Violation Detail
Standard Cited: 19100119 F01 II Process safety management of highly hazardous chemicals.
This violation item has been deleted.
Inspection Nr: 312602147
Citation: 01003B
Citation Type: Serious
Abatement Status: X
Initial Penalty:
Current Penalty:
Issuance Date: 09/30/2009
Nr Instances: 4
Nr Exposed: 127
Abatement Date: 02/12/2010
Gravity: 10
Report ID: 0627400
Contest Date: 10/23/2009
Final Order: 04/16/2010
Related Event Code (REC):
Emphasis:
| Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
|---|---|---|---|---|---|---|
| Penalty | J: ALJ Decision | 04/16/2010 | 02/12/2010 | Serious | ||
| Penalty | Z: Issued | 09/30/2009 | 02/12/2010 | Serious |
Text For Citation: 01 Item/Group: 003B Hazard: REFINERY
29 CFR 1910.119(f)(1)(ii): The employer's written operating procedures did not address the requirements for the operating limits listed in 29 CFR 191.119(f)(1)(ii)(A) and (B): ALON USA, LP, 200 Refinery Road, Big Spring, TX. The employer does not include the consequences of deviation and the steps required to correct or avoid deviation in their written operating procedures for specific pressure vessels. The following information was not prepared and included in the 2008 Process Hazard Analysis. This violation was observed on or about April 15, 2009 in the following instances: a. The Alky Plant Air Knockout Drum, designated as 011D-036, carries compressed air at 85 psig. The Alky Plant written operating procedures do not include the operating limits of the Air Knockout Drum. The vessel carries no National Board data plate, nor is any information regarding this vessel on the file. No data could be found regarding the maximum allowable working pressure (MAWP) of this vessel. b. The Fuel Gas Treater written operating procedures do not include the operating limits of the diglycolamine (DGA) Surge Drum, designated as 010D-123. There is no documentation regarding the MAWP, other than a partially obliterated National Board plate. c. The #1 Sulfur Recovery Unit written operating procedures do not include the operating limits of the DGA Recovery Drum. The DGA Recovery Drum, designated as 069D-004, cleaned the fuel gas flow to the #1 Sulfur Recovery Unit. No National Board data plate was found on this vessel, and no documentation on file regarding the MAWP. d. The #1 Sulfur Recovery Unit written operating procedures do not include the operating limits of the Acid Gas Knockout Drum. The Acid Gas Knockout Drum, designated as 069D-002, in the #1 Sulfur Recovery Unit had no documentation on file regarding the maximum allowed working pressure (MAWP) for this pressure vessel. Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure that the consequences of deviation and steps required to correct or avoid deviations.s
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