Dorado, Arkansas, at the Fluid Catalytic
Cracking
Unit #7 (FCCU#7), the ladderway opening to the northern fixed ladder on the
east side of the overhead condenser level was equipped with a single chain
across
the top of the opening.  This condition exposed employees walking and
working
in the area to the hazard of falls from elevation.
c.On or about June 2, 2009, and prior thereto, at the Fluid Catalytic
Cracking Unit
#7, the southern fixed ladderway opening on the east side of the overhead
condenser level was equipped with a single chain across the top of the
opening.
This condition exposed employees walking and working in the area to the
hazard
of falls from elevation.

Issued

Oct 19, 2009

Abate by

Oct 22, 2009

Penalty

Initial $2,250 · Current $2,250

General-duty citation text

29 CFR 1910.23(c)(1):  Open sided floor(s) or platform(s) 4 feet or more
above the adjacent
floor or ground level were not guarded by standard railings (or the
equivalent as specified in 29
CFR 1910.23(e)(3)(i) through (v)), on all open sides:
a.On or about June 2, 2009, and at times prior thereto and thereafter, at
the facility
located at 1000 McHenry in El Dorado, Arkansas, at the Fluid Catalytic
Cracking
Unit #7 (FCCU#7), approximately 20.5 inches of the standard railing
between the
north end of the fractionator overhead condenser tanks on the south end of
the
overhead condenser level was not equipped with a mid rail.  This condition
exposed employees walking and working in the area to the hazard of falls
from
elevation.
b.On or about June 2, 2009, and at times prior thereto and thereafter, at
the facility
located  at 1000 McHenry in El Dorado, Arkansas, at the Fluid Catalytic
Cracking Unit #7 (FCCU#7), the guardrail between the north end of the
fractionator overhead condenser tanks on the south end of the overhead
condenser
level had an opening of approximately 20.5 inches without a top rail or
mid rail.
This condition exposed employees walking and working in the area to the
hazard
of falls from elevation.

Issued

Oct 19, 2009

Abate by

Oct 22, 2009

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.119(c)(2):   The employer did not consult with employees and
their representative
on the conduct and development of process hazards:
On or about March 2001, and at times prior thereto and thereafter, at the
facility located
at 1000 McHenry in El Dorado, Arkansas the employer did not consult with
employees
and their representatives on the conduct and development of the mini
process hazard
analysis (PHA) on facility siting and human factors that was a part of the
2001 PHA
Revalidation.es

Issued

Oct 19, 2009

Abate by

Oct 22, 2009

General-duty citation text

29 CFR 1910.119(e)(3)(v):  The process hazard analysis did not address
facility siting:
On or about June 2, 2009, and at times prior thereto and thereafter, at
the facility located
at 1000 McHenry in El Dorado, Arkansas, for the Fluid Catalytic Cracking
Unit #7, the
employer did not assure that the mini process hazard analysis that was
conducted during
the 2001 Revalidation adequately addressed facility siting in that the
"What If" checklist
did not contain specific justifications for each individual situation or
condition on the
global generic questions such as but not limited to the following:  2.1,
2.2, 2.3 , 2.4,
2.5, 2.6, 2.7, 2.9, 2.10, 2.11, 2.12, 2.14, 2.15, 2.16, 2.17, 2.18, 2.19,
2.20, 2.21,
2.22, 2.23, 2.24, 2.25, 2.26, 2.28, 2.29, 2.30, 2.31, 2.32, 2.43, 2.44,
2.45, 2.46, 2.47,
2.48, 2.49, 2.51, 2.53, 2.54, 2.55, 2.56, 2.57, 2.58, 2.59, 2..60, 2.61,
2.62, 2.63,
2.64, 2.65, 2.66, 2.67, 2.68, 2.69, 2.70, 2.71, 2.72, 2.73, 2.74, 2.75,
2.76, 2.77, 2.80,
2.81, 2.82, 2.83, 2.84, 2.85, 2.86, 2.87, 2.88, 2.89, 2.90, 2.91, 2.92,
2.94, 2.95, 2.96,
2.97, 2.98, 2.99, 2.100, 2.101, 2.102, 2.103, 2.104, 2.105, 2.106, 2.107,
2.108 and
2.109.

