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Violation Detail
Standard Cited: 19100119 E05 Process safety management of highly hazardous chemicals.
Inspection Nr: 312380512
Citation: 01015
Citation Type: Serious
Abatement Status:
Initial Penalty: $6,300.00
Current Penalty: $6,300.00
Issuance Date: 08/04/2009
Nr Instances: 3
Nr Exposed: 180
Abatement Date: 08/17/2009
Gravity: 10
Report ID: 0627700
Contest Date: 08/24/2009
Final Order:
Related Event Code (REC):
Emphasis:
Text For Citation: 01 Item/Group: 015 Hazard: REFINERY
29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address process hazard analysis (PHA) team findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions: The employer does not establish a system to promptly address action items from the process hazard analysis. The employer violated this standard for multiple PHA's and PHA revalidations covering approximately 16 years. The employer violated this standard on or about February 4, 2009, and at times prior thereto, where the employer does not resolve action items from process hazard analysis in a timely manner. a) In the CDU: A PHA recommendation was made to install a high level alarm on the FA- 24 knockout drum in the initial 1995 PHA and subsequent PHA revalidations and was not installed until June 2008 (13 years). b) In the CDU: A PHA recommendation was made to investigate moving the vent line from the FA-24 knockout drum away from the atmospheric tower in the initial 1995 PHA and subsequent PHA revalidations; however, the vent line remains in the same condition. c) In the FCCU: The employer did not install H2S monitors to address the hazard of hydrogen sulfide identified in the 1995 PHA and subsequent PHA revalidations. 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 the findings, recommendations, and resolutions for process hazard analysis are promptly addressed. The employer must document what actions are to be taken, develop a written schedule of when the actions are to be completed, and communicate the actions to affected employees.