BATON ROUGE, LA — 2011-03-14 00:00:00

OSHA Inspection: EXXONMOBIL REFINING & SUPPLY COMPANY

Planned inspection · Safety discipline

At a glance

On 2011-03-14 00:00:00, OSHA opened a planned safety inspection of EXXONMOBIL REFINING & SUPPLY COMPANY in 4045 SCENIC HIGHWAY, BATON ROUGE, LA 70805 (NAICS 324110). OSHA activity number 314769704.

What this inspection record means

OSHA opens inspections for many reasons — routine scheduling under a national or local emphasis program, an employee complaint or referral, or a follow-up after a reported injury. Opening or conducting an inspection is not itself an allegation or a finding that this employer broke any rule; any findings appear as the citations listed below, and citations can be contested, reduced, or withdrawn.

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Where did this inspection happen?

Establishment: EXXONMOBIL REFINING & SUPPLY COMPANY
Site address: 4045 SCENIC HIGHWAY
City: BATON ROUGE
State: LA
ZIP: 70805
Mailing: PO BOX 551, BATON ROUGE, LA 70821

What kind of inspection was it?

Inspection type: Planned (H)
Scope: Partial (B)
Discipline: Safety
Advance notice: No
Union status: Y

When did the case open and close?

Opened: 2011-03-14 00:00:00
Closing conference: 2011-09-12 00:00:00
Case closed: 2013-02-19 00:00:00
Last modified: 2015-01-05 00:00:00
Data loaded: 2015-01-08 01:01:51

Establishment context

NAICS code: 324110
SIC code (legacy): 2911
Employees: 2100
Ownership type: A
Industry flags: Manufacturing safety.

Citations

22 citations on file for this inspection.

5(a)(1)

Serious Gravity 10 1 instance 8 exposed

Issued: Sep 12, 2011
Abate by: Sep 15, 2011
Penalty: Initial $7,000

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish to each of his employees a place of employment which was free from
recognized
hazards that were causing or likely to cause death or serious phyical harm
to employees in
that employees were exposed to struck by hazards from a falling vent
stack.  The employer
failed to ensure that the Low Pressure Let Down Steam Vent Stack located
near the
Hydrocracker Blowdown Drum is in compliance with ASME STS-1 mechanical and
structural stability code for guyed stacks 4.10.1.1 and 4.10.1.2.:
This violation most recently occurred at the Exxon Mobile Refinery and
Supply Company in
Baton Rouge, Louisiana on or about March 31, 2011, and at times prior
thereto, when the
employer failed to repair the broken guy wires to keep the exhaust vent
stack in stable
position.
Abatement notes:  Among other methods, one feasible method of abatement to
reduce this
hazard is to: Follow the requirements of the ASME STS-1section 4.10.1.1
and 4.10.1.2
which states that there should be a minimum of three guy cables at 120 deg
from each other
around the circumference and cables shall be attached to a fixed and
stable structure or
foundation.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement
plan describing the actions it is taking to ensure that all guyed stacks
conform to ASME STS-
1.   The violation must be abated no later than 10 days from the receipt
of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $7000.00

1910.37 B04

Serious Gravity 01 1 instance 30 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $3,300 · Current $5,500

General-duty citation text

29 CFR 1910.37(b)(4): Signs were not posted along the exit access
indicating the direction of
travel to the nearest exit and exit discharge if the direction of travel
to the exit or exit discharge
was not immediately apparent:
The employer did not post signs that would provide a clear direction of
travel along the Mutual
Aid Route (at or near the intersection of 17th Street and Utilities Road)
for employees who must
utilize the route to exit the refinery during an emergency evacuation.
This
violation was
documented on or about April 28, 2011.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement plan
describing the actions it is taking to ensure that signs posted along the
Mutual Aid Route provide
a clear direction of travel.   The violation must be abated no later than
10 days from the receipt
of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S) $5500.00
2011-09-12 00:00:00 — Z (S) $3300.00