Issued

Oct 19, 2009

Abate by

Oct 22, 2009

General-duty citation text

29 CFR 1910.119(e)(3)(vi):  The process hazard analysis did not address
human factors:
On or about June 2, 2009, and at times prior thereto and thereafter, at
the facility located
at 1000 McHenry in El Dorado, Arkansas, for the Fluid Catalytic Cracking
Unit #7, the
employer did not assure that the mini process hazard analysis that was
conducted during
the 2001 Revalidation adequately addressed human factors in that the "What
If" checklist
did not contain specific justifications for each individual situation or
condition on the
global generic questions such as but not limited to the following:  1.4,
1.6, 1.7, 1.9,
1.10, 1.11, 1.12, 1.13, 1.14, 1.15, 1.16, 1.18, 1.19, 1.20, 1.21, 1.22,
1.23, 1.24, 1.25,
1.28, 1.30, 1.31, 1.32, 1.33, 1.34, 1.35, 1.41, 1.42, 1.43, 1.44, 1.45,
1.46, 1.47, 1.48,
1.49, 1.50, 1.51, 1.52, 1.53, 1.54, 1.55, 1.56, 1.57, 1.58 and 1.59.

Issued

Oct 19, 2009

Abate by

Oct 22, 2009

Penalty

Initial $2,250 · Current $2,250

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):
On or about June 2, 2009, and at times prior thereto and thereafter, at
the facility located
at 1000 McHenry in El Dorado, Arkansas, in the following instances, the
process safety
information depicted on the piping and instrument diagrams was not updated
or validated
to reflect current field design conditions at the Fluid Catalytic Cracking
Unit
#7:
a.Drawing D-51-173 depicted  an 8 inch block vale car sealed open located
downstream from 07PSV 109 that was not present in the field.
b.Drawing D-51-173 depicted an 8 inch block valve car sealed open located
downstream from 07PSV 110 that was not present in the field.
c.In the field, the collar plate for Fractionator Overhead Condenser 101
had 0007-
100 stamped in the metal.
d.In the field, the collar plate for Fractionator Overhead Condenser 100
was labeled
0007-101 in black and white.
On or about June 9, 2009, and prior thereto, at the facility located at
1000 McHenry, El
Dorado, Arkansas, in the following instances, the process safety
information depicted on
the piping and instrument diagrams was not correct in that the temperature
design limit
on the P&ID for the regenerator was listed as 650 degrees F which did not
take
into
consideration that the vessel was lined with refractory which increased
the design limit
to 1450 degrees F:
e.Drawing D-51-167 revision 11
f.Drawing D-51-168 revision 11vision

Issued

Oct 19, 2009

Abate by

Oct 22, 2009

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:
On or about June 9, 2009, and at times prior thereto and thereafter, at
the facility located
at 1000 McHenry in El Dorado, Arkansas, the employer did not include the
relief system
design or design basis in its Process Safety Information (PSI) for the
Fluid Catalytic
Cracking Unit #7 (FCCU#7) Feed Preheater Header Blowdown Drum 007-031.

Issued

Oct 19, 2009

Abate by

Oct 22, 2009

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.119(d)(3)(ii):  The employer did not document that the
equipment in the process
complied with recognized and generally accepted good engineering practices:
On or about May 14, 2009, and at times prior thereto and thereafter, at
the facility
located at 1000 McHenry in El Dorado, Arkansas, the employer did not
comply with
recognized and generally acceptable good engineering practice (RAGAGEP)
when it
failed to protect employees inside inadequately protected structures that
were exposed to
explosion, fire and high pressure hazards as a result of a highly
hazardous chemical
release from process equipment in the following instances:
a.Building #04 Field House for Unit #5
b.Building #05 Field House for Unit #7it

Issued

Oct 19, 2009

Abate by

Oct 22, 2009

Penalty

Initial $2,250 · Current $2,250

General-duty citation text

29 CFR 1910.119(e)(1):  The process hazard analysis was not appropriate to
the complexity of
the process and did not identify, evaluate, and address the control of the
hazards involved in the
process:
On or about June 9, 2009, and at times prior thereto and thereafter, at
the facility located
at 1000 McHenry in El Dorado, Arkansas, the employer did not identify or
determine
in when it conducted the Process Hazard Analysis (PHA) whether the relief
system
design for the Fluid Catalytic Cracking Unit #7 (FCCU #7) was adequate at
the unit's
actual throughput for the discharge of Cat Feed (hot gas oil) from the Cat
Feed Pre-
heater Header Pressure Safety Valve (PSV) relief system into Blowdown Drum
007-031.

