OSHA Inspection: SINCLAIR CASPER REFINING COMPANY

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

Penalty

Initial $1875.00 · Current $1055.00 Reduced

General-duty citation text

1910.119(d)(3)(i)(D)*  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. Information pertaining to the equipment in the
process shall
include:  Relief system design and design basis:
1.  The employer did not have the design/design basis process safety
information
prior to
October 7, 2010 for PSV74-804.
2.  The employer did not have the original design basis or relocation
design information for
the atmospheric blowdown drum.

Issued

2011-01-05 00:00:00

Abate by

2011-01-31 00:00:00

General-duty citation text

1910.119(d)(3)(ii)*  The employer shall document that equipment complies
with recognized
and generally accepted good engineering practices:
The employer did not comply with RAGAGEP (CCPS, API 752, & AIChE/Dow Fire
and
Explosion Index) when it still had employees working in control room and
maintenance
facilities that were inside the hazard zone and were not adequately
protected while inside
structures in the event of a hazardous release/explosion.

Issued

2011-01-05 00:00:00

Abate by

2011-01-31 00:00:00

Penalty

Initial $4500.00 · Current $2531.00 Reduced

General-duty citation text

1910.119(e)(3)(i)*  Process hazard analysis. The employer shall perform an
initial process
hazard analysis (hazard evaluation) on processes covered by this standard.
The process
hazard analysis shall be appropriate to the complexity of the process and
shall
identify,
evaluate, and control the hazards involved in the process. Employers shall
determine and
document the priority order for conducting process hazard analyses based
on a rationale
which includes such considerations as extent of the process hazards,
number of potentially
affected employees, age of the process, and operating history of the
process. The process
hazard analysis shall address:  The hazards of the process:
Previous process hazard analysis conducted on atmospheric relief devices
did not address
hazardous materials/HHC being vented to atmosphere or
safeguards/engineering controls
associated with venting to safe locations.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.119(e)(3)(iii)*  The process hazard analysis shall address:
Engineering and
administrative controls applicable to the hazards and their
interrelationships such as
appropriate application of detection methodologies to provide early
warning of releases:
The employer's process hazard analyses for the refinery including, but not
limited to the
previous PHA's for the #5 Crude Unit did not identify the specific
engineering and
administrative controls applicable to the lighting of H-501.  Employees
were exposed to the
process related hazards associated with the fire and explosion that
occurred on May 25,
2010, due to the lack of specific identification of engineering and
administrative controls and
their interrelationships associated with the lighting procedures of heater
H-501 after a
turnaround.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.119(e)(3)(iv)*  The process hazard analysis shall address:
Consequences of failure of
engineering and administrative controls:
The employer's process hazard analyses for the refinery including, but not
limited to the
previous PHA's for the #5 Crude Unit did not identify the consequences of
failure of
engineering and administrative controls applicable to the lighting of
H-501.  Employees were
exposed to the process related hazards associated with the fire and
explosion that occurred on
May 25, 2010, due to the lack of specific consequences of failure of
engineering and
administrative controls and their interrelationships associated with the
lighting procedures of
heater H-501 after a turnaround.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.119(e)(3)(vi)*  The process hazard analysis shall address: Human
factors:
The past process hazard analysis associated with human factors did
not/adequately address
safety features or shutdown of HVAC system for controlling building
environment during a
release of hazardous materials.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.119(e)(3)(vii)*  The process hazard analysis shall address:  A
qualitative evaluation of a
range of the possible safety and health effects of failure of controls on
employees in the
workplace:
The employer's process hazard analyses for the refinery including, but not
limited to the
previous PHA's for the #5 Crude Unit did not identify a qualitative
evaluation of a range of
the possible safety and health effects of failure of controls on employees
in the workplace
applicable to the lighting of H-501.  Employees were exposed to the
process related hazards
associated with the fire and explosion that occurred on May 25, 2010, due
to the lack of
specific qualitative evaluation of a range of the possible safety and
health effects of failure of
controls on employees in the workplace and their interrelationships
associated with the
lighting procedures of heater H-501 after a turnaround.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

Penalty

Initial $1875.00 · Current $1054.00 Reduced

General-duty citation text

1910.119(e)(5)*  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:
Not all findings and recommendations from FCC Unit PHA Revalidation Study
from June
2006 complete and not all Compliance Audits from FCC Unit from October
2007 completed
in a timely manner. Issues with adequate signage/labeling and employee
alarm systems had
not been addressed.  Employer had no formal mechanism in place to track
work orders
associated with PSM processes/issues.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

Penalty

Initial $4500.00 · Current $2531.00 Reduced

General-duty citation text

1910.119(f)(1)(i)(D)*   Operating procedures.  The employer shall develop
and implement
written operating procedures that provide clear instructions for safely
conducting activities
involved in each covered process consistent with the process safety
information and shall
address at least the following elements. Steps for each operating phase:
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 is executed in a safe and timely manner:
Not all operating procedures for the FCC Unit (NOP, ESP, Start-Up, & SOP)
allowed
qualified operators to conduct an emergency shutdown procedure.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.119(f)(1)(i)(E)*  Operating procedures.  The employer shall develop
and implement
written operating procedures that provide clear instructions for safely
conducting activities
involved in each covered process consistent with the process safety
information and shall
address at least the following elements.  Steps for each operating phase;
Emergency
Operations:
The FCC Unit "Emergency Operating Procedures" (EOP) FCC-OP-1100, revised
02/07 did
not address consequences of deviation from the EOP or operating limits.ng

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.119(f)(1)(i)(G)*  Operating procedures. The employer shall develop
and
implement
written operating procedures that provide clear instructions for safely
conducting activities
involved in each covered process consistent with the process safety
information and shall
address at least the following elements. Steps for each operating phase:
Startup following a
turnaround, or after an emergency shutdown:
The employer did not develop and implement adequate written operating
procedures that
provided clear instructions for safely conducting activities involved in
the lighting of H-501
located at the #5 Crude Unit.  Employees were exposed to the process
related hazards
associated with the fire and explosion that occurred on May 25, 2010, due
to the lack of
clear/adequate operating procedures associated with the lighting
procedures of heater H-501
after a turnaround.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

Penalty

Initial $1875.00 · Current $1055.00 Reduced

General-duty citation text

1910.119(g)(3)*  Training documentation. The employer shall ascertain that
each employee
involved in operating a process has received and understood the training
required by this
paragraph. The employer shall prepare a record which contains the identity
of the employee,
the date of training, and the means used to verify that the employee
understood the training:
The employer management representative was not documenting how he verified
operator
knowledge/training associated with on the job training or that the
employees always
understood their classroom training or the subject matter of the
incorrectly answered test
questions.

Issued

2011-01-05 00:00:00

Abate by

2011-01-31 00:00:00

Penalty

Initial $1875.00 · Current $1054.00 Reduced

General-duty citation text

1910.119(j)(2)*  Mechanical integrity.  Written procedures. The employer
shall establish and
implement written procedures to maintain the on-going integrity of process
equipment:
1.  Mechanical integrity procedures had not been developed for
safety/safety critical
instrumentation; employees were using manufacturer's/owner's manuals to
rely upon repair
and maintenance procedures/information for instrumentation.
2.  Mechanical integrity program did not address anomalous data.
3.  Mechanical integrity program for "Inspection & Testing Procedures" for
repair
procedures associated with pressure vessels did not properly address
repair/alteration
procedures associated with repair/maintenance personnel.
4.  Mechanical integrity program for "Inspection & Testing Procedures" did
not include/list
specific requirements for welders' qualifications for welding process
piping or when qualified
welding procedures were required.
5.  Prior to 2009 the mechanical integrity procedure for inspecting piping
was not complete
IAW RAGAGEP (API 570).

