OSHA Inspection: SUPERIOR REFINING COMPANY, LLC.

Issued

Oct 2, 2018

Abate by

Apr 2, 2021

Penalty

Initial $11,641 · Current $11,641

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): The employers relief system design and design calculation for 15G-SV006, High Pressure Receiver Relief Valve and the flare were not adequately performed:    a) Superior Refining Company; On or about April 26, 2018, the 15G-SV006 relief valve sizing document provided indicated the calculations were  performed for pressure relief of the High Pressure Receiver (15G-V07), Primary Absorber (15G-V08), Sponge Absorber (15G-V09) and Water Knockout Drum (15G-V13). The calculations failed to include piping and vessels from the discharge of the gas compressors to the Stripper Column (including the High Pressure (HP) Receiver Condensers, HP Receiver, HP Receiver Water Knockout Drum, Primary Absorber, Sponge Absorber, and Stripper Column).    b) Superior Refining Company; On or about April 26, 2018, the 15G-SV006 relief valve sizing document backpressure calculation included the discharge piping and elbows to the flare header (measuring less than 30 feet total length); however, the calculation failed to include the full length to the flare (flare header continues for over 100 feet to the flare), as well as, the possible flows and pressures from other relief devices in the common flare header.

Issued

Oct 2, 2018

Abate by

Apr 2, 2021

Penalty

Initial $11,641 · Current $11,641

General-duty citation text

29 CFR 1910.119(d)(3)(iii): For existing equipment designed and constructed in accordance with codes, standards, or practices no longer in general use, the employer did not determine and document that the equipment in the process was designed, maintained, inspected, tested, and operating in a safe manner (i.e. fit-for-service):    a) On or about April 26, 2018, the employer failed to determine equipment constructed of ASTM A-212 steel was fit-for-service.    Recommended Abatement: The employer will perform a fitness for service analysis on vessels constructed of A-212 steel in accordance with ASME Boiler and Pressure Code Section VIII, API 510, and API 579-1/ASME FFS-1, prior to returning them to service.

Issued

Oct 2, 2018

Abate by

Apr 2, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(ii): The employers inspection and testing procedures did not follow recognized and generally accepted good engineering practices:    a) On or about April 26, 2018, the employer failed to perform a fitness for service analysis on equipment constructed of ASTM A-212 steel.     Recommended Abatement: The employer will perform a fitness for service analysis on vessels constructed of A-212 steel in accordance with ASME Boiler and Pressure Code Section VIII, API 510, and API 579-1/ASME FFS-1, prior to returning them to service.

Issued

Oct 2, 2018

Abate by

Apr 2, 2021

Penalty

Initial $11,641 · Current $11,641

General-duty citation text

29 CFR 1910.119(e)(3)(i): The employer has not identified critical hazards of the process in the Process Hazard Analysis (PHA):    b) Superior Refining Company; On or about April 26, 2018, the employer did not adequately address the hazards associated with shutdowns, including but not limited to, the hazards associated with operation in manual mode, distractions from additional operators and workers in areas, introduction of air or other materials into the systems, deviations from procedures, inerting and purging of equipment, and other abnormal conditions and situations experienced during shutdowns.

Issued

Oct 2, 2018

Abate by

Apr 2, 2021

Penalty

Initial $0 · Current $11,641

General-duty citation text

29 CFR 1910.119(f)(1)(ii):  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 addressing   consequences of deviation and the steps required to correct or avoid deviations per 1910.119(f)(1)(ii)(A) & (B):    (a) On or about April 26, 2018, the standard operating procedures did not contain the operating parameters, consequences of deviation from those parameters, and the steps required to avoid and correct the deviations.

Issued

Oct 2, 2018

Abate by

Apr 2, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(iv): The employer failed to ensure operating procedures included safety systems and their functions:     (a) Superior Refining Company; On or about April 26, 2018, information on safety systems and their functions were not addressed and implemented in operating procedures such as, but not limited to, OPP0563 - Fluid Catalytic Cracking Unit (FCCU), Gas Concentration, Merox, and C3C4 Splitter Shutdown and OPP0590 Loss of Catalyst Level from Regenerator.

Issued

Oct 2, 2018

Abate by

Apr 2, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(2): Operating procedures were not readily accessible to employees who work in or maintain a process area:      (a) The Superior Refining Company; On or about April 26, 2018, operating procedures for the Fluid Catalytic Cracking Unit (FCCU), Gas Concentration Unit, and the Alkylation Unit were not provided with safe upper and lower limits, the consequences of deviation, and the steps required to correct or avoid deviations as the operating procedures referred the operators to other documents that were not always readily available in events such as, but not limited to, loss of power, loss and/or malfunction of operating system, or some other event.

Issued

Oct 2, 2018

Abate by

Apr 2, 2021

Penalty

Initial $11,641 · Current $11,641

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:    (a) During the 2008 and 2013 turnarounds, where inspection findings of outside contractor on the spent catalyst slide valve showed erosion, the employer did not ensure generally accepted good engineering practices before placing the spent catalyst slide valve back into service.    Recommended Abatement:  Prior to placing equipment back into service, inspection and tests of equipment should be addressed per the facilitys Mechanical Integrity Program and recognized and generally accepted good engineering practices.

Issued

Oct 2, 2018

Abate by

Apr 2, 2021

Penalty

Initial $11,641 · Current $11,641

General-duty citation text

29 CFR 1910.119(l)(3): Employees involved in operating a process, as well as, maintenance and contract employees whose job tasks would be affected by a change in the process were not informed of, and trained in the change, prior to the process commencing:     a) Superior Refining Company; On or about April 26, 2018, employees were not adequately trained on operating procedure OPP0563 (dated 4/25/18) Fluid Catalytic Cracking Unit (FCCU), Gas Concentration, Merox, and C3C4 Splitter Shut-down utilized during the shutdown; changes were made to the procedure including, but not limited to, the addition of vapor phase cleaning, the order in which shutdown was performed, and when equipment was blinded.

Issued

Oct 2, 2018

Abate by

Apr 2, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(l)(5): A change covered by this paragraph resulted in a change in the operating procedures or practices required by paragraph (f) of this section, and such procedures or practices were not updated accordingly:    a) Superior Refining Company; On or about April 26, 2018, adequate management of change procedures were not performed prior to utilization of operating procedure OPP0563 (dated 4/25/18) Fluid Catalytic Cracking Unit (FCCU), Gas Concentration, Merox, and C3C4 Splitter Shut-down; changes were made to the procedure including, but not limited to, the addition of vapor phase cleaning, the order in which shutdown was performed, and when equipment was blinded.