OSHA Inspection: HOLLY REFINING & MARKETING - TULSA LLC

Issued

Mar 14, 2011

Abate by

Aug 30, 2011

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
employer did not
furnish employment and a place of employment which were free from
recognized hazards
that were causing or likely to cause death or serious physical harm to
employees in that
employees were exposed to fire hazards:
The employer did not control ignition sources through proper bonding and
grounding during
manual operations with flammable liquids.  On or about November 4, 2010,
in the #2
Platformer Unit, the employer failed to ensure proper bonding and
grounding during process
operations at the Methanol and Chloride Injection Tanks:
a) The employer did not ensure proper grounding of the 55-gallon drum of
methanol used
during the manual addition process to the Chloride Injection Tank.
b) The employer did not ensure proper bonding between the employee, the
plastic containers
used to transfer the methanol, the 55-gallon drum of methanol, and the
Chloride
Injection
Tank during manual addition of methanol to the Chloride Injection Tank.
One feasible method of abatement for this hazard, among others, would be
to ensure proper
grounding and bonding of containers is done to ensure static discharge is
eliminated.

Issued

Mar 14, 2011

Abate by

Oct 1, 2011

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.38(d):  The employee alarm system did not use a distinctive
signal for each
purpose and comply with the requirements in 29 CFR 1910.165:
On or about September 14, 2010, and at times prior thereto, the employer
did not ensure a
distinctive alarm system was in place to warn of fire, vapor release, or
severe weather for
Holly Refinery West, exposing employees to the hazards of fire, explosion,
toxic vapor
inhalation and flying debris during emergency events.cy

Issued

Mar 14, 2011

Abate by

Oct 1, 2011

General-duty citation text

29 CFR 1910.120(q)(2)(ix):  The emergency response plan did not address
emergency
alerting and response procedures:
On or about September 14, 2010, and at times prior thereto, emergency
alerting procedures
addressed in both the Emergency Response Plan and the Incident Command
Reference
Manual for Holly Refinery West were not consistent, exposing employees to
the hazards of
fire, explosion, toxic vapor inhalation and flying debris during emergency
events.cy

Issued

Mar 14, 2011

Abate by

Apr 16, 2011

Penalty

Initial $5,000 · Current $3,500 Reduced

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
(RAGAGEP):
a)  On or about September 14, 2010, and at times prior thereto, the
employer did not document
the positive-pressure ventilation system in the Crude Unit/Platformer
Control Room complied
with RAGAGEP such as NFPA 496 when the blast-rated doors on the west side
of the control
room were allowed to be used as a common entry/exit.  The west doors were
designed for use
solely as an occupant Emergency Exit or to allow transport of large
equipment.
b)  On or about September 14, 2010, and at times prior thereto, the
employer did not comply
with RAGAGEP such as, but not limited to, API 752, when they housed
employees
in
inadequately protected structures such as, but not limited to, the Boiler
House Control Room.
This exposes employees to the hazards of explosion, fire, and toxic
vapors.
c)  On or about September 14, 2010, and at times prior thereto, the
employer did not document
that relief systems associated with atmospheric blowdown drums in the
Propane Deasphalting
Unit, Methyl Ethyl Ketone Unit, Crude Distillation Unit and Lubes
Extraction Unit complied
with RAGAGEP, such as, but not limited to, API 521.

Issued

Mar 14, 2011

Abate by

Dec 31, 2011

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(e)(5):  The employer did not establish a system to
promptly address
process hazard analysis (PHA) team findings and recommendations; assure the
recommendations are resolved in a timely manner and 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:
On or about September 14, 2010, and at times prior thereto, the employer
did not resolve the
2007 #2 Platformer Unit PHA Revalidation finding and action item to design
a system to
eliminate the practice of manual addition of perchloroethylene to the
Chloride Injection Tank.tion

Issued

Mar 14, 2011

Abate by

Dec 31, 2011

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(f)(1): The employer did not develop and implement written
operating
procedures that provided clear instructions for safely conducting
activities involved in each
covered process consistent with process safety information:
On or about September 14, 2010, and at times prior thereto, the employer
did not fully
develop detailed written operating procedures.  Procedures did not
identify all steps
necessary to perform the procedures and/or did not identify by name, call
number, control
board identifier or other means the valves, pumps, controllers, and
connections referenced in
the procedures.  These procedures, among others, were deficient:
a) OPLT602.DOC, Unifiner Shutdown
b) OPLT606.DOC, Depentanizer Tower Shutdown
c) OBS602.DOC, Butane Splitter Shutdown
d) OPLT105.DOC, Operate and Maintain Chemical Injection Systemson

