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Violation Detail
Standard Cited: 19100119 L02 IV Process safety management of highly hazardous chemicals.
Inspection Nr: 313029233
Citation: 01011
Citation Type: Serious
Abatement Status: X
Initial Penalty: $2,500.00
Current Penalty: $5,000.00
Issuance Date: 08/19/2010
Nr Instances: 4
Nr Exposed: 7
Abatement Date: 09/07/2010
Gravity: 03
Report ID: 0625700
Contest Date: 09/10/2010
Final Order:
Related Event Code (REC):
Emphasis:
| Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
|---|---|---|---|---|---|---|
| Penalty | I: Informal Settlement | 12/17/2010 | $5,000.00 | 09/07/2010 | Serious | |
| Penalty | Z: Issued | 08/19/2010 | $2,500.00 | 09/07/2010 | Serious |
Text For Citation: 01 Item/Group: 011 Hazard: REFINERY
29 CFR 19101910.119(l)(2)(iv): The management of change procedures do not includ e the necessary time period for the change. This violation was observed on or ab out June 2, 2010 when it was noted that Request for Change (RFC)#836, initiated on 8/18/97, to raise the maximum allowable temperature for #1 Platformer Reactor s from 980 F to 1000 does not include the necessary time period for the change. The employer's standard form for their RFC (Calumet's MOC program) does not have a field to designate a target completion date or necessary time period. This is further evidenced in the following RFCs: RFC # 5444 initiated on 04/15/ 2010, for injecting caustic into liquid seal at #3 flare; RFC # 5458 issued on 0 4/26.2010, for installing pressure controllers on MEK; and RFC # 5461 issued on 04/29/2010 for injecting caustic into liquid seal at #3 flare. This lack of stat ed time management in the procedure could expose employees to fire and explosion hazards if the change is accomplished ineffectively. Pursuant to 29 C. F. R. 19 03.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation that it is in compliance with the standard, including updating their Request for Change form to include the necessary time period for the change.