OSHA Inspection: NAVAJO REFINING COMPANY, LLC

Issued

Mar 27, 2014

Abate by

Apr 29, 2014

Penalty

Initial $1,500

General-duty citation text

11.5.2.9 NMAC
29 CFR 1910.119(d)(2)(i)(A): Process safety information concerning the
technology of the
process in the process did not include accurate simplified process flow
diagrams:
The employer did not ensure that Process Safety Information on their
simplified process flow
diagrams was up to date and accurate. The missing information includes,
but is not limited
to:
1.Alky Unit (Unit 9) -The following equipment was not included in the
simplified
process flow diagrams:
a.Fuel Gas Coalescer (D-600)
b.Acid Relief Neutralizer (D-660)
c.Acid Relief Neutralizer Bottom (D-618)
d.Off Site Acid Storage (D-301)
e.Off Site Acid Storage (D-310)
2.Sats Gas Unit (Unit 35) -The following equipment was not included in the
simplified
process flow diagrams:
a.Feed Surge Drum Water Knockout (D-225)
b.PB Water Knockout (D-226)
c.Propane NaOH Scrubber (D-334)
d.Off Gas Knockout Drum (D-762)
e.Grissom Russel Exchanger (X-756)
3.CCR Unit (Unit 70) -The following equipment was not included in the
simplified
process flow diagrams:
a.Regeneration Tower (W-351)
b.Reactor Effluent Air Cooler (X-315)
c.Reactor Effluent Air Cooler (X-316)
d.Off Gas Chloride Guard (D-330)
e.Booster Hydrogen Coalescer (D-337)
f.Recycle Gas Coalescer (D-338)
Date Corrected:                                     Describe Corrective
Action:

Issued

Mar 27, 2014

Abate by

Apr 29, 2014

General-duty citation text

11.5.2.9 NMAC
29 CFR 1910.119(d)(3)(i)(B): Process safety information pertaining to the
equipment in the
process did not include accurate piping and instrument diagrams (P&ID's):
The employer did not ensure that Process Safety Information on their P&IDS
was up-to-date
and accurate. The inaccurate or out of date information includes, but is
not limited to:
1.Alky Unit (Unit 9):
a.Spare Fresh KOH Storage (T-807) is no longer in use, but is included in
the P&ID
(09-V-3-D-12) and not identified as being out of service.
b.Spare Fresh KOH Drum (D-623) is no longer in use, but is included in the
P&ID (09-
V-3-D-12) and not identified as being out of service.
c.H-600 Induced Draft Fan (F-657) has been out of service for
approximately 4 years,
but is included in the P&ID (09-V-3-D-20) and not identified as being out
of service..
2.Sats Gas Unit (Unit 35):
a.Depropanizer (W-83) has been out of service since at least 2010, but is
included in
the P&ID (35-V-2-D-4) and not identified as being out of service. It is
not included in the
current list of pressurized vessels. The P&ID also doesn't include the
connections to this
equipment that have been disconnected since it was taken out of service.
b.Depropanizer Overhead Receiver (D-313) is out of service, but is
included in the
P&ID (35-V-2-D-4) and not identified as being out of service. It is not
included in the
current list of pressurized vessels.
c.W-60 De-ethanizer Intercooler Bottom (X-229) and W-60 De-ethanizer
Intercooler
Top (X-230) are out of service and blinded, but are included in the P&ID
(35-V-2-D-2) and
not identified as being out of service. Both are on the current list of
pressurized vessels and
identified as being out of service.
d.Butane to storage cooler (X-268) is out of service, but is included in
the P&ID (35-V-
2-D-11) and not identified as being out of service. It is on the current
list
of pressurized
vessels and identified as being out of service.
3.CCR Unit (Unit 70):
a.Relief Valve for D-276 is misidentified as PSV-279 in the P&ID
(70-V-11-D-6) and
the pressure setting is incorrectly identified as 550 psig, which exceeds
the vessel design
pressure of 168 psig. It should be PSV-7051 and the pressure setting
should be 168 psig.
b.Reactor Effluent Fin Fans (X-314, X-315, X-316 and X-317) are not
included in the
P&IDs. All are on the current list of pressurized vessels.
Date Corrected:                                     Describe Corrective
Action:

