OSHA Inspection: TESORO HAWAII CORP

Issued

Jan 19, 2011

Abate by

Jan 24, 2011

Penalty

Initial $1,375 · Current $1,375

General-duty citation text

29 CFR 1910.23(e)(1) [Refer to chapter 12-72.1, HAR] was violated because:
A walking/working platform for R-603 reactor tower that was 44 feet above
ground had a
top guard railing height of 34 inches from the platform surface.   A low
top guard railing
height exposed employees to fall hazards with the potential for serious
injuries.
29 CFR 1910.23(e)(1) states "Railing, toe boards, and cover
specifications.  A standard
railing shall consist of top rail, intermediate rail, and posts, and shall
have a vertical height
of 42 inches nominal from upper surface of top rail to floor, platform,
runway, or ramp
level.  The top rail shall be smooth-surfaced throughout the length of the
railing.  The
intermediate rail shall be approximately halfway between the top rail and
the floor, platform,
runway, or ramp.  The ends of the rails shall not overhang the terminal
posts except where
such overhang does not constitute a projection hazard."
Location:  Reactor R-603 of the Distillate Hydrocracker Unit (DHC)

Issued

Jan 19, 2011

Abate by

Jan 24, 2011

Penalty

Initial $1,375 · Current $1,375

Issued

Jan 19, 2011

Abate by

Feb 7, 2011

Penalty

Initial $1,375 · Current $1,375

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D) [Refer to chapter 12-74.11, HAR] was violated
because:
1.The employer's Process Safety Information (P.S.I.) was inaccurate in
that the safe
operating limits for process pumps P602A, P602B, and P602C had differing
minimum
operating limits in the document titled "Tesoro Hawaii Corp.  Safe
Operating Parameters and
Consequences of Deviation" (Document 17-01-02), and the Management of
Change titled
"MOC 2010029-001-DHC:  R2009136 Modify Procedures for Feed Min Flow"
(Document
14-12-02).  Documents that provide conflicting set points may lead to
confusion and the
possibility of Operator error in handling the process and lead to "Sudden
loss of feed could
lead to high furnace outlet temperature and reactor runaway, with
potential catastrophic
explosion hazard."
2.The employer's Process Safety Information was inaccurate in that the
employer
provided several differing temperatures for heat exchangers in the Naphtha
Hydrotreater
Unit.  Document 03-01-01 listed vessel maximum design temperatures that
differed from the
maximum design temperatures listed in the vessel's equipment file.  The
maximum design
temperature for Exchangers E-401A through E-401F differed 40 to 300
degrees Fahrenheit
between Document 03-01-01 and their individual equipment file.  Pressure
vessel shell and
tube temperatures that are not maintained or accurately tracked may hinder
the evaluation of
possible temperature related damage associated with the mechanical
integrity
of the pressure
vessels and can result in catastrophic failure.
3.The employer's Process Safety Information was inaccurate in that the
employer
provided differing pressures for a heat exchanger in the Naphtha
Hydrotreater Unit.  Process
flow and instrumentation diagram (P& I D) drawing A-600-B-049, revision
20, 9/15/09
(Document 03-03-02, Page 001069) indicates a the shell design pressure for
E-632 of 150 psi
which does not concur with the design information from the U-1 form for
E-632
manufactured by Kobe Steel in 1985  (Document 08-01i-01, Page 007149)
which indicates
that the maximum allowable working pressure is 140 psi for the shell.
Pressure vessel shell
pressures that are not maintained or accurately tracked may hinder the
evaluation of possible
temperature related damage associated with the mechanical integrity of the
pressure vessels
and can result in catastrophic failure.
29 CFR 1910.119(d)(2)(i)(D) states "Process safety information.  In
accordance with the
schedule set forth in paragraph (e)(1) of this section, the employer shall
complete a
compilation of written process safety information before conducting any
process hazard
analysis required by the standard.  The compilation of written process
safety information is
to enable the employer and the employees involved in operating the process
to identify and
understand the hazards posed by those processes involving highly hazardous
chemicals.  This
process safety information shall include information pertaining to the
hazards of the highly
hazardous chemicals used or produced by the process, information
pertaining to the
technology of the process, and information pertaining to the equipment in
the process.
Information pertaining to the technology of the process.  (i) Information
concerning the
technology of the process shall include at least the following: (D) Safe
upper and lower limits
for such items as temperatures, pressures, flows or Compositions."
Location:  Establishment