1910.119 D03 IB

Other-than-serious Gravity 10 3 instances 11 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000 · Current $5,500 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)The employer did not ensure that Process Safety Information (PSI)
depicted on their
P&IDs was up-to-date and accurate.  The employer violated this standard on
or about
March 14, 2011 when set pressures for Hydrocracker Reactor safety relief
valves:
SV-020l020, SV-020l021, SV-020l022, SV-020l023, SV-020l024, and SV-020l025
were not correctly documented on the PMCDs (the employer's P&ID
equivalent) as
observed on safety valve tags in the field.  This exposed employees to
fire and
explosion hazards.
The following PMCDs/P&IDs were deficient:
A-26116-7-0115-702: The set pressures listed on the P&ID for safety relief
valves SV-020l020 and SV-020l021 were lower than the set pressures observed
on safety relief valve tags in the field.
A-26116-7-0117-702: The set pressures listed on the P&ID for safety relief
valves SV-020l022 and SV-020l023 were lower than the set pressures observed
on safety relief valve tags in the field.
A-26116-7-0119-702: The set pressures listed on the P&ID for safety relief
valves SV-020l024 and SV-020l025 were lower than the set pressures observed
on safety relief valve tags in the field.
b)The employer violated this standard on or about May 27, 2011 when a CSHO
review
of the P&IDs showed the employer did not ensure that the Hydrocracker unit
(HCLA)
Piping and Instrument Diagrams (P&IDs) are complete and accurate.
Drawing A-26116-7-0800-702 incorrectly shows the firewater flow direction
in the
system piping as a flow from the Blowdown Drum, D-115 to the firewater
supply
system. The correct direction of firewater flow is from the firewater
system to the
Blowdown Drum, D-115.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement
plan describing the actions it is taking to ensure that process safety
information pertaining to
the equipment in the process includes accurate and updated piping and
instrument diagrams
(P&IDs).   The violation must be abated no later than 10 days from the
receipt of this
citation.

Recent events (2)

2012-07-19 00:00:00 — F (O) $5500.00
2011-09-12 00:00:00 — Z (S) $7000.00

1910.119 D03 II

Deleted Serious Gravity 10 1 instance 11 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000

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:
The employer does not ensure that Hydrocracker Reactors R-101, R-102, and
R-103 are
adequately protected from overpressure.  Set pressures for reactor safety
relief valves: SV-
020l020, SV-020l021, SV-020l022, SV-020l023, SV-020l024, and SV-020l025
are set higher
than the maximum allowable working pressure (MAWP).  This violation was
documented on
or about March 14, 2011.
API RP 520: "Sizing, Selection, and Installation of Pressure-Relieving
Devices in Refineries,
Part I - Sizing and Selection" (7th edition, January 2000; Section
3.5.2.2.2, pages 39 and 40)
states that when multiple pressure relief devices are used on a vessel
(sized for operating
non-fire contingencies), the set pressure of the first device shall not
exceed the Maximum
Allowable Working Pressure (MAWP) and the set pressure of the additional
device or
devices shall not exceed 105% of the MAWP.  In addition, pages 97 and 98
of the ASME
Code, Section VIII (2004), UG-134: "Pressure Setting of Pressure Relief
Devices"
also
confirms these set pressure requirements for relief devices.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement
plan describing the actions it is taking to ensure that pressure setting
of safety relief devices
for process vessels do not exceed the design pressure of the vessel.  The
violation must be
abated no later than 10 days from the receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $7000.00

1910.119 E03 III

Deleted Serious Gravity 10 1 instance 10 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000

General-duty citation text

29 CFR 1910.119(e)(3)(iii)  The process hazard analysis was not
appropriate to the
complexity of the process.  It did not 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 violated this standard on or about June 6, 2011.  In its
Pipestill (PSLA-7)
2011 Delta and Transient Operation Hazop, the employer recommended that
the
three gate
valves on the pipe line connecting the fire water system to the main
quench (river) water
supply pipe line be carsealed open to ensure adequate quench water flow to
Blowdown Drum
D-7.  However, there are two block valves and a control valve on the river
water line
downstream of the point where the fire water line merges with it.  These
three valves must
also be kept open for quench water to reach the blowdown.  However, the
PHA made no
recommendation to carseal those valves open, and a field audit verified
the valves are not
carsealed open.  Since the valves on the river water line are downstream
of the point where
the fire water merges with the river water line, closure of any one of
these three valves will
eliminate the flow of quench water to the blowdown.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement
plan describing the actions it is taking to ensure that every future
Process
Hazard Analysis is
sufficient to cover all process hazards. The violation must be abated no
later than 10 days
from the receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $7000.00

