OSHA Inspection: EXXONMOBIL BATON ROUGE REFINERY (BRRF)

Issued

2017-05-19 00:00:00

Abate by

2017-06-23 00:00:00

Penalty

Initial $12675.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(d): The process safety information did not include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.   On or about November 23, 2016 ,the employer did not maintain a compilation of written process safety information pertaining to the DURCO plug valve involved in the incident located in the Alkylation Unit of the refinery.      Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date, the employer must submit documentation showing that it is in compliance with the requirement, including describing the steps that it is taking to ensure that process safety information is available for all DURCO plug valves and pressure vessels currently present in the Alkylation Unit.

Issued

2017-05-19 00:00:00

Abate by

2017-06-23 00:00:00

Penalty

Initial $12675.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not certify annually that operating procedures were current and accurate.   The employer did not ensure that the operating procedures for the Alkylation Unit were certified as current and accurate annually. The operating procedures for the Alkylation Unit had not been certified since April 2, 2015.                                      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 operating procedures are certified annually.  The violation must be abated no later than 30 days from the receipt of this citation.

Issued

2017-05-19 00:00:00

Abate by

2017-06-23 00:00:00

Penalty

Initial $12675.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain on-going integrity of process equipment as required.   On or about November 22, 2016, the employer failed to implement written maintenance procedures to maintain the ongoing integrity of equipment such as, but not limited to plug valves.  The employer did not ensure that the written procedures established for valve operation and maintenance were implemented in accordance with the Exxon Baton Rouge Refinery programs:    a.     Valve maintenance was not performed in accordance with the ExxonMobil Valve Operation and Maintenance (WP-240) procedure, the Lined Plug Valve Preventative Maintenance procedure (Valve PM-6), and the Manual Gear Operator-Valve Preventative Maintenance procedure (Valve PM-8) for:      DURCO Plug Valve- Handwheel BX28318A, top cap 5679142,  valve F1GG411 6-150, valve CT37841AA/101, Exxon valve tag 50/3322 and valves such as, but not limited to the following:  1. Valve located on piping circuit P130L130-F;  2. Valve located on piping circuit P126L120-A;  3. Valve located on piping circuit P119L100-N; 4. Valve located on piping circuit P119L100-F;  5. Valve located on piping circuit P130L130-F; 6. Valve located on piping circuit P119L100-H;  7. Valve located on piping circuit P119L100-H; 8. Valve located on piping circuit L120-G;     b.    Maintenance on the Gear Operator was not performed in accordance with the procedures referenced in Valve PM-8 Manual Gear Operator (Gearbox) Valve Preventive Maintenance-January 2005; in that process operators will substitute nails for the sheer pin to connect the handwheel to the shaft; a prohibited practice.      c.     The following information was not included in the ExxonMobil mechanical integrity inspection files for the following process equipment:    1.    Isometric drawings indicating the CMLocations were not available for the pressure vessels D-21 and D-22;         Isometric drawings for the following piping circuits did not include all CMLocations as follows: 2.    -P123L025A did not indicate the location of CMLs 11, 12, and 13; and for sub-circuit DO1 and SO1 all CMLs           were missing. 3.    -P123L030H did not indicate the location for CMLs 2, 5, 6, and 8; and the parent circuit           H CMLs 21 and 26; and for Sub-circuit S05 and SO6 all CMLs were missing. 4.    -P123L060A did not indicate the location for CMLs 1, 3, 16, 17, 18, 19 and 20; 5.    -P123L040G did not indicate the location of CMLs 1, 5, 6, 7, 8, 9 6.    -P123L040F  did not indicate the location of CMLs 1-4 7.    -P123L040C  did not indicate the location of CMLs 1, 3, 4, 5, 6 8.    -P123L040B  did not indicate the location of CMLs 4, 5    ExxonMobil AIMS requires a separate examination and inspection of deadleg piping:    9.    -P123L060A  No UT examinations were conducted on piping circuit S01; a deadleg identified in 2004.    10.  -P123L040G   No UT examinations were conducted on piping circuit S01 and S02; a deadleg identified in 2009.    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 valve operations and maintenance program is implemented.  The violation must be abated no later than 30 days from the receipt of this citation.

Issued

2017-05-19 00:00:00

Abate by

2017-06-23 00:00:00

Penalty

Initial $12675.00 · Current $0.00 Reduced

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 did not ensure that the inspection and testing procedures for process equipment in the Alkylation Unit followed recognized and generally accepted good engineering practices such as, but not limited to API 510, and API 570.  a.    The period between external pressure vessel inspections exceeded five years for the following pressure vessels in the Alkylation Unit:    D-18, D-19, D-20, D-21, D-22, D-419, D-421     b.    The period between internal pressure vessel inspections exceeded ten years for the following pressure vessels in the Alkylation Unit:    D-20, D-21, D-419, D-420, D-421    c.    For Class 2 piping circuit P123L030-H, the period between external piping inspections exceeded five years and for UT examinations the period exceeded one-half of the remaining life of the piping equipment or ten years for the following TMLocations:    Circuit H     - TMLs 3, 6, 12, and 16AN, 16BN, 16CT Circuit S01  - TMLs 2, 5, 6, 8       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 periodic inspection are conducted within the timeframe prescribed in consensus standards such as API 510 and, API 570. The violation must be abated no later than 90 days from the receipt of this citation.