Issued

Mar 27, 2014

Abate by

Apr 29, 2014

Penalty

Initial $1,500

General-duty citation text

11.5.2.9 NMAC
29 CFR 1910.119(e)(1): The employer did not perform an initial process
hazard analysis on
processes covered by this standard:
Process hazard analyses were not performed on all piping systems, valves,
controls and other
process equipment between processes. The employer determined that the
process boundary
for each process subject to PSM is the battery limit blinding point for
that unit, which does
not include the piping systems between PSM covered processes.
Date Corrected:                                     Describe Corrective
Action:

Issued

Mar 27, 2014

Abate by

Apr 29, 2014

Penalty

Initial $1,500

General-duty citation text

11.5.2.9 NMAC
29 CFR 1910.119(f)(4): The employer did not 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 did not develop and implement safe work practices when they
omitted
lockout/tagout requirements such as, but not limited to requiring that
lockout locks shall not
be used for other purposes and that the identity of the employee applying
the
device shall be
indicated.
Date Corrected:                                     Describe Corrective
Action:

Issued

Mar 27, 2014

Abate by

Dec 31, 2015

Penalty

Initial $1,500

General-duty citation text

11.5.2.9 NMAC
29 CFR 1910.119(h)(2)(ii): The employer shall inform contract employers of
the known
potential fire, explosion, or toxic release hazards related to the
contractor's work and the
process:
The employer did not inform the contractor of all the specific hazards to
which contractor
employees were exposed when working on or near each PSM covered process.
Date Corrected:                                     Describe Corrective
Action:

Issued

Mar 27, 2014

Abate by

Aug 31, 2015

Penalty

Initial $1,500

General-duty citation text

11.5.2.9 NMAC
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 and did not
include procedures for handling small releases.
The Emergency response plan does not include procedures for plant
operations personnel to
follow prior to evacuation or procedures for handling small releases.
Date Corrected:                                     Describe Corrective
Action:

Issued

Mar 27, 2014

Abate by

Aug 31, 2015

General-duty citation text

11.5.2.9 NMAC
29 CFR 1910.38(c)(3): The emergency action plan does not include
procedures to be
followed by employees who remain to operate critical plant operations
before they evacuate:
The emergency response plan did not include procedures for plant
operations personnel for
critical plant operations to follow prior to evacuation.
Date Corrected:                                     Describe Corrective
Action:

Issued

Mar 27, 2014

Abate by

Apr 29, 2014

Penalty

Initial $1,500

General-duty citation text

11.5.2.9 NMAC
29 CFR 1910.134(k)(5)(ii):  Retraining was not conducted when inadequacies
in the
employee's knowledge or use of the respirator indicated that the employee
did not retain the
necessary training or skill:
The employer did not ensure that retraining was provided for employees in
the Alky/CCR
and South divisions who did not retain knowledge in the use of respiratory
protection as
exhibited by the donning and doffing of the respiratory protection
equipment by employees.
Date Corrected:                                     Describe Corrective
Action:

Issued

Mar 27, 2014

Abate by

Mar 30, 2016

General-duty citation text

11.5.2.9 NMAC
29 CFR 1910.119(h)(2)(vi): The employer did not maintain a contract
employee injury and
illness log related to the contractor's work in process areas for all
contractors:
The employer did not maintain or provide injury and illness logs
containing all of the
required information for eleven contractor employees from seven companies
injured at the
refinery from 2010 to 2013.
Date Corrected:                                     Describe Corrective
Action:
I attest that all corrective actions contained in this document are
accurate and affected
employees have been informed of the abatement.
Signature:                                                Date: