OSHA Inspection: SINCLAIR WYOMING REFINING COMPANY

Issued

2012-09-13 00:00:00

Abate by

2012-12-31 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

1910.119(e)(3)(iii)*  Process hazard analysis. 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. (Acceptable detection methods might include process monitoring
and control
instrumentation with alarms, and detection hardware such as hydrocarbon
sensors.):
Process hazard analysis that were previously conducted did not address
engineering and
administrative controls associated with problems with pump 8P-145 in LPG
area in the Alky
Unit that vented to atmosphere and controlling LEL.

Issued

2012-09-13 00:00:00

Abate by

2012-10-09 00:00:00

General-duty citation text

1910.119(e)(3)(vi)*  Process hazard analysis. The process hazard analysis
shall address:
Human factors:
Prior process hazard analysis's that were conducted did not address human
factors
associated
with pump 8P-145 venting to atmosphere in worker area.  Employer did not
ensure
employees had an adequate amount of time needed or protection to complete
all steps
associated with trying to vent pump to atmosphere (get adequate suction
for pump 8P-145).

Issued

2012-09-13 00:00:00

Abate by

2012-09-18 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

1910.119(f)(1)(iii)(B)*  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.  Safety and health
considerations:  Precautions
necessary to prevent exposure, including engineering controls,
administrative controls, and
personal protective equipment:
The employer did not develop and implement written operating procedures
that provide clear
instructions for safely conducting activities associated with safety and
health considerations
(precautions necessary to prevent exposure, including engineering
controls, administrative
controls, and personal protective equipment) when venting pump to
atmosphere.  The
employer had not developed an operating procedure to specifically address
the hazards with
pump (bullet pump 8P-145) that placed employees at risk when pumping when
trying to get
suction.

Issued

2012-09-13 00:00:00

Abate by

2012-12-31 00:00:00

Penalty

Initial $4250.00 · Current $4250.00

General-duty citation text

1910.119(f)(4)*  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:
The employer developed, but failed to properly implement hot work
procedures/safe work
practices.  Attendants were not maintaining an accurate count of
authorized entrants (Not all
entrants were signing out on permits and attendant did not sign entrants
out once work
complete and entrants  no longer in permitted confined spaces.
Ancillary Reference:  1910.146(i)(3)*  Duties of attendants. The employer
shall ensure that
each attendant:  Continuously maintains an accurate count of authorized
entrants in the
permit space and ensures that the means used to identify authorized
entrants under paragraph
(f)(4) of this section accurately identifies who is in the permit space:

Issued

2012-09-13 00:00:00

Abate by

2012-09-18 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

1910.119(g)(1)(i)*  Training. Initial training. Each employee presently
involved in operating
a process, and each employee before being involved in operating a newly
assigned process,
shall be trained in an overview of the process and in the operating
procedures as specified in
paragraph (f) of this section. The training shall include emphasis on the
specific safety and
health hazards, emergency operations including shutdown, and safe work
practices
applicable
to the employee's job tasks:
Employees involved in running pump (bullet pump  8P-145) had not been
trained in
procedures to protect themselves from venting pump to atmosphere (nor had
employer
developed operating procedure for this task) that addressed the specific
safety and health
hazards associated with venting pump to atmosphere.

Issued

2012-09-13 00:00:00

Abate by

2012-09-18 00:00:00

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 did not ascertain that each employee involved in venting pump
8P-145 had
received proper training.  The employer had not prepared a record which
contained the
identity of the employees, the date of training, and the means used to
verify
that the
employees understood the training or that training conducted was adequate
for task associated
with pump 8P-145.

Issued

2012-09-13 00:00:00

Abate by

2012-10-09 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

1910.119(j)(4)(ii)*  Inspection and testing.  Inspection and testing
procedures shall follow
recognized and generally accepted good engineering practices:
LPG Bullet pressure vessels not being inspected following recognized and
generally accepted
good engineering practices identified in API Standard 653.  Tanks/vessels
were not being
inspected within 10 years of initial placement into service.
Ancillary Reference:  API Standard 653, 4th Edition, April 2009. 6.1
General -  Periodic in-
service inspection of tanks shall be performed as defined herein.  The
purpose of this
inspection is to assure continued tank integrity.  6.4.4.4 Internal
inspection is primarily
required to do as follows.  c) Identify and evaluate any tank bottom
settlement.  6.4.2.1 The
interval from initial service until the initial internal inspection shall
not
exceed 10 years.