1910.119 E03 VI

Deleted Serious Gravity 10 1 instance 11 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address
human factors.
The 2010 PHA for the Hydrocracker Unit did not ensure that human factors
are considered as
having a potential impact on safety and health.  The employer violated
this standard on or about
May 12, 2011, when investigation indicated that there are not sufficient
personnel in the
Hydrocracker unit to adequately handle emergency situations if more than
one unit is involved.
Hydrocracker employees operate not only the Hydrocracker, but four other
units as well.  The
2010 PHA addressed the problem of too few employees during startup.  MOC
201104100
addresses the number of employees available on start-up along with ten
other PHA
recommendations.  It does not address the number of persons required to
adequately
handle an
emergency or upset condition which arises during normal operations.   It
states there is no
impact on safety and health.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement plan
describing the actions it is taking to ensure that the management of
change procedures assure that
the impact of the change on safety and health is addressed prior to any
change.  The violation
must be abated no later than 10 days from the receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $7000.00

1910.119 E05

Other-than-serious Gravity 05 1 instance 10 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $5,000 · Current $5,500

General-duty citation text

29 CFR 1910.119(e)(5) The employer failed to establish a system to
promptly address the
PHA recommendations ; assure that the recommendations are resolved in a
timely manner
and that the resolution is documented.
The employer violated this standard on or about June 21, 2011 when a
review of the P&IDs
and 2010 PHA report indicated that PHA recommendation item No S-5008 to
add a note to
the bypass line of safety valve, SV-020l081, in red-lined P&ID No:
A-26116-7-0130-702
was not complete.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement
plan describing the actions it is taking to ensure that PHA
recommendations are completed in
a timely manner.  The violation must be abated no later than 10 days from
the receipt of this
citation.

Recent events (2)

2012-07-19 00:00:00 — F (O) $5500.00
2011-09-12 00:00:00 — Z (O) $5000.00

1910.119 F03

Deleted Serious Gravity 01 1 instance 10 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $3,300

General-duty citation text

29 CFR 1910.119(f)(3)  The employer did not certify annually that the
operating procedures
for the Hydrocracker Unit were current and accurate.
This standard was violated on or about April 19, 2011 when the employer
failed to certify
the Hydrocracker Unit operating procedures were current and accurate.  The
SSEP procedure
manual had been certified on April 19, 2010 and should have been certified
again on or
before that date in 2011.  However, the actual date in 2011 that the
procedures were certified
was April 29, ten days later than it should have been.  The procedures in
the binder that was
not certified included but is not limited to the following:
HCLA-SU-0304 is Rev. 0 dated 12/05
HCLA-SU-0321 is Rev. 0 dated 12/05
HCLA-SU-0351 is Rev. 0 dated 03/08
HCLA-SU-0355 is Rev. 0 dated 03/08
HCLA-SD-0402 is Rev. 0 dated 12/05
HCLA-SD-0406 is Rev. 1 dated 02/08
HCLA-EP-0501 is Rev. 0 dated 12/05
HCLA-EP-0506 is Rev. 2 dated 02/10
HCLA-EP-0508 is Rev. 0 dated 12/05
HCLA-EP-0509 is Rev. 1 dated 02/10
HCLA-EP-0510 is Rev. 0 dated 12/05
HCLA-EP-0511 is Rev. 0 dated 12/05
HCLA-EP-0512 is Rev. 0 dated 12/05
HCLA-EP-0520 is Rev. 1 dated 02/10
HCLA-EP-0522 is Rev. 1 dated 02/10
HCLA-EP-0540 is Rev. 1 dated 02/10
HCLA-EP-0544 is Rev. 1 dated 02/10
HCLA-EP-0699 is Rev. 0 dated 12/05
HCLA-SP-0727 is Rev. 0 dated 12/05
HPLA-SP-0732 is Rev. 1 dated 01/11
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement
plan describing the actions it is taking to ensure that in the future,
operating procedures will
be certified annually. The violation must be abated no later than 10 days
from the receipt of
this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $3300.00

1910.119 H02 IV

Deleted Serious Gravity 10 1 instance 10 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000

