Text For Citation: 01 Item/Group: 008 Hazard: REFINERY

29 CFR 1910.119(e)(3)(iii): The process hazard analysis does not address the engineering and administrative controls applicable to the hazards and their interrelationship, such as, appropriate application of detection methodologies to provide early warning of releases. (a) This violation occurred on or about January 27, 2009, and times prior thereto, where the employer's process hazard analysis (1995, 1997, 2001 and 2006) conducted for the #2 Crude Unit did not address any controls and devices to provide early warning of releases. The Company has 6 LEL monitors (Sensor 1 to 6), 6 hydrogen sulfide monitors (A1-710, A1-710B, A1-712A A1-745, A1-106-N, A1-106S), 2 flare (F-400) pilot temperature transmitters ( Flare T1 and T2), 4 level transmitters ( 2 high level and 2 low level on 2 level gages (Flare Knock-out Pot D-514 and Flare Level Gage) which were not considered in the PHA's. This condition exposed employees to a fire and explosion hazards. Pursuant to 29 CFR 1903.19(d), within 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 it is taking to ensure that the process safety information is collected for each detection device and utilized in the process hazard analysis and mechanical integrity program