OSHA Inspection: MONROE ENERGY, LLC

Issued

May 1, 2014

Abate by

Jun 16, 2014

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(f)(1): The employer did not 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:     a)  Monroe Energy Refinery, Area 3, D1 Diesel Hydrotreater Unit- On or about November 1, 2013, Unit D1 experienced a loss of cooling water.  Rather than implement the approved, written emergency shutdown procedure, DIE-EM-002.000, for responding to a loss of cooling water, the employer allowed Unit D1 to be stopped and held in a warm, idle state without following a written procedure with clear instructions for safely conducting these activities.     b)  Monroe Energy Refinery, Area 3, D1 Unit, Diesel HTU- The employer, on or about November 1, 2013, in responding to a loss of cooling water and expecting a brief shut down, elected to shut down the system using Reactor Shutdown Procedure, DIE-SD-003.000.  The employer failed to implement and ensure the procedure was followed.  Multiple procedural operations that were not performed included sweeping the heater tubes with hydrogen, setting the heater control system in bypass, placing a torch in the heater and positioning the stack dampers to 100 percent open.     c) Monroe Energy Refinery, Area 3, D1 Unit Heater- On or about November 2, 2013, after the restoration of cooling water, the employer directed the restart of the heater using procedure DIE-SU-009.000.  However, the status and position of the heater and its components did not allow the startup procedure to be implemented and followed.  Some but not all conditions that prevented following the procedure included fuel gas and pilot gas pilot systems not isolated, hydrogen circulation was not started or verified, valve positions were not correct or verified, firebox purging was not conducted, and the center burner was locked out and not in the correct position for startup.  The heater was restarted without following the procedure and a fire resulted.

Issued

May 1, 2014

Abate by

Jun 30, 2014

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process:    a)  Area 3, D1 Unit - The center burner of the D1 Heater was locked and tagged out of service in October, 2013 due to a gas leak.  The heater continued in operation until November 1, 2013.  The company did not implement Management of Change procedures before continuing to operate the heater without the operational center burner.      b)  Area 3, D1 Unit - The start-up procedure for the D1 Unit Heater, DIE-SU-009.000, requires, in Step 8.8, that the center burner to be lit first.  On November 2, 2013, this heater was started up with the center burner removed from service due to a gas leak.   The company did not implement a Management of Change procedure prior to deviating from the requirements of Step 8.8 of DIE-SU-009.000.