General-duty citation text

29 CFR 1910.119(h)(2)(iv): The employer did not develop and implement safe
work
practices consistent with 29 CFR 1910.119(f)(4), to control the entrance,
presence and exit of
contract employers and contract employees in covered process areas:
The employer did not develop and implement safe work practices to account
for contract
employees' entry, presence and exit into process areas.  The employer
violated this standard
on or about April 28, 2011 and June 9, 2011 where contract employees
performing
demolition work in the 3-LEUS (Light Ends) Unit were not accounted for by
the
host
employer through a Unit control room sign-in/sign-out log or other method.
a)April 28, 2011:  Blue Permit (#342075) was generated for "Entry or
Special Hot
Work" involving Midwest and Lowery employees.  The task was to enter to
demo,
repair, and rebuild the #6 Cell /28 Cooling Tower.  At the time of the OSHA
walkaround, there were a total of eight Midwest contract employees present
in the
process area to perform the work permit tasks and only the name of the
Acceptor was
documented on the work permit maintained in the control room.  All eight
employees
had signed the LOTO Accountability List that was maintained by the
contractor in the
field.  The Work Permission Book in the control room has none of the
Midwest
employees signed in.
b)June 9, 2011:  Blue Permit (#342678) was generated for "Entry or Special
Hot Work"
involving Midwest and Lowery employees.  The task was to enter to demo,
repair,
and rebuild the #2 Cell /27 Cooling Tower.  At the time of the OSHA
walkaround,
there were a total of ten Midwest contract employees present in the
process area to
perform the work permit tasks and only the name of the Acceptor was
documented on
the work permit maintained in the control room.  All ten employees had
signed the
LOTO Accountability List that was maintained by the contractor in the
field.   When
CSHOs first arrived in the contractor area designated by the work permit,
two
employees were not accounted for.  It was later determined that the two
employees
had left the work permit area but had remained in the Unit.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement
plan describing the actions it is taking to ensure that all "normally
unassigned employees"
present in the process areas are accounted for and that their entry,
presence
and exit in
process areas are controlled.  The violation must be abated no later than
10 days from the
receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $7000.00

1910.119 H02 V

Other-than-serious Gravity 10 1 instance 8 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000 · Current $5,500 Reduced

General-duty citation text

29 CFR 1910.119 (h)(2)(v): The employer does not periodically evaluate the
performance of
contract employers in fulfilling their obligations as specified in
paragraph (h)(3) of this section:
The employer does not periodically evaluate the performance of contract
employers in fulfilling
their obligation to assure that each contract employee is instructed in
the applicable provisions
of the emergency action plan as specified in 29 CFR 1910.119(h)(3)(ii);
contract employees who
perform multiple tasks/functions in various units throughout the refinery
did not know the
difference between the unit-wide alarm and the refinery-wide alarm.  This
violation was
documented on or about June 07, 2011.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement
plan
describing the actions it is taking to ensure that contract employers are
periodically evaluated
on their performance in instructing each contract employee in the
applicable provisions of the
Emergency Response Plan, including the difference between unit and
refinery alarms.  The
violation must be abated no later than 10 days from the receipt of this
citation.

Recent events (2)

2012-07-19 00:00:00 — F (O) $5500.00
2011-09-12 00:00:00 — Z (O) $7000.00

1910.119 J02

Deleted Serious Gravity 10 3 instances 10 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000

General-duty citation text

29 CFR 1910.119 (j)(2) The employer did not establish and implement
written procedures to
maintain the on-going integrity of process equipment.
a)The employer did not implement its Mechanical Integrity Program (General
Thickness
Monitor Requirement Section 3.1) for resolving anomalous pressure vessel
inspection
data. The employer did not address the inconsistencies on thickness
measurements
taken on the shell and channel box of heat exchanger E-103D on January
2004 and
July 2009.   The report for the shell side indicates a serious anomaly
which was not
addressed for the last seven (7) years. Test results which were collected
on 01/2004
(shell) (Bates #7995-7996) have several readings with thickness higher
than the initial
thickness which was measured in 1972 by more than 0.020".   This violation
was
documented on May 6, 2011.
b)The employer does follow the External Inspection of Piping procedure
from their
Global Inspection Practices Manual which references API 570 for piping
inspections
The company failed to include the appropriate thickness measurements
(previous
thickness) for Piping Circuit P020L500-X in its calculation of corrosion
rates in 2009.
Section 7.1.3 of API 570 specifically states that "corrosion rates shall
be calculated on
either a short term or a long term basis" for existing piping. The
employer violated
this standard on or about March 14, 2011 when the employer did not
complete the
corrosion analysis required by API 570 for inspections on P020L500-X
piping
circuit.
c)The employer's Mechanical Integrity Program does not ensure that
Hydrocracker
Reactors R-101, R-102, and R-103 were adequately protected from
overpressure.  Set
pressures for reactor safety relief valves: SV-020l020, SV-020l021,
SV-020l022, SV-
020l023, SV-020l024, and SV-020l025 were set higher than the maximum
allowable
working pressure (MAWP).  This violation was documented on or about March
14,
2011.
As per API RP 520: "Sizing, Selection, and Installation of
Pressure-Relieving Devices
in Refineries, Part I - Sizing and Selection" (7th edition, January 2000;
Section
3.5.2.2.2, pages 39 and 40) when multiple pressure relief devices are used
on a vessel
(sized for operating non-fire contingencies), the set pressure of the
first device shall
not exceed the Maximum Allowable Working Pressure (MAWP) and the set
pressure
of the additional device or devices shall not exceed 105% of the MAWP.  In
addition,
see pages 97 and 98 of the ASME Code, Section VIII (2004), UG-134:
"Pressure
Setting of Pressure Relief Devices" which also confirms the set pressure
requirements
for relief devices.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement
plan describing the actions it is taking to ensure that steps are taken to
resolve anomalous
data readings.   The violation must be abated no later than 10 days from
the receipt of this
citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $7000.00

