Text For Citation: 01 Item/Group: 003 Hazard:

29 CFR 1910.119(e)(3)(iii): The Process Hazard Analysis did not address engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.) a) Philadelphia Energy Solutions Refinery Complex, 3144 Passyunk Ave, Philadelphia, PA 19145 - HF Alkylation Unit 433: On or about June 21, 2019, the employer's PHA did not address automatic activation of an emergency shutdown system such as the means to automatically shut down or isolate flammable releases adjacent to V-1, V-6, and P-14A/B upon detection of fire and gas leak, automatic activation of HF spray mitigation or firewater system, or other means such as a process deviation based on alarm set point (e.g. HF, flammable gas release, high pressure, high level etc.). Employees working on and in the vicinity of equipment containing highly hazardous chemicals are exposed to fire, explosion, toxics, and corrosive hazards.