Text For Citation: 01 Item/Group: 014 Hazard: REFINERY

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the conse quences of failure of engineering and administrative controls: a) The employer d oes not ensure that the 400 Unit process hazard analysis (PHA), dated October 13 , 2009, addresses the consequences of failure of engineering and administrative controls. "Node 5: T-401 and associated piping", lists "no consequence of intere st" for items such as more flow, less flow, more pressure, and less pressure, wi th no possible causes, safeguards or recommendations listed. The consequences of failure from conditions such as high temperature, high pressure, low flow, high flow, reverse flow will result in administrative controls (i.e., alarms, implem entation of emergency operating procedures, manual closing of valves, training) and engineering controls (relief valves, rupture discs, flare system, automatic closing of valves) being put into effect. The consequences of failure of these controls are not inc luded in the PHA. More pressure and more flow can result in conditions leading t o catastrophic equipment failure and the potential release of hydrocarbons. By n ot evaluating the consequences of deviation, including those affecting the safet y and health of employees, the employer was deprived of critical information use d to ensure process stability and employee safety and health. This violation was documented on or about December 20, 2010. b) The employer does not ensure that the 400 Unit process hazard analysis (PHA), dated October 13, 2004, addresses th e consequences of failure of engineering and administrative controls. "Node 5.4: PSV to Flare", lists "no consequence of interest" for items such as more flow, reverse flow, and more pressure, with no possible causes, safeguards or recommen dations listed. The consequences of failure from conditions such as high tempera ture, high pressure, low flow, high flow, reverse flow will result in administra tive controls (i.e., alarms, implementation of emergency operating procedures, manual closing of valves, trai ning) and engineering controls (relief valves, rupture discs, flare system, auto matic closing of valves) being put into effect. The consequences of failure of t hese controls are not included in the PHA safeguards, or recommendations listed. More pressure and more flow can result in conditions leading to catastrophic eq uipment failure and the potential release of hydrocarbons. By not evaluating the consequences of deviation, including those affecting the safety and health of e mployees, the employer was deprived of critical information used to ensure proce ss stability and employee safety and health. This violation was documented on or about December 20, 2010. Pursuant to 29 CFR 1903.19, within ten (10) calendar d ays of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including the steps that it is taki ng to ensure that employees are not being exposed to highly hazardous chemicals.