Issued

Mar 14, 2011

Abate by

Mar 17, 2011

General-duty citation text

29 CFR 1910.119(f)(3):  The operating procedures were not reviewed as
often as necessary
to assure that they reflect current operating practice, including changes
that result from
changes in process chemicals, technology, and equipment, or changes to
facilities:
On or about September 14, 2010, and at times prior thereto, the Unit
Description Manual for
the Platformer Unit did not reflect current operating practice; Section
1.1.2 incorrectly
identified 1,1,1 Trichloroethylene as a chemical used in the platformer
reactor section.
IN THE ALTERNATIVE:
29 CFR 1910.119(d)(1): Process safety information pertaining to the
hazards
of the highly
hazardous chemicals in the process did not consist of the elements
specified in 29 CFR
1910.119 (d)(1)(i) through (vii).h

Issued

Mar 14, 2011

Abate by

Aug 31, 2011

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(iv):  The employer did not ensure contract employees
follow the host
employer's safe work practice when entering, exiting, or working in the
covered process
areas:
The employer did not ensure contractors are properly signed in/out of the
process areas to
allow effective personnel accounting and emergency evacuation/rescue
procedures.
a)On December 10, 2010, four contractor employees signed in and entered
the Unifiner
process area, but failed to sign out of the process area.
b)On December 8, 2010, three contractor employees failed to sign in when
entering the
#8 cooling tower.
c)On December 8, 2010, two contractor employees signed in and entered the
#2
Platformer, but failed to sign out of the process area.

Issued

Mar 14, 2011

Abate by

Apr 16, 2011

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii):  The frequency of inspections and tests of
process equipment to
maintain its mechanical integrity was not consistent with applicable
manufacturers'
recommendations and good engineering practices, or more frequently
determined to be
necessary by prior operating experience:
On or about September 14, 2010, and at times prior thereto, the employer's
mechanical
integrity inspection process for pressure vessels did not adhere to
RAGAGEPs such as API
510 - "Pressure Vessel Inspection Code: Maintenance Inspection, Rating,
Repair, and
Alteration" on the frequency of inspection of thickness measuring
locations (TMLs) for
pressure vessels including, but not limited to:
a) #2 Platformer Unit:  TRPV12 374 Depentanizer (Rerun) Tower
b) #2 Platformer Unit:  R-PV2 374 Reactor2
c) Unifiner Unit:  E-104D 373 Reactor Product Condenser
d) Unifiner Unit:  R-HV3 373 Unifining Reactorng

Issued

Mar 14, 2011

Abate by

Aug 31, 2011

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(l)(1):  The employer did not establish and implement
written procedures to
manage changes to process chemicals, technology, equipment, and procedures
and, changes
to facilities that affect a covered process:
a)#2 Platformer, Unifiner and Butane Splitter Units:  On or about
September 14, 2010,
and at times prior thereto, the employer did not implement management of
change
procedures for increasing the charge to the units.
b)#2 Platformer:  On or about November 3, 2010, the employer did not
implement
management of change procedures for the hand addition of methanol to the
Chloride
Injection Tank.tion

Issued

Mar 14, 2011

Abate by

Apr 16, 2011

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(l)(4):  A change covered by 29 CFR 1910.119(l) resulted in
a change in
the process safety information required by 29 CFR 1910.119(d) and the
process information
was not updated:
On or about September 14, 2010, and at times prior thereto, the employer
did not update
#2 Platformer piping and instrument diagrams (P&IDs).  P&ID MF-45075
depicting the
Chloride Injection Tank and Methanol Injection Tank and associated piping
and equipment
was not concurrent with actual field conditions.

Issued

Mar 14, 2011

Abate by

Dec 31, 2011

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(o)(4):  The employer did not promptly determine and
document an
appropriate response to each of the findings of the compliance audit, and
document that
deficiencies have been corrected:
On or about September 14, 2010, and at times prior thereto, compliance
audit items were not
corrected and documented.  Action Item 1 identified in the 2009 PSM Audit
was not fully
corrected and documented for the Butane Splitter Unit.ter

Issued

Mar 14, 2011

Abate by

Jun 30, 2011

Penalty

Initial $2,500 · Current $1,750 Reduced

General-duty citation text

29 CFR 1910.132(d)(1)(i): The employer did not select and have each
affected employee use
the types of personal protective equipment that would protect the affected
employee from the
hazards identified in the hazard assessment:
In the #2 Platformer Unit, the employer did not ensure employees used
appropriate personal
protective equipment such as chemically-resistant gloves and faceshields:
a) On or about September 14, 2010, and at times prior thereto, for
employees manually
adding perchloroethylene to the injection tank.
b) On or about November 4, 2010, and at times prior thereto, for employees
manually
adding methanol to the injection tank.tion