1910.119 J04 II

Deleted Serious Gravity 10 1 instance 10 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000

General-duty citation text

29 CFR 1910.119(j)(4)(ii)  Inspection and testing procedures did not
follow recognized and
generally accepted good engineering practices.
The employer does not follow RAGAGEP (API 570) for piping inspection when
it
failed to
include the appropriate thickness measurements (previous thickness) for
Piping Circuit
P020L500-X in its calculation of corrosion rates in 2009.  The employer
violated this
standard on or about March 14, 2011 when the employer did not complete the
corrosion
analysis required for inspections on P020L500-X piping circuit.
Not being able to ascertain what the corrosion rate is might result in not
knowing if the
corrosion rate has exceeded the expected rate; this factor is even more
crucial for thickness
monitoring as the piping circuit approaches its retirement date.  API 580,
Section 5.5.1,
states that the rate of deterioration is one of the four factors affecting
the probability of
equipment failure, and it has not been monitored closely in this case.
Without a thorough
inspection plan and assessment based on historical data, the piping
systems can't be operated
reliably and efficiently.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement
plan describing the actions it is taking to ensure that corrosion analysis
is completed in a
timely manner after inspections.   The violation must be abated no later
than 10 days from
the receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $7000.00

1910.119 J05

Deleted Serious Gravity 10 1 instance 10 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000

General-duty citation text

29 CFR 1910.119(j)(5)  - Employer did not ensure that deficiency in
equipment is corrected
in a safe and timely manner
The employer does not 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 violated this standard on or about March 14, 2011 when a broken
gate valve
caused a level gauge on D-110 to not work properly; rendering the visual
verification of
liquid level for this vessel ineffective.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement
plan describing the actions it is taking to ensure that all equipment is
maintained in a safe
and reliable condition.   The violation must be abated no later than 10
days from the receipt
of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $7000.00

1910.119 L01

Deleted Serious Gravity 05 1 instance 10 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $5,500

General-duty citation text

29 CFR 1910.119(l)(1): The employer shall establish and implement written
procedures to
manage changes to process chemicals, technology, equipment, and
procedures; and changes
to facilities that affect a covered process.
The employer did not ensure that an MOC was written to manage the changes
made on
process piping.  The employer violated this standard on or about March 31,
2011 when
process piping to D-99, D-111, D-137 and D-138 was disconnected because it
was below
retirement thickness.  The disconnection was done without going through
MOC procedure,
therefore P&IDs (PMCDs) were not updated once the isolation of thin piping
to D-111, D-
99, D-137, and D-138 was completed.  These are secondary process piping
circuits that
contain hydrocarbon; and are used to test a level switch. It was not
connected at the time of
inspection.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement
plan describing the actions it is taking to ensure that changes in process
equipment and piping
will be properly managed through MOC procedure .   The violation must be
abated no later
than 10 days from the receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $5500.00

1910.119 L02 II

Deleted Serious Gravity 10 1 instance 11 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000