Issued

Jan 19, 2011

Abate by

Feb 7, 2011

General-duty citation text

29 CFR 1910.119(d)(3)(i)(A) [Refer to chapter 12-74.1, HAR] was violated
because:
The U-1 form for the E-401B heat exchanger constructed by Waner
Corporation of Tulsa,
OK in 1974 contained in the Tesoro equipment file does not reflect a
change in the tube
bundle material which occurred since the original heat exchanger was
installed.  Inaccurate
metallurgy can lead to hazards associated with deterioration, corrosion,
and embrittlement
and lead to leakage within the vessel.
29 CFR 1910.119(d)(3)(i)(A) states "Process safety information.  In
accordance with the
schedule set forth in paragraph (e)(1) of this section, the employer shall
complete a
compilation of written process safety information before conducting any
process hazard
analysis required by the standard.  The compilation of written process
safety information is
to enable the employer and the employees involved in operating the process
to
identify and
understand the hazards posed by those processes involving highly hazardous
chemicals.  This
process safety information shall include information pertaining to the
hazards of the highly
hazardous chemicals used or produced by the process, information
pertaining to the
technology of the process, and information pertaining to the equipment in
the process.
Information pertaining to the equipment in the process.  (i) Information
pertaining to the
equipment in the process shall include:  (A) Materials of construction."
Location:  Establishment

Issued

Jan 19, 2011

Abate by

Feb 7, 2011

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B) [Refer to chapter 12-74.11, HAR] was violated
because:
Piping Instrument & Diagrams (P&IDs) A-400-B-003 and A-600-A-1025 for the
Naphtha
Hydrotreater Unit and the Distillate Hydrocracker Unit did not mirror
field conditions.
The following conditions were found where the P&IDs differed from the
field conditions:
1.Temperature Indicator (TI-422 off of D-402) on P&ID A-400-B-003 was not
found in
the field;
2.Spectacle Blinds (off of D-602 bottoms) on P&ID A-600-A-1025 were not
found in
the field at the locations indicated on the PI & D;
3.A valve on a line from D-623 to D-604 (6"-P60681-AD2) was found not to
be car
sealed open, where P&ID A-600-A-1025 states that the valve is car sealed
open;
4. An extra three inch gate valve downstream of PSV-425 was found in the
field but not
indicated on PI &D A-400-B-003.
5.P&ID A-400-B-003 had a note that PSV-423 was reset to 242 PSIG that was
not
reflected on PSV-423's tag in the field.
6.A Chloride Injection line indicated on the PI & D A-400-B-002 was
previously noted
to be disconnected in the field according to a Process Hazard Analysis
conducted in 2009,
however was not shown as disconnected on the PI &D provided.
P&IDs that do not mirror field conditions can lead to process upsets and
deviations during
normal operations, and confusion and delay during emergency operations,
and may result in
catastrophe if a process upset cannot be brought under control.
29 CFR 1910.119(d)(3)(i)(B) states "Process safety information.  In
accordance with the
schedule set forth in paragraph (e)(1) of this section, the employer shall
complete a
compilation of written process safety information before conducting any
process hazard
analysis required by the standard.  The compilation of written process
safety information is
to enable the employer and the employees involved in operating the process
to identify and
understand the hazards posed by those processes involving highly hazardous
chemicals.  This
process safety information shall include information pertaining to the
hazards of the highly
hazardous chemicals used or produced by the process, information
pertaining to the
technology of the process, and information pertaining to the equipment in
the
process.
Information pertaining to the equipment in the process.  (i) Information
pertaining to the
equipment in the process shall include:  (B) Piping and instrument
diagrams (P&ID's)."
Location:  Distillate Hydrocracker and Naphtha Hydrotreater Units.  (Refer
to A-400-B-003,
A-600-A-1025, and A-400-B-002)

