OSHA Inspection: MARTIN OPERATING PARTNERSHIP, LP

Issued

Jul 18, 2013

Abate by

Aug 2, 2013

Penalty

Initial $0 · Current $0

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 the process safety information:   The employer does not ensure written operating procedures are developed and implemented that provided clear instructions for safely conducting activities involved in each process.     The violation occurred in the # 1 Crude Unit on or about January 23, 2013 and times prior to where the employer failed to ensure written operating procedures were developed and implemented to provide clear instructions for the use of chains, locks, or car-seals to ensure the intervening block valves to/from relief devices were open during operation following a shutdown/turn around.  Identified relief devices and equipment include but are not limited to:  a.  PSV-8504 (#1 Desalter) b.   PSV-8505 (#2 Desalter) c.  PSV-8502 (Atmospheric Tower) d.  PSV-8503/8511 (Vacuum Tower) e.  PSV-8512 (V-7325-Vacuum Seal Drum).     This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gasses.  Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure written operating procedures are implemented that provide clear instructions for safely conducting activities in each process to maintain the on-going mechanical integrity of process equipment according to recognized and generally accepted good engineering practices.

Issued

Jul 18, 2013

Abate by

Aug 2, 2013

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to assure that the recommendations were resolved in a timely manner and that the resolution was documented.  The employer does not ensure that a system was established to assure the 2012 PHA recommendations were resolved in a timely manner and the resolution was documented.  a. The violation occurred on or about January 30, 2013 and times prior thereto at Martin Operating Parntership where the employer failed to ensure that facility siting recommendations for proper control room ventillation were resolved in a timely manner.  This condition exposed employees to inhalation, fire, and explosion hazards.  b. The violation occurred on or about January 30, 2013 and times prior thereto in Martin Operating Parntership where the employer failed to ensure that facility siting recommendations for installation of blast mitigation glass were resolved in a timely manner and resolution was documented.  This condition exposed employees to inhalation, fire, and explosion hazards.  c. The violation occurred on or about January 30, 2013 and times prior thereto in Martin Operating Parntership where the employer failed to ensure that facility siting recommendations for equipment outside the control room to be rated for flammable area was resolved in a timely manner and resolved in a timely manner.  This condition exposed employees to inhalation, fire, and explosion hazards.  d. The violation occurred on or about January 30, 2013 and times prior thereto in Martin Operating Parntership where the employer failed to ensure that recommendation #5 for verification of relief valve capacity was resolved in a timely manner and resoltution documented.  This condition exposed employees to inhalation, fire, and explosion hazards.  e. The violation occurred on or about January 30, 2013 and times prior thereto in Martin Operating Parntership where the employer failed to ensure that recommendation #6 for verification of relief valve #1 and #2 relief valves and associated piping are sized properly was resolved in a timely manner and resolution documented.  This condition exposed employees to inhalation, fire, and explosion hazards.  f. The violation occurred on or about January 30, 2013 and times prior thereto in Martin Operating Parntership where the employer failed to ensure that recommendation #7 for verification of requirements for over pressure protection of equipment including vessels associated with the vacuum tower was resolved in a timely manner and resolution documented.  This condition exposed employees to inhalation, fire, and explosion hazards.    Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure that the process hazard analysis teams recommendations are resolved in a timely manner and that the resolution is documented.

Issued

Jul 18, 2013

Abate by

Aug 2, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5):  The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) in a safe and timely manner when necessary means where taken to assure safe operation.  The employer does not correct deficiencies in equipment that were outside acceptable limits in a safe and timely manner when necessary means where taken to assure safe operation.  The violation occurred on or about January 30, 2013 in Crude Unit #1 where the employer failed to correct deficiencies in equipment that were outside acceptable limits in a safe and timely manner when necessary means were taken to assure safe operation.  An identified equipment-containing structure includes but is not limited to Crude #1 Unit control room.  This condition exposed employees to fire and explosion hazards.  Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure that the control room deficiencies have been addressed and documented.

Issued

Jul 18, 2013

Abate by

Aug 2, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5):  The employer did not correct deficiencies in equipment that were outside acceptable limits (as defined by process information in 29 CFR 1910.119(d) before further use or in a safe and timely manner.     The employer does not ensure deficiencies are corrected in equipment that is outside acceptable limits before further use or in a safe and timely manner.    A.  The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed ensure a relief valve was provided to protect equipment from overpressure scenarios in accordance with RAGAGEP such as ASME Division I, Section VIII and API 520. Identified equipment requiring relief protection include but not limited to:     a. PSV-XX01 (E-2246, E-2207, E-2245, E-2209, E-2248, E-2211, E-2212, E-2213, E-2214, and E-2215) b. PSV-XX02 (E-2202 and E-2228) c. PSV-XX03/04 (E-2205 and E-2229) d. PSV-XX05 (E-2211, E-2248, E-2230, E-2216, E-2217, and E-2218) e. PSV-XX06/07/08 (E-2213, E-2212, E-2247, E-2243, E-2249, and E-2232) f.  PSV-XX?? (E-2261 and E-2262) g. PSV-XX12 (E-2207, E-2208, E-2209, E-2210, and E-2204) h. PSV-XX16 (E-2206) i.  PSV-XX21 (E-2214 and E-2215).    This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gasses.  B.  The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure relief valves were properly sized for relieving capacity in accordance with RAGAGEP such as API 520.  Identified relief valves include but not limited to:    a. PSV-8504 (#1 Desalter) b. PSV-8502 (Atmospheric Tower) c. PSV-8503/8511 (Vacuum Tower).    This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gasses.  C.  The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure relief valves relieving set pressure was at or below the maximum allowable working pressure of the vessel(s) it is protecting in accordance with RAGAGEP such as API 520 and ASME Division I, Section VIII. Identified relief valves include but not limited to:     a. PSV-8502 (Atmospheric Tower) b. PSV-8503/8511 (Vacuum Tower).    This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gasses.  D.  The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure relief valves discharged to a safe location in accordance with a RAGAGEP such as ASME Division I, Section VIII. Identified relief valves include but not limited to:  a. PSV-8504 (#1 Desalter) b. PSV-8505 (#2 Desalter) c. PSV-8512 (Vacuum Seal Drum).    This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gasses.    E.  The violation occurred in the #1 Crude Unit on or about January 23, 2013 and at times prior thereto where the employer failed to ensure relief valve discharge line/piping was sized to handle the relieving capacity of the relief valve in accordance with a RAGAGEP such as ASME Division I, Section VIII and/or API 520. Identified relief valves include but not limited to:   a. PSV-8504 (#1 Desalter) b. PSV-8505 (#2 Desalter).    This condition exposed employees to fire and explosion hazards from potential releases of flammable liquids or gasses.    Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure deficiencies are corrected in equipment that is outside acceptable limits before further use or in a safe and timely manner.

Issued

Jul 18, 2013

Abate by

Aug 2, 2013

Penalty

Initial $38,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D):  Process safety information pertaining to the equipment in the process did not include the relief system design and design basis:   The employer does not ensure that the process safety information pertaining to the equipment in the process contains the relief design and design basis.   The violation occurred on or about February 5, 2013 and times prior thereto in Crude Unit #1 where the employer failed to ensure that the process safety information included the relief system design and design basis.  Identified relief devices include but are not limited to 01-PSV8505 and 01-PSV8508.  This condition exposed employees to fire and explosion hazards.    Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement date the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure that relief system design and design basis information is documented and is part of the process safety information.