Issued

2011-01-05 00:00:00

Abate by

2011-01-31 00:00:00

Penalty

Initial $1875.00 · Current $1055.00 Reduced

General-duty citation text

1910.119(j)(3)*  Training for process maintenance activities. The employer
shall train each
employee involved in maintaining the on-going integrity of process
equipment in an overview
of that process and its hazards and in the procedures applicable to the
employee's job tasks to
assure that the employee can perform the job tasks in a safe manner:
Employees had not received adequate training on procedures for testing,
calibration, and
preventative maintenance of safety instrumentation (fixed H2S alarms, flow
alarms,
temperature alarms, auxiliary burner flame out, flame detectors, level
alarms, shutdown
alarms, and/or control valves), since mechanical integrity procedures had
not been completed
so employees could be trained on all procedures/requirements associated
with safety
instrumentation.

Issued

2011-01-05 00:00:00

Abate by

2011-01-31 00:00:00

Penalty

Initial $4500.00 · Current $2531.00 Reduced

General-duty citation text

1910.119(j)(4)(i)*  Mechanical integrity.  Inspection and testing.
Inspections and tests shall
be performed on process equipment:
1.  H2S monitors were not being inspected and tested on a regular
scheduled basis.  Lasted
documented testing/inspections on area H2S monitors was November 1, 2005.
2.  Flow alarms, temperature alarms, flame detectors, auxiliary burners,
level alarms,
shutdown alarms, & control valve alarms were not being tested and/or
calibrated.
Instrumentation was only being tested and/or calibrated when there was a
malfunction.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.119(j)(4)(ii)*   Mechanical integrity. Inspection and testing.
Inspection and testing
procedures shall follow recognized and generally accepted good engineering
practices:
1.  During exchanger inspection and testing for CE403 (Depropanizer
Reboiler), employer
did not follow RAGAGEP (API 510) or Mechanical Integrity Program
"Inspection & Testing
Procedures", regarding inspection location points.
2.  Welding program/procedures were not complete to address RAGAGEP
associated with
Center for Chemical Process Safety (Mechanical Integrity) and AWS
regarding quality
assurance and qualifications of maintenance personnel associated with
welding.
3.  During repair work on Depropanizer Reboiler Condensate Knockout Pot
RAGAGEP was
not followed associated with hydrostatic testing prior to installation/use
after repairs were
made.
4.  Prior to 2009 retirement thickness and previous repairs & replacement
documentation was
not properly collected/maintained (2P544-6 - BC 1978).

Issued

2011-01-05 00:00:00

Abate by

2011-01-31 00:00:00

General-duty citation text

1910.119(j)(4)(iii)*   Mechanical integrity.  Inspection and testing. The
frequency of
inspections and tests of process equipment shall be consistent with
applicable manufacturers'
recommendations and good engineering practices, and more frequently if
determined to be
necessary by prior operating experience:
Manufacturer's recommendations and generally accepted good engineering
practices were not
being followed:
1.  Personal H2S monitors were not being inspected and tested (calibrated)
at least to
manufacturer's recommendations.  Manufacturer's testing frequency is at
least every thirty
(30) days to ensure monitor integrity.  Of the eleven (11) employees
monitor calibration
records checked there were twenty-eight (28) instances of monitors not
being bump-
tested/calibrated within thirty (30) days.
2.  Not all pressure vessels were being inspected in required five year
intervals (overdue) by
RAGAGEP API 510 and Mechanical Integrity Program, "Inspection & Testing
Procedures"
for CT-264, E-217, CE-260, & CT-192.
3.  Not all piping inspections were complete in accordance with RAGAGEP
API 570, prior
to 2009 information was typically chalked on pipe and/or was not available
(2P544-6 - BC &
252MPA-002).