General-duty citation text

29 CFR 1910.119(l)(2)(ii):  The management of change procedures did not
assure that the
impact of the change on safety and health is addressed prior to any change:
Management of change procedures do not ensure that the employer adequately
addresses
the
impact that MOC 200402007 (HCLA T/A: E-103 ABCDE Rupture Discs) would have
on safety
and health prior to implementing it.  The employer failed to evaluate how
the E-103 exchangers'
rupture discs and the D-115 condensable blowdown drum would impact each
other during a
depressuring event to D-115.  This violation was documented on or about
April 21, 2011.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement plan
describing the actions it is taking to ensure that the management of
change procedures assure that
the impact of the change on safety and health is addressed prior to any
change.  The violation
must be abated no later than 10 days from the receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $7000.00

1910.119 M01

Deleted Serious Gravity 10 1 instance 12 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000

General-duty citation text

29 CFR 1910.119(m)(1):  The employer did not investigate each incident
which resulted in, or
could reasonably have resulted in a catastrophic release of highly
hazardous chemicals in the
workplace:
The employer failed to investigate an incident in the hydrocracker unit
which occurred when one
of three check valves on the discharge of pump P-103 failed to close,
causing the overpressure
of well water tank TK-1 such that its hinged lid blew off, and resulting
in the release of H2S
that had backed into tank TK-1 from D-103, the high pressure separator,
which contains
hydrocarbons, H2, H2S, and NH3. This violation was documented on or about
June 27, 2011.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement plan
describing the actions it is taking to ensure that all incidents and near
misses are investigated.
The violation must be abated no later than 10 days from the receipt of
this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $7000.00

1910.119 M04 II

Deleted Serious Gravity 01 2 instances 12 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $3,300

General-duty citation text

29 CFR 1910.119(m)(4)(ii):  The report prepared at the conclusion of the
investigation of an
incident which resulted in, or could reasonably have resulted in a
catastrophic release of a highly
hazardous chemical(s) in the workplace, did not include the date the
investigation began:
a) The employer did not include the date the investigation began in the
D-115 CBD Incident
Investigation report for an incident that occurred on September 12, 2007.
The date is required
to determine whether the investigation was started within 48 hours as
required.  This violation
was documented on or about April 06, 2011.
b) The employer did not include the date the investigation began in the
HHLA-S F-201 Pressure
Excursion Near Miss Incident Investigation report for an incident that
occurred on February 7,
2006.  The date is required to determine whether the investigation was
started within 48 hours
as required.  This violation was documented on or about April 06, 2011.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement plan
describing the actions it is taking to ensure that incident investigation
reports contain all pertinent
information, including the date the investigation began.   The violation
must be abated no later
than 10 days from the receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $3300.00

1910.119 M04 IV

Deleted Serious Gravity 05 1 instance 12 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $5,500

General-duty citation text

29 CFR 1910.119(m)(4)(iv):  The report prepared at the conclusion of the
investigation of an
incident which resulted in, or could reasonably have resulted in, the
catastrophic release of a
highly hazardous chemical(s), did not include the factors that contributed
to the incident:
The employer does not include all of the contributing factors in the D-115
CBD Incident
Investigation report for an incident that occurred on September 12, 2007.
The employer failed
to address the cause of the C-101 compressor trip, which was one of the
incident's initiating
events, and the inadequacy of MOC 200402007, which was one of the root
causes of the event.
This condition was documented on or about April 21, 2011.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement plan
describing the actions it is taking to ensure that incident investigation
reports contain all pertinent
information, including the factors that contributed to the incident.  The
violation
must be abated
no later than 10 days from the receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $5500.00

1910.119 O01

Deleted Serious Gravity 10 2 instances 26 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000

General-duty citation text

29 CFR 1910.119(o)(1):  The employer did not certify that it had evaluated
compliance with the
provisions of 29 CFR 1910.119 at least every three years to verify that
the procedures and
practices developed under the standard are adequate and being followed:
a) The employer did not develop and implement a sampling strategy that
would ensure statistical
validity/significance and selection of a representative number of pressure
vessel inspection
records to review while conducting the 2007 compliance audit.  This
violation was documented
on or about May 12, 2011.
b) The employer does not develop and implement a sampling strategy that
would ensure
statistical validity/significance and selection of a representative number
of pressure vessel
inspection records to review while conducting the 2010 compliance audit.
This violation was
documented on or about May 12, 2011.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement plan
describing the actions it is taking to make sure that a strategy is
developed and implemented to
ensure a representative number of vessels is chosen for evaluation, and
that all incident
investigation reports include the date the investigation began and the
factors that contributed to
the incident during compliance audits.   The violation must be abated no
later than 10 days from
the receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $7000.00

