Text For Citation: 01 Item/Group: 004 Hazard:

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the consequences of failure of engineering and administrative controls: 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 failed to address the consequences of failure of engineering controls such as the need for an independent active firewater protection system to protect V-1 and V-6 from flame impingement due to a jet fire. The existing elevated monitor (Monitor # 1) which serves the HF spray mitigation system can only provide limited firewater to V-1/V-6, but was unavailable during the fire/explosion event. Employees working on and in the vicinity of equipment containing highly hazardous chemicals are exposed to fire, explosion, toxics, and corrosive hazards. b) 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 failed to address consequences of failure of engineering controls such as the need for fireproofing of V-1, V-6 and associated pipe supporting P-14A/B, where the un-fireproofed equipment and piping support structures, and the inadequate spacing between vessels resulted in fire spreading due to jet fire impingement. Employees working on and in the vicinity of equipment containing highly hazardous chemicals are exposed to fire, explosion, toxics, and corrosive hazard.