Issued

Oct 19, 2009

Abate by

Oct 22, 2009

General-duty citation text

29 CFR 1910.119(e)(6):  The employer did not ensure that the process
hazard analysis was
consistent with the current process:
On or about June 9, 2009, and at times prior thereto and thereafter, at
the facility located
at 1000 McHenry in El Dorado, Arkansas, the employer failed to consider in
its Process
Hazard Analysis (PHA) update/revalidation, the throughput increase and any
potential
effect the increase might have on the adequacy of the current process,
including the
existing relief system.

Issued

Oct 19, 2009

Abate by

Oct 22, 2009

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.119(e)(5):  The employer did not assure that the process
hazard analysis team's
recommendations were resolved in a timely manner and that the resolution
was documented:
On or about June 9, 2009, and at times prior thereto and thereafter, at
the facility located
at 1000 McHenry in El Dorado, Arkansas, for the Fluid Catalytic Cracking
Unit #7 the
employer did not assure that the following nodes for the 1995 Process
Hazard Analysis
(PHA) were resolved in a timely manner and that the resolution was
documented:
a.Node Number 171-02
b.Node Number 166-09
c.Node Number 166-01
d.Node Number 169-01
e.Node Number 166-07
f.Node Number 166-08
g.Node Number 166-04
h.Node Number 163-05

Issued

Oct 19, 2009

Abate by

Nov 23, 2009

Penalty

Initial $2,250 · Current $2,250

General-duty citation text

29 CFR 1910.119(f)(1):  The employer did not develop and implement written
operating
procedures that provided clear instructions for safety conducting
activities in each covered
process consistent with the process safety information and which addressed
the elements listed
in 29 CFR 1910.119(f)(1)(i) through (f)(1)(v):
a.On or about June 6, 2009, and at times prior thereto and thereafter, at
the facility
located at 1000 McHenry in El Dorado, Arkansas, the written operating
procedures for the No. 7 Charge Heater Relief Valves dated 6-5-09 was not
accurate in that it did not reflect two handwritten changes made on 5-26-09
attached to management of change (MOC) 10-16-08-007.
b.On or about June 6, 2009, and at times prior thereto and thereafter, at
the facility
located at 1000 McHenry in El Dorado, Arkansas, the written operating
procedure for Emergency Shutdown did not accurately reflect the operators
assigned to step numbers 1.1, 1.2, 1.3, 1.4, 1.5, 1.5, 1.9, and 1.11
listed in the
shutdown procedure.
c.On or about June 6, 2009, and at times prior thereto and thereafter, at
the facility
located at 1000 McHenry in El Dorado, Arkansas, the written operating
procedure for Regenerator Afterburning did not reflect the operators
assigned to
step numbers: 4.1, 4.2, 4.3, 4.4, 4.5, 5.1, 5.2, 5.3, 5.4, and 5.5 listed
in the
procedure.
d.On or about May 5, 2009, and at times prior thereto and thereafter, at
the facility
located at 1000 McHenry in El Dorado, Arkansas, the employer failed to
develop
written emergency operating procedures for the blowdown drum at the Fluid
Catalytic Cracking Unit #7.t

Issued

Oct 19, 2009

Abate by

Nov 23, 2009

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 in a safe and timely
manner:
On or about July 13, 2009, and at times prior thereto and thereafter, at
the facility
located at 1000 McHenry in El Dorado, Arkansas, the written emergency
shutdown
procedure did not assign qualified operators with the responsibility of
shutting down
Fluid Catalytic Cracking Unit #7.t

