Text For Citation: 01 Item/Group: 006A Hazard: REFINERY

29 CFR 1910.119(f)(1): The employer did not develop or implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process: The employers written operating procedures listed below did not provide clear instructions for safely conducting activities involved in each covered process: a) 33-06-06 - Putting Propane Scrubber Online,11/15/99. The procedure does not provide a description of location for the inlet and outlet block valves. b) 33-07-01 - Bypass Reactor, 07/21/03. Procedure references "valves" but does not identify how many and how they may be identified, and or give a location description. c) 33-08-01 - Bypass Contactor, 11/23/99. Procedure references "valves" but does not identify how many. Procedure states "Caution Excess flush pressure on contactor will have to be relieved to acid storage drum", but does not give a value for excess flush pressure. d) 33-11-11 - Temporary, Operating the Isostripper With (1) PSV Removed, 11/10/06. The Hi Alarm noted in the procedure was identified by the employer as a critical alarm. There is no note indicating a temporary MOC is needed to set the alarm levels as indicated. The procedure also states two values for the setting of the high alarm. ("Set the Hi-Alarm on AAPC at 155# and the Hi-Alarm at 160#) e) 33-13-01 - Line up a Recycle Pump, 12/10/99. Procedures references "valves" but does not identify how many and how they may be identified, and or give a location description. f) 33-20-05 - Sat Gas Startup, 12/11/00. Procedure references "valves" but does not identify how many and how they may be identified, and or give a location description. g) 33-36-01 - Alky Shutdown, O5/23/02. Procedure references "valves" and "drains" but does not identify how many and how they may be identified, and or give a location description. h) 33-06-04 - Bypass Alumina Treater, 10/23/06. Procedure references "valves" but does not identify how many. i) 33-37-02 - Start Steam Turbine Water Pump & 12 C.T. (P2183), 12/20/06. Procedure references "valves" but does not identify how many and how they may be identified, and or give a location description. j) 33-37-03 - Emergency Shutdown of Isostripper Reboiler Due to Tube Failure, 10/17/06. Procedure references "valves" but does not identify how many, how they may be identified, and or give a location description. k) 33-37-04 - Seal Failure on North Drying Tower Pump Motor, 03/07/06. Procedure references "valves" but does not identify how many and how they may be identified, and or give a location description. l) 33-37-05 - Emergency Alky Shutdown Due to Loss of Recycle Pump Seals, O5/24/06. Procedure references "valves" but does not identify how many. m) 33-37-06 - H.F. Acid Regenerator Overhead Cooler Leak Shell Side, 07/23/01. Procedure has a "Caution" which states "Depending on severity of leak and wind direction, SOP may very." There is no information that relates as how the procedure may vary beyond this statement. n) 33-37-09 - Emergency Shutdown Due to Loss of Cooling Water, 12/18/06. Procedure identifies B&F operators to "Take feed out of Contactor and Reactor", but does not identify how this is done, nor does it refer to any other procedure(s). Procedure identifies B&F operators to "Take south partial offline, Depressure and empty", but does not identify how this is done, nor does it refer to any other procedure(s). o) 35-20-04 - Bypassing the Super Heater, 12/11/02. Procedure identifies B&F operators to "BYPASS gas con", but does not identify how this is done, nor does it refer to any other procedure(s). p) 35-22-01 - Loss of Power at FCC, 09/20/06. Procedure references "valves" but does not identify how many and how they may be identified, and or give a location description. q) 35-30-09 - Steam Reactor, 03/27/07. Procedure references "valves" but does not identify how many and how they may be identified, and or give a location description. r) 35-30-23 - Putting 35FC202 Charge Heater By-Pass into Service, 08/29/06. Procedure references "valves" but does not identify how many and how they may be identified, and or give a location description. s) 35-32-01 - ESD Due to Loss of High Pressure BFW, 07/12/06. Procedure references "valves" but does not identify how many and how they may be identified, and or give a location description. Employees were exposed to release of volatile organic compounds (VOC)s to atmosphere that have resulted in explosion and fire leading to death and injury to persons in or near the facility. 29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is completed.