Text For Citation: 01 Item/Group: 013B Hazard: REFINERY

29 CFR 1910.119(e)(3)(v): The process hazard analysis (PHA) did not address facility siting: The employer does not address facility siting during PHA's regarding relief system equipment that discharges to atmosphere. This violation was observed on or about February 4, 2009, and at times prior thereto, for the 1995 Crude Unit PHA (and subsequent PHA revalidations) the employer does not consider the siting of its employees or facilities in relation to hydrocarbon releases from relief system equipment that discharges to the atmosphere. a) In the CDU: Work platforms within 50 feet of the discharge from the vent stack from FA- 24, blowdown drum, expose employees to fire and explosion from hydrocarbons and inhalation of toxic hydrogen sulfide. Heavier than air hydrocarbons can be released from the vent stack, collect at ground level, and cause vapor cloud explosions. b) In the CDU: Work platforms within 50 feet of the FA-1, atmospheric tower, relief valves expose employees to possible fire and explosion from hydrocarbon releases. c) In the CDU: FA-18, stabilizer tower, relieves to atmosphere near the crude unit heaters exposing employees to possible fire and explosion from hydrocarbon releases. Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation describing the steps that it is taking to ensure that the discharge of hydrocarbons from FA-24 blowdown drum, FA-1 atmospheric tower and FA-18 stabilizer tower is to a safe location.r