Standard Cited:19100119 E03 VI Process safety management of highly hazardous chemicals.

Violation Items
Nr: 311611081 Citation: 01006 Issuance: 03/08/2010 ReportingID: 0524700
Viol Type:Serious NrInstances:6 Contest Date:03/31/2010
Abatement Date:04/19/2010 Nr Exposed:25 Final Order:
Initial Penalty:5000.00 REC: Emphasis:
Current Penalty:5000.00 Gravity:10 Haz Category:REFINERY



Text For Citation: 01 Item/Group: 006 Hazard: REFINERY
29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors: a.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer's 2006 Alky 1 PHA claim human actions as safeguards and did not address human factors, such as, but not limited to, an operator's inability to manually drain water from the reactor when a slug of water in the Butylene feed coalescer could cause carryover of water into the reactor which could result in acid runaway, or freezing and rupture of the line. b.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer's 2006 Alky 1 PHA claim human actions as safeguards and did not address human factors, such as, but not limited to, an operator's inability to operate the Alky 1 Iso Recycle in manual mode which could result in flow being cut to processes in Alky 2 or 3 and lead to a major process upset. c.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer's 2006 Alky 1 PHA claim human actions as safeguards and did not address human factors, such as, but not limited to, an operator's inability to follow training and/or procedures to supply condensate to the first stage reactor which could result in process upset. d.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer's 2006 Alky 1 PHA claim human actions as safeguards and did not address human factors, such as, but not limited to, an operator's inability to close the block valve in the reflux line which could result in the over-pressurization of the debutanizer tower. e.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer did not ensure the 2008 FCC PHA considered human factors, in that, an isolation valve in the blower discharge line may require more than one operator to close it during an emergency shutdown. f.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer did not ensure the Alky 1 PHA considered the ability of employees to respond to acid releases in inclement and cold weather while wearing level A protective suits and SCBAs. In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification. This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.t,