Issued

Jan 19, 2011

Abate by

Jan 24, 2011

Penalty

Initial $1,375

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D) [Refer to chapter 12-74.1-1, HAR] was violated
because:
The employer did not comply with RAGAGEP when it failed to provide
adequate controls to
ensure that intervening valves on the upstream lines to relief devices
PSV-H113 and PSV-
H125 remained in the open position during operation when a pressure vessel
was the possible
source of a relieving event (ASME Boiler and Pressure Vessel Code,
Division 1 (BPVC),
Section VIII, UG-135(d) and Appendix M are examples of RAGAGEP for
controlling
intervening stop valves on relief lines.  A closed intervening valve
upstream or downstream
of a pressure relief device during a process upset could lead to
catastrophic failure of the
vessel.
29 CFR 1910.119(d)(3)(i)(D) states "Process safety information.  In
accordance with the
schedule set forth in paragraph (e)(1) of this section, the employer shall
complete a
compilation of written process safety information before conducting any
process hazard
analysis required by the standard.  The compilation of written process
safety information is
to enable the employer and the employees involved in operating the process
to identify and
understand the hazards posed by those processes involving highly hazardous
chemicals.  This
process safety information shall include information pertaining to the
hazards of the highly
hazardous chemicals used or produced by the process, information
pertaining to the
technology of the process, and information pertaining to the equipment in
the process.
Information pertaining to the equipment in the process shall include:  (F)
Design codes and
standards employed."
Location:  Catalytic Reformer Unit and Distillate Hydrocracker Unit

Issued

Jan 19, 2011

Abate by

Feb 7, 2011

Penalty

Initial $1,375 · Current $1,375

General-duty citation text

29 CFR 1910.119(d)(3)(ii) [Refer to chapter 12-74.1, HAR] was violated
because:
The employer did not comply with RAGAGEP when it failed to protect
employees inside
inadequately protected main control room structure that could be exposed
to toxic material as
a result of a toxic release from process equipment.  RAGAGEP for facility
siting include,
but are not limited to, CCPS [Ref. 38 and 39], API 752, and AIChE/Dow Fire
and
Explosion Index.  An inadequately protected structure exposes employees to
toxic material
hazards with the potential for serious injuries.
29 CFR 1910.119(d)(3)(ii) states "The employer shall document that
equipment complies
with recognized and generally accepted good engineering practices."
Location:  Main Control Room

Issued

Jan 19, 2011

Abate by

Jan 24, 2011

Penalty

Initial $1,375

General-duty citation text

29 CFR 1910.119(e)(5) [Refer to chapter 12-74.1-1, HAR] was violated
because:
The employer failed to assure that the recommendations were resolved in
that R2009114-016
stated that a PHA item with a risk rank of 3 and rejected by management is
acceptable.  All
other recommendations that were rejected included language under the
justification for why
the recommendations were rejected.  Additionally, R2008001-001,
R2008001-002 and
R2008001-004 with recommendations that were not approved did not list the
justification.
29 CFR 1910.119(e)(5) states "The employer shall establish a system to
promptly address the
team's findings and recommendations; assure that the recommendations are
resolved in a
timely manner and that the resolution is documented; document what actions
are to be taken;
complete actions as soon as possible; develop a written schedule of when
these actions are to
be completed; communicate the actions to operating, maintenance and other
employees whose
work assignments are in the process and who may be affected by the
recommendations
or
actions."
Location:  Establishment