Issued

2017-05-19 00:00:00

Abate by

2017-06-23 00:00:00

Penalty

Initial $12675.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.     A. The employed did not ensure that a written management of change document was prepared and implemented for the change in the handle configuration for the following plug valves:     a.    valve located on piping circuit P130L130-F; remove gear-box and install valve handle; b.    valve located on piping circuit P126L120A remove gear-box and install valve handle; c.    valve located on piping circuit P119L100-N; remove gear-box and install valve handle; d.    valve located on piping circuit P119L100-F; remove gear-box and install valve handle; e.    valve located on piping circuit P130L130-F; remove gear-box and install valve handle; f.     valve located on piping circuit P119L100-H; remove gear-box and install valve handle; g.    valve located on piping circuit P119L100-H; remove gear-box and install valve handle; h.    valve located on piping circuit L120-G; remove gear-box and install valve handle; i.     valve located on piping circuit P130L120-C associated with E-25    B. The employed did not ensure that a written management of change document was implemented and prepared for valves reported as not functioning as designed:    a.       13089036-*FLEX* ALKY/ Gear operator                 8/7/2016     OSNO b.       13137654 - ETEIV541-VA P18A Suction Valve        9/10/2016   OSNO c.       13137737- Power -operated EBVs C-3 to C-2 ET     9/10/2016   OSNO d.       13149094 - Power-operated  EBVs C-2 to C-1          9/17/2016   OSNO e.       13169471 - ETEIV120-VA P-309 Isolation valve-.     10/01/2016  OSNO f.        13190109 - Gear operator broken                       10/12/2016  OSNO g.       13191935 - Gate valve broken                            10/21/2016  OSNO h.       13205163 - DISTILLATION-Battery Limit Val            10/22/2016  OSNO i.        13205164 - ALAX - Battery Limit Valve Sig                10/22/2016  OSNO j.        13205370 - Power-operated  EBVs C-2 Comp- flare    10/22/2016 OSNO k.       13205371 - Power -operated EBVs C-3 Suction-flare   10/22/2016 OSNO  l.        13205372 - Power -operated EBVs C-1to C-2             10/22/2016 OSNO  m.      13205373 - Power-operated EBVs  C-1Suction           10/22/2016 OSNO  n.       13205374 - Power-operated EBVs  C-2 Suction          10/22/2016  OSNO o.       13205375 - Power-operated EBVs C-2 Discharge        10/22/2016  OSNO p.       replace leaking valve located on piping circuit P123L040-D q.       replace leaking valve located on piping circuit P123L020-B r.        reduced port valves limit feed rate for C-3    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 written management of change evaluations are conducted as a result of changes to process  equipment.  The violation must be abated no later than 30 days from the receipt of this citation.

Issued

2017-05-19 00:00:00

Abate by

2017-06-23 00:00:00

Penalty

Initial $12675.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.   a. The employer did not certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. A compliance audit was last conducted at the ExxonMobil Baton Rouge refinery in 2013. No compliance audit was performed in 2016.  b. The employer did not certify that a compliance audit was conducted for the Alkylation Unit and/or included audit items from the Alkylation Unit to evaluate compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. The employer did not provide documentation that a compliance audit of the Alkylation Unit had been conducted every three years.  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 a compliance audit is completed for the Alkylation Unit.  The violation must be abated no later than 90 days from the receipt of this citation.

Issued

2017-05-19 00:00:00

Abate by

2017-06-23 00:00:00

Penalty

Initial $63375.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(ii): Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.   The employer did not ensure that the inspection and testing procedures for process equipment in the Alkylation Unit followed recognized and generally accepted good engineering practices such as, but not limited to API 570.  a.     The period between visual external piping inspections exceeded five years for Class 1 piping for the following piping circuits in the Alkylation Unit:    P123L060-A, P123L040-C, P123L040-D, P123L040-F, P123L040-G, P123L040-B    b.    For Class 1 piping, the period between UT examinations exceeded one-half of the remaining life of the piping equipment or five years for the following piping circuits (TMLocations):    P123L025-A  TMLs 4CE and 4CB P123L060-A TMLs 3AB, 3BN, and 3CE, 16, 17 P123L040-G TMLs 1, 5, 6, 7, 8, and 9 P123L040-F TMLs 1-4 P123L040-D TMLs 1, 2, 6, and 7 P123L040-C TMLs 1, 4, and 5    EXXONMOBIL WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD OR ITS EQUIVALENT STANDARD 29 CFR 1910.119(J)(4)(i), WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER #1138813, CITATION NUMBER 1, ITEM NUMBER 1a  AND WAS AFFIRMED AS FINAL ORDER ON AUGUST 29, 2016, WITH RESPECT TO A WORKPLACE LOCATED AT 5000 BAYWAY DRIVE, BAYTOWN, TEXAS 77522.    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 periodic inspections and evaluations are conducted within the timeframe prescribed in consensus standards such as API 570. The violation must be abated no later than 90 days from the receipt of this citation.