Issued

Oct 19, 2009

Abate by

Nov 23, 2009

General-duty citation text

29 CFR 1910.119(f)(1)(ii):  The employer's written operating procedures
did not address the
requirements for the operating limits listed in 29 CFR
191.119(f)(1)(ii)(A) and (B):
a.On or about June 9, 2009, and at times prior thereto and thereafter, at
the facility
located at 1000 McHenry in El Dorado, Arkansas, the employer did not list
in
the normal operating procedure for the regenerator afterburning the
operating
limits to identify when the normal operating procedure was applicable or
required.
b.On or about June 9, 2009, and at times prior thereto and thereafter, at
the facility
located at 1000 McHenry in El Dorado, Arkansas, the employer did not list
in
the emergency operating procedure for hydraulic oil failure the operating
limits
for when the emergency operating procedure was applicable or required.
c.On or about June 9, 2009, and at times prior thereto and thereafter, at
the facility
located at 1000 McHenry in El Dorado, Arkansas, the employer did not list
in
the emergency shutdown procedure for Fluid Catalytic Cracking Unit #7 the
operating limits when the procedure was applicable or required.e

Issued

Oct 19, 2009

Abate by

Nov 16, 2009

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.119(h)(2)(ii):  The employer did not inform contract employers
of the known
potential fire, explosion, or toxic release hazards related to the
contractor's
work and the
process:
On or about June 24, 2009, and at times prior thereto, at the facility
located at 1000
McHenry in El Dorado, Arkansas, at the light straight run reflux pump, the
employer
failed to notify contract employees of the potential of a hydrocarbon
release during the
scheduled performance of pump shut-down, repair, and restart maintenance
procedures.
Employees of J. Christy construction were working in accordance with an
active hot
work permit during this procedure.  A release did occur; the source of
which was within
17 feet of the employees, exposing them to the hazards of fire or
explosion.

Issued

Oct 19, 2009

Abate by

Oct 22, 2009

Penalty

Initial $2,250 · Current $2,250

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:
On or about June 9, 2009, and at times prior thereto and thereafter, at
the
facility located
at 1000 McHenry in El Dorado, Arkansas the employer operated the Fluid
Catalytic
Cracking Unit #7 (FCCU#7) while the Cat Feed Preheater Header relief system
Blowdown Drum (007-031) was undersized and did not provide sufficient
liquid retention
capability to prevent Cat Feed (hot gas oil) discharged from the Preheater
Header PSVs
#156 and #157 from reaching an ignition source and/or creating a thermal
burn hazard
at grade.

Issued

Oct 19, 2009

Abate by

Nov 5, 2009

Penalty

Initial $2,250 · Current $2,250

General-duty citation text

29 CFR 1910.119(n):  The employer's emergency action plan did not include
procedures for
handling small releases:
On or about May 5, 2009, and at times prior thereto and thereafter, at the
facility located
at 1000 McHenry in El Dorado, Arkansas, Lion Oil Company's written
emergency
response plan/action plan did not include a procedure that instructed
employees how to
distinguish between small releases and large releases and what employee
actions were
required.

Issued

Oct 19, 2009

Abate by

Oct 22, 2009

General-duty citation text

29 CFR 1910.120(q)(2)(vii):  The emergency response plan did not address,
to the extent not
addressed elsewhere, the decontamination:
On or about May 5, 2009, and at times prior thereto and thereafter, at the
facility located
at 1000 McHenry in El Dorado, Arkansas, Lion Oil Company Inc.'s written
emergency
response plan did not address decontamination procedures.tion

Issued

Oct 19, 2009

Abate by

Nov 16, 2009

General-duty citation text

29 CFR 1910.120(q)(2)(x):  The emergency response plan did not address, to
the
extent not
addressed elsewhere, the critique of response and follow-up:
On or about May 5, 2009, and at times prior thereto and thereafter, at the
facility located
at 1000 McHenry in El Dorado, Arkansas, Lion Oil Company Inc.'s written
emergency
response plan did not address critique of emergency response and follow-up.

Issued

Oct 19, 2009

Abate by

Nov 16, 2009

General-duty citation text

29 CFR 1910.120(q)(2)(xi):  The emergency response plan did not address,
to the extent not
addressed elsewhere, the PPE and emergency equipment:
On or about May 5, 2009, and at times prior thereto and thereafter, at the
facility located
at 1000 McHenry in El Dorado, Arkansas, Lion Oil Company Inc.'s written
emergency
response plan did not address personal protective equipment and emergency
response
equipment.