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

Penalty

Initial $1875.00 · Current $1055.00 Reduced

General-duty citation text

1910.119(j)(5)*   Mechanical integrity.  Inspection and testing. Equipment
deficiencies. The
employer shall correct deficiencies in equipment that are outside
acceptable limits (defined by
the process safety information in paragraph (d) of this section) before
further use or in a safe
and timely manner when necessary means are taken to assure safe operation:
1.  The employer did not ensure that area H2S monitors were being
inspected and tested on a
regular scheduled basis to correct deficiencies in equipment (alarms) that
were outside
acceptable limits (bad sensors, loose wiring, replace monitor). The last
documented
testing/inspections on area H2S monitors to ensure equipment operating
within acceptable
limits was November 1, 2005.
2.  Employer was not able to validate/track that equipment deficiencies
were being corrected
in a timely manner.  Work orders were hand written and not under a
tracking system to
ensure that equipment deficiencies were fixed in a timely manner to ensure
safe operation of
the FCC Unit.  Work orders would be completed and not documented and/or
marked
fix
today/ASAP and not fixed for over a week or longer.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

Penalty

Initial $1125.00 · Current $845.00 Reduced

General-duty citation text

1910.119(l)(2)(ii)*   Management of change.  The procedures shall assure
that the following
considerations are addressed prior to any change:  Impact of change on
safety and health:
Two Management of Change's (MOC) for 1995 & 2008 did not address impact of
change on
safety and health.  MOC's 1995-01 (Unit 252) & 2008-38 (Unit 252).

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.119(l)(3)*  Management of change.  Employees involved in operating a
process and
maintenance and contract employees whose job tasks will be affected by a
change in the
process shall be informed of, and trained in, the change prior to start-up
of the process or
affected part of the process:
No maintenance personnel  were involved/informed in management of change
2008-38 of
FFC Unit FCV-250 replacement on unit # 252 and no operators or maintenance
personel
were involved in management of change 1995-001 of FCC Unit Clemtex
Additive Injection
System of Desox whose job tasks could have been affected by the changes.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.119(l)(4)*   Management of change.  If a change covered by this
paragraph results in a
change in the process safety information required by paragraph (d) of this
section, such
information shall be updated accordingly:
Nothing identified in either management of change for 2008-38 of FCC Unit
FCV-250
replacement on unit # 252 and 1995-001 of FCC Unit Clemtex Additive
Injection System of
Desox resulted in a change in the process safety information required by
1910.119(d).

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.119(l)(5)*  Management of change.  If a change covered by this
paragraph results in a
change in the operating procedures or practices required by paragraph (f)
of this section,
such procedures or practices shall be updated accordingly:
Nothing identified in either management of change for 2008-38 of FCC Unit
FCV-250
replacement on unit # 252 and 1995-001 of FCC Unit Clemtex Additive
Injection System of
Desox resulted in a change in the operating procedures or practices
required by 1910.119(f).

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

Penalty

Initial $1125.00 · Current $844.00 Reduced

General-duty citation text

1910.134(h)(2)(i)*  Storage. The employer shall ensure that respirators
are stored as follows:
All respirators shall be stored to protect them from damage,
contamination, dust, sunlight,
extreme temperatures, excessive moisture, and damaging chemicals, and they
shall be packed
or stored to prevent deformation of the facepiece and exhalation valve:
Two respirators were not being stored to protect them from damage,
contamination, or dust.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

Penalty

Initial $1875.00 · Current $1054.00 Reduced

General-duty citation text

1910.212(a)(1)*  Types of guarding. One or more methods of machine
guarding shall be
provided to protect the operator and other employees in the machine area
from hazards such
as those created by point of operation, ingoing nip points, rotating
parts,
flying chips and
sparks:
Employees not protected from rotating shafts on pumps in the FCC Unit.

Issued

2011-01-05 00:00:00

Abate by

2011-01-31 00:00:00

General-duty citation text

1910.39(c)(5)* Minimum elements of a fire prevention plan. A fire
prevention plan must
include: The name or job title of employees responsible for the control of
fuel source
hazards:
The employers' fire prevention plan did not list the name(s) or job titles
of employees
responsible for the control of fuel source hazards within the facility.le

