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

Violation Items
Nr: 311611081 Citation: 02031B Issuance: 03/08/2010 ReportingID: 0524700
Viol Type:WillFul NrInstances:5 Contest Date:03/31/2010
Abatement Date:04/19/2010 Nr Exposed:40 Final Order:
Initial Penalty: REC: Emphasis:
Current Penalty: Gravity:10 Haz Category:REFINERY



Text For Citation: 02 Item/Group: 031B Hazard: REFINERY
29 CFR 1910.119(e)(3)(i): The process hazard analysis does not address the hazards of the process: BP-Husky Refining, LLC - Oregon, Ohio: The employer does not address in the process hazard analyses, the existence of permanent connections between the plant fire water system and process systems that could lead to the contamination of fire water supply with hydrocarbons or other process fluids, in that, a. In the Isocracker 2 Unit, there is a cross connection at the 6" supply water to the cooler box on the east side of the unit; b. In the Hydrogen Unit there are two cross connection instances on the blowdown drum; c. In the Sulfur Recovery Unit, there are two filter backwash cross connections; d. In the Reformer 2 regeneration system, there is a cross connection between the quench and cooling water; e. There are cross connections on the discharge sides of the fire water booster pumps in the FCC Unit. Pursuant to 29 CFR 1903.19, within the (10) calendar days of the abatement date, the employer must submit documentation that it has abated the hazard. In addition, udner 29 CFR 1903.19(e), the employer, must submit an abatement plan describing the actions it is taking to ensure that it is in compliance with the standard. The abatement plan shall establish dates during the next three months to determine when applicable PHA's will be updated to address the hazards of cross contamination of fire water with process water. Once the plan has been fully implemented, the employer must submit certification of its full compliance with the standard.e