Issued

2012-09-13 00:00:00

Abate by

2012-09-18 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

1910.119(j)(5)*  Mechanical integrity. 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:
The employer did not correct pump deficiencies identified by engineering
when an
engineering work flow process was conducted to redesign and engineer pump
and no interim
controls established to protect employees when venting LPG pump (8P-145)
in Alky Unit that
was outside of the acceptable limits with current procedures.  Employees
vented pump to
atmosphere due to lack of suction and employer was aware of past issues
with pump and
failed to take appropriate action to prevent the incident that occurred on
May 25, 2012.

Issued

2012-09-13 00:00:00

Abate by

2012-09-18 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

1910.119(l)(1)*  Management of change.  The employer shall establish and
implement
written procedures to manage changes (except for "replacements in kind")
to process
chemicals, technology, equipment, and procedures; and, changes to
facilities that affect a
covered process:
The employer failed to complete MOC's before making changes to processes
or equipment
(2011 Emergency Eyewash Stations and Safety Showers Procedures updated
(changed
monthly inspections to weekly), a new type of emergency eye wash/shower
stations were
being installed, & block valves were installed near level bridle in Alky
Unit associated with
installation of temporary Sour Water System) that affected the covered
processes in the Alky
Unit.

Issued

2012-09-13 00:00:00

Abate by

2012-12-31 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

1910.151(b)*  In the absence of an infirmary, clinic, or hospital in near
proximity
to the
workplace which is used for the treatment of all injured employees, a
person or persons shall
be adequately trained to render first aid. Adequate first aid supplies
shall be readily
available:
1.  Adequate first aid supplies were not available (burn cream).
Employees were burned in a
flash fire and required burn cream and supply had been previously depleted
from the
previous catastrophe and not restocked.  No management took appropriate
steps to restock
supply burn cream or ensure others restocked after previous incident.
2.  No emergency care was available/within in the critical minutes (3 - 4
minutes from the
workplace where employees were flashed/burned) between the occurrence of
the flash fire
and the availability of person adequately trained to render first aid,
physician(s), or hospital
care for the injured employees.s),

Issued

2012-09-13 00:00:00

Abate by

2012-10-09 00:00:00

Penalty

Initial $7000.00

General-duty citation text

1910.151(c)*  Where the eyes or body of any person may be exposed to
injurious corrosive
materials, suitable facilities for quick drenching or flushing of the eyes
and body shall be
provided within the work area for immediate emergency use:
Suitable facilities for quick drenching or flushing of the eyes and body
were
not always
available or provided in the Alky Unit for immediate emergency use:
1.  Employees eyes that could be exposed to injurious corrosive materials
could not access
suitable portable eye wash units for quick drenching or flushing of the
eyes due to steam
spraying in the direction of emergency portable eye station at the KOH.
2.  Emergency shower was not immediately available in LPG Storage Area
(not functioning)
for use after a fire incident or when working around caustics in LPG (KOH
area) in Alky
unit.  Employees were unable to use the closest emergency shower after
being sprayed with
LPG product that ignited and flashed/burned employees.  Closest emergency
shower unit was
at the other end of LPG Storage Area (employees would be more than 10
seconds from
emergency unit and would have to cross through LPG to reach working
emergency shower.
3.  Portable emergency eye wash unit was not being inspected weekly
(inadvertently
omitted
per safety department).
Ancillary Reference: American National Standards Institute (ANSI)
Z358.1-1998, Emergency
showers shall be in accessible locations that require no more than 10
seconds to reach and
should be within a travel distance no greater than 30.5 meters (100 feet)
from the hazard.
Emergency Eyewash and Shower Equipment, which states, at section 7.4.4,
that eyewash
facilities are to be located to require no more than 10 seconds to reach
but that where a
strong acid or caustic is used, the unit should be immediately adjacent to
the hazard.

Issued

2012-09-13 00:00:00

Abate by

2012-10-09 00:00:00

General-duty citation text

1910.157(c)(4)*  The employer shall assure that portable fire
extinguishers are maintained in
a fully charged and operable condition and kept in their designated places
at all times except
during use:
Fire extinguisher had been discharged after an incident and not
immediately
replaced,
removed from site, or tagged.