1910.120 Q06 I

Deleted Serious Gravity 10 1 instance 2 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $7,000

General-duty citation text

29 CFR 1910.120 (q)(6)(i):  Employees who participated, or were expected
to participate, in an
emergency response as first responders at the awareness level took further
action beyond
initiating an emergency response sequence to a hazardous release by
notifying the proper
authorities:
The employer failed to ensure that two employees identified as first
responders at the awareness
level acted within the limitations of their qualifications, by allowing an
employee to perform air
monitoring in an emergency response to an H2S release in the PCLA/Cat unit
and allowing
another employee to act as fire fighter against multiple small leaks and
seal fires; both
employees acted in a manner that was beyond initiating a response to a
potentially hazardous
release by notifying the authorities.  This violation was documented on or
about May 10, 2011.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement plan
describing the actions it is taking to ensure that employees are trained
to the level of response
expected of them during emergencies.   The violation must be abated no
later than 10 days from
the receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (S)
2011-09-12 00:00:00 — Z (S) $7000.00

1910.119 N

Other-than-serious Gravity 03 3 instances 31 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $1,100 · Current $1,100

General-duty citation text

29 CFR 1910.119(n):  The employer did not establish and implement an
emergency action plan
for the entire plant in accordance with the provisions of 29 CFR 1910.38:
a) The employer does not establish an emergency action plan in accordance
with
29 CFR
1910.38(d) by failing to maintain an employee alarm system that complies
with the requirement
in 1910.165(b)(4) to declare the preferred method by which to report a
unit-wide emergency and
1910.165(b)(5) to establish complete procedures for sounding the emergency
unit-wide alarm that
include what location(s) it can be sounded from, which person(s) to
contact to sound the alarm,
and by what means to make contact.  This violation was documented on or
about April 27,
2011.
b) The employer did not implement an emergency action plan in accordance
with the provisions
of 29 CFR 1910.38(c)(1) by failing to ensure that employees in an area of
the hydrocracker that
spans from north of compressor C-101 to south of drum D-103 could utilize
their radios to
execute procedures for reporting a fire or other emergency to the
controllers at the Refinery
Operations Control Center (ROCC).  This violation was documented on or
about May 06, 2011.
c) The employer failed to implement an emergency action plan in accordance
with the provisions
of 29 CFR 1910.38(c)(4) by not ensuring that the phone provided at the
Mutual Aid Staging
Area (Staging Area G) was fully functional and approved for use in a class
1, division 2, group
C hazardous location in order to promote safe execution of procedures to
account for employees
after emergency evacuation via the Mutual Aid Route.  This violation was
documented on or
about April 28, 2011.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement plan
describing the actions it is taking to ensure that the Emergency Response
Plan is established and
implemented in accordance with the provisions of 29 CFR 1910.38.   The
violation must be
abated no later than 10 days from the receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (O) $1100.00
2011-09-12 00:00:00 — Z (O) $1100.00

1910.307 C

Deleted Other-than-serious Gravity 03 1 instance 31 exposed

Issued: Sep 12, 2011
Abate by: Sep 29, 2011
Penalty: Initial $1,100

General-duty citation text

29 CFR 1910.307(c):  Equipment, wiring methods, and installations of
equipment in hazardous
(classified) locations were not intrinsically safe, approved for the
hazardous
(classified) location,
or safe for the hazardous (classified) location:
The employer did not maintain the telephone provided at the Mutual Aid
Staging Area (Staging
Area G) in the condition necessary for it to be utilized in the class 1,
division 2, group C
hazardous location for which it was approved.  The employer failed to
ensure that the plate
protecting the electrical components from the atmosphere/ambient air
remained affixed to the
phone.  This violation was documented on or about April 28, 2011.
Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an
abatement plan
describing the actions it is taking to ensure that the equipment at
Staging Area G is maintained
such that it is approved for the hazardous location.  The violation must
be abated no later than
10 days from the receipt of this citation.

Recent events (2)

2012-07-19 00:00:00 — F (O)
2011-09-12 00:00:00 — Z (O) $1100.00

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Source

This record is reproduced from the U.S. Department of Labor Open Data API (OSHA inspection dataset). The original IMIS detail view is available at OSHA's Establishment Search for activity number 314769704.

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