OSHA Inspection: BLUE DOLPHIN ENERGY COMPANY

Issued

Sep 6, 2022

Abate by

Oct 24, 2022

Penalty

Initial $14,502 · Current $7,251 Reduced

General-duty citation text

29 CFR  1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices.   On or about May 4, 2022, the employer did not document that equipment complies with ASME Boiler and Pressure Vessel Code, Section VIII Division 1, 1968 Edition, Section UG-134 (g) (Pressure Relief Devices Installation) to ensure that pressure relief valves discharged to a safe location; including but not limited to the relief valve PSV-2210 on the Resid Heat Exchanger E-208A/B.

Issued

Sep 6, 2022

Abate by

Oct 24, 2022

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.145(c)(2)(i): Caution signs were not used to warn against potential hazards.   On or about May 4, 2022, the employer did not use caution signs to warn against potential hazards such as thermal burns and/or toxic gas release hazards from relief valves' discharge; including but not limited to discharge from the pressure safety valve PSV-2210 on the Resid Heat Exchangers E-208A/B. The PSV-2010 discharge piping was directed to the ground next to the heat exchangers and walkways.

Issued

Sep 6, 2022

Abate by

Nov 30, 2022

Penalty

Initial $14,502 · Current $7,251 Reduced

General-duty citation text

29 CFR  1910.119(e)(5): The employer did not establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.   On or about May 4, 2022, the employer did not resolve 2014 PHA recommendations in a timely manner, including but not limited to:    a. Consider the addition of hydrocarbon detectors with alarms and a steam deluge system be installed near the P 204 A/B Naphtha Pumparound Pumps. Consider dual seal pumps. (Risk ranking 2 Safe).   b. Consider the addition of hydrocarbon detectors with alarms installed near the P-207 A/B Pumparound Pumps. (Risk ranking 2 Safety).   c. Consider the addition of a high pressure alarm on the LPG tanks provided in the control room. (Risk ranking 2 Safety).

Issued

Sep 6, 2022

Abate by

Jan 3, 2023

Penalty

Initial $14,502 · Current $7,251 Reduced

General-duty citation text

29 CFR  1910.119(e)(6):At least every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section, to assure that the process hazard analysis is consistent with the current process.  On or about May 4, 2022, the employer did not update and revalidate the 2014 process hazard analysis (PHA) to assure that the process hazard analysis was consistent with the current process.

Issued

Sep 6, 2022

Abate by

Jan 3, 2023

Penalty

Initial $14,502 · Current $7,251 Reduced

General-duty citation text

29 CFR  1910.119(j)(4)(i): Inspections and tests were not performed on process equipment.   On or about May 4, 2022, the employer did not perform  inspections and tests on process equipment including but not limited to the following piping circuits: a.  8"-HC-2030-3"H-B1(P-202 Crude Booster Pump discharge). P&ID M-02. b.  8"-HC-2178-3 ?"H-B1 (P-202 Crude Booster Pump suction). P&ID M-02. c.  3"-HC-2005-N-A1 (P-203A/B discharge line). P&ID M-06. d.  3"-HC-3011-1 ?"-A1 (C-301 Overhead). P&ID M-07. e.  4"-HC-3036-4"H-B1 (C-301 bottom to E-302), P&ID M-07 and f.  8"-HC-3031-3"H-B1 (E-307 Overhead to C-302). P&ID M-09

Issued

Sep 6, 2022

Abate by

Jan 3, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.119(j)(2): Written procedures. The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment. On or about May 4, 2022, the employer did not establish and implement written procedures for inspection and testing piping including Corrosion Under Insulation (CUI) procedure.

Issued

Sep 6, 2022

Abate by

Oct 24, 2022

Penalty

Initial $14,502 · Current $7,251 Reduced

General-duty citation text

29 CFR  1910.119(j)(5): The employer did not correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.   On or about May 4, 2022 the employer did not correct deficiencies in equipment, including but not limited to the piping support of the crude discharge piping from P-202 (Crude Booster Pump) to E-204 (Kerosene/Crude Heat Exchanger).

Issued

Sep 6, 2022

Abate by

Jan 3, 2023

Penalty

Initial $14,502 · Current $7,251 Reduced

General-duty citation text

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.   On or about May 4, 2022, the employer did not perform compliance audits every 3 years since 2012 for the crude unit to verify that the procedures and practices developed under the standard are adequate and are being followed.

Issued

Sep 6, 2022

Abate by

Jan 3, 2023

Penalty

Initial $14,502 · Current $7,251 Reduced

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.   On or about May 4, 2022, the employer did not ensure periodic visual external inspections for pressure vessels was consistent with their adopted RAGAGEP, API 510 June 2006 Edition, section 6.4.1 "Unless justified by an RBI assessment, each aboveground vessel shall be given a visual external inspection at an interval that does not exceed the lesser of five years or the required internal/on-stream inspection". Periodic visual external inspections were not performed on the following vessels:  i. D-203 (Overhead Accumulator). (P&ID M-06) ii. D-301 (Stabilizer Feed Surge Drum). (P&ID M-07) iii. C-302 (Depropanizer Column). (P&ID M-09) iv. E-208A and E-208B (Crude/Hot Resid Exchanger). (P&ID M-03)