Issued

Jan 19, 2011

Abate by

Jan 24, 2011

Penalty

Initial $1,375 · Current $1,375

General-duty citation text

29 CFR 1910.119(f)(4) [Refer to chapter 12-74.1, HAR] was violated because:
The employer did not implement its safe work practice for motorized
equipment and other
equipment with sources of ignition when used within operating units that
contain flammable
or combustible materials.  A diesel mobile crane, Super Heat F6H
equipment, and
Whisperwatt Diesel Powered AC Generator were not listed on hot work
permits for hot work
being conducted at the Distillate Hydrocracker Unit (DHC).   Failure to
list equipment with
sources of ignition on hot work permits exposed employees to fire hazards
with the potential
for serious injuries.
29 CFR 1910.119(f)(4) states "The employer shall develop and implement
safe work
practices 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.  These safe work
practices shall apply to employees and contractor employees."
Location:  Distillate Hydrocracker Unit (DHC)

Issued

Jan 19, 2011

Abate by

Jan 24, 2011

Penalty

Initial $1,375 · Current $1,375

General-duty citation text

29 CFR 1910.120(q)(3)(v) [Refer to chapter 12-74.1, HAR] was violated
because:
The buddy system was not specifically listed as a component of the
employer's written
Emergency Response Plan and the employer failed to provide any information
on the manner
in which this would be performed by the Emergency Response Team in the
event of chemical
release, fire or other emergencies.  The lack of a buddy system puts
individual Emergency
Response Team personnel at risk should they enter a unit alone, become
overwhelmed, and
need assistance or rescue.
29 CFR 1910.120(q)(3)(v) states "The individual in charge of the ICS shall
limit the number
of emergency response personnel at the emergency site, in those areas of
potential or actual
exposure to incident or site hazards, to those who are actively performing
emergency
operations.  However, operations in hazardous areas shall be performed
using the buddy
system in groups of two or more."
Location:  Establishment

Issued

Jan 19, 2011

Abate by

Jan 24, 2011

General-duty citation text

29 CFR 1910.120(q)(3)(vi) [Refer to chapter 12-74.1, HAR] was violated
because:
The provision for back up personnel was not included in the employer's
Emergency
Response Plan and the employer  failed to provide information on the
manner in which this
would be performed by employees in the event of chemical release, fire, or
other
emergency.
The lack of back up personnel puts Emergency Response Team personnel at
risk should they
enter a unit, become overwhelmed, and need assistance or rescue.
29 CFR 1910.120(q)(3)(vi) states "Back-up personnel shall stand by with
equipment ready to
provide assistance or rescue.  Advance first aid support personnel, as a
minimum, shall also
stand by with medical equipment and transportation capability."
Location:  Establishment

Issued

Jan 19, 2011

Abate by

Jan 24, 2011

Penalty

Initial $1,375 · Current $1,375

General-duty citation text

29 CFR 1910.134(h)(3)(i)(B) [Refer to chapter 12-64.1, HAR] was violated
because:
Self Contained Breathing Apparatuses (SCBAs) used by the Emergency
Response Team and
Fire Brigade were not being inspected at least monthly.  Use of a
malfunctional SCBA in an
emergency situation can expose the user to an oxygen deficient and toxic
environment,
leading to asphyxiation.
29 CFR 1910.134(h)(3)(i)(B) states "The employer shall ensure that
respirators are inspected
as follows:  (B) All respirators maintained for use in emergency
situations shall be inspected
at least monthly and in accordance with the manufacturer's
recommendations, and shall be
checked for proper function before and after each use."
Location:  Establishment

Issued

Jan 19, 2011

Abate by

Jan 24, 2011

General-duty citation text

29 CFR 1910.134(h)(3)(iii) [Refer to chapter 12-64.1, HAR] was violated
because:
Self Contained Breathing Apparatuses (SCBAs) used by the Emergency
Response Team and
Fire Brigade were not being inspected at least monthly.  Use of a
malfunctional SCBA in an
emergency situation can expose the user to an oxygen deficient and toxic
environment,
leading to asphyxiation.
29 CFR 1910.134(h)(3)(iii) states "In addition to the requirements of
paragraphs (h)(3)(i) and
(ii) of this section, self-contained breathing apparatus shall be
inspected
monthly.  Air and
oxygen cylinders shall be maintained in a fully charged state and shall be
recharged when the
pressure falls to 90of the manufacturer's recommended pressure level.
The employer
shall determine that the regulator and warning devices function properly."
Location:  Establishment