Standard Cited:19100119 L01 Process safety management of highly hazardous chemicals.

Violation Items
Nr: 311611081 Citation: 01012 Issuance: 03/08/2010 ReportingID: 0524700
Viol Type:Serious NrInstances:7 Contest Date:03/31/2010
Abatement Date:04/19/2010 Nr Exposed:250 Final Order:
Initial Penalty:5000.00 REC: Emphasis:
Current Penalty:5000.00 Gravity:10 Haz Category:REFINERY



Text For Citation: 01 Item/Group: 012 Hazard: REFINERY
29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process: a.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer failed to ensure the management of change (MOC) procedure was implemented for changes or additions made to operating procedures and alarm set points on the DCS. The employer permitted a project to take place outside of the MOC procedure in which approximately 47 changes or additions were made to operating procedures and 58 changes or additions were made to alarm set points in multiple units across the refinery, including the FCC and Alky Units. b.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer failed to ensure the established management of change (MOC) procedure had been conducted for changes to tube bundle metallurgy in the Vacuum Bottoms/Naptha exchanger (PR-543676) in the Crude Vac 1 Unit. The metallurgy was changed to 9-Cr and 5-Cr in January 1996; it was changed again to all 9-Cr tubes and carbon steel tube sheets in October 1998. c.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer failed to ensure the management of change (MOC) procedure was implemented for changes made to the naphtha treater furnace, crude 1 furnace and the crude vac furnace fuel gas and pilot gas lines. The furnaces' fuel and pilot gas lines were changed from 304 stainless steel to 316L stainless steel. d.BP-Husky Refining, LLC - Oregon, Ohio: On or about October 4, 2009, the employer did not conduct an MOC when replacing approximately 130 feet of 12 and 18 inch flare piping STD A106 Grade B with XS A106 Grade B carbon steel piping in piping circuits 13000 and 13010 in the Alky 1 unit. e.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 29, 2009, the employer did not conduct an MOC when continuing operations after a second leak was discovered on the flare line in the Alky 1 unit and no temporary repair was made. f.BP-Husky Refining, LLC - Oregon, Ohio: The employer did not conduct an MOC when changing the maximum inspection interval for piping circuits from the TML level to the circuit level which permitted some TML's to become overdue. g.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer failed to ensure the management of change (MOC) procedure was followed for the decommissioning of the Steam Separator (PR11069). 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 purchaseor repair of the equipment, photographic or video evidence of abatement, or other written records.t,