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.132(d)(1)(ii)* The employer shall assess the workplace to determine
if hazards are
present, or are likely to be present, which necessitate the use of
personal protective
equipment (PPE). If such hazards are present, or likely to be present, the
employer shall:
Communicate selection decisions to each affected employee:
The employer did not ensure the personal protective equipment selection
decision was
effectively communicated to each affected employee in the employers
assessment.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.132(d)(2)* The employer shall verify that the required workplace
hazard assessment has
been performed through a written certification that identifies the
workplace evaluated; the
person certifying that the evaluation has been performed; the date(s) of
the hazard
assessment; and, which identifies the document as a certification of
hazard assessment:
Employer's personal protective equipment training did not identify that
the training was a
certification of training.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.132(f)(4)* Training. The employer shall verify that each affected
employee has received
and understood the required training through a written certification that
contains the name of
each employee trained, the date(s) of training, and that identifies the
subject of the
certification:
The employer did not identify that the training documented with employees
was
the
company's written certification of training.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.1030(f)(1)(ii)(D)* The employer shall ensure that all medical
evaluations and
procedures including the hepatitis B vaccine and vaccination series and
post-exposure
evaluation and follow-up, including prophylaxis, are:  Provided according
to
recommendations of the U.S. Public Health Service current at the time
these evaluations and
procedures take place, except as specified by this paragraph (f):
One employee had not completed his Hepatitis B series and tracking had
failed to ensure
completion of the series.
Ancillary reference: The U.S. Public Health Service (USPHS) provides for
some flexibility
in scheduling. If the series is interrupted after the first dose, the
second dose must be
administered as soon as possible, and the second and third doses must be
separated
by an
interval of at least 8 weeks. If only the third dose has been delayed, it
must be administered
as soon as possible. This permits a certain flexibility, and there should
be little or no added
financial burden on a reasonably diligent employer if an employee misses a
date for a shot.
The employer would simply reschedule the missed shot as soon as possible.
You must also
have your employee tested for antibody to Hepatitis B surface antigen, one
to two months
after the completion of the three-dose vaccination series.
Post-vaccination testing must be
completed 1-2 months after the third vaccine dose for results to be
meaningful. A protective
antibody response is an anti-HBs concentration of 10 or more
milliInternational Units per
milliliter (?10mIU/mL). Employees who do not respond to the primary
vaccination series
must be revaccinated with a second three-dose vaccine series and retested,
unless they are
HbsAg-positive (infected).

Issued

2011-01-05 00:00:00

Abate by

2011-01-31 00:00:00

General-duty citation text

1910.1030(g)(2)(iv)* Annual training for all employees shall be provided
within one year of
their previous training:
Not all employees had received annual bloodborne pathogens training within
the previous
year.

Issued

2011-01-05 00:00:00

Abate by

2011-01-31 00:00:00

General-duty citation text

1910.1030(g)(2)(vii)(F)* The training program shall contain at a minimum
the following
elements: An explanation of the use and limitations of methods that will
prevent or reduce
exposure including appropriate engineering controls, work practices, and
personal protective
equipment:
Employees did not know of the appropriate work practices associated with
spill kit locations
associated with the clean-up of bloodborne pathogens within the refinery.

Issued

2011-01-05 00:00:00

Abate by

2011-01-31 00:00:00

General-duty citation text

1910.1030(g)(2)(vii)(G)* The training program shall contain at a minimum
the following
elements: Information on the types, proper use, location, removal,
handling, decontamination
and disposal of personal protective equipment:
Employees did not know the proper procedures for disposal of biological
(blood)
contaminated personal protective equipment.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.1030(h)(2)(i)(C)* Training records shall include the following
information:
The names and qualifications of persons conducting the training:
The employers annual bloodborne pathogens training did not include the
qualifications of the
person conducting the training.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.1030(h)(2)(i)(D)* Training records shall include the following
information:
The names and job titles of all persons attending the training sessions:
The employers bloodborne pathogens training documentation did not include
the job titles of
all persons attending the training.

Issued

2011-01-05 00:00:00

Abate by

2011-01-10 00:00:00

General-duty citation text

1910.1200(f)(5)(i)*  Except as provided in paragraphs (f)(6) and (f)(7) of
this section, the
employer shall ensure that each container of hazardous chemicals in the
workplace is labeled,
tagged or marked with the following information:  Identity of the
hazardous chemical(s)
contained therein:
Two chemical containers in the control room were not labeled with identity
